diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731941/EFTA02731941.md b/marker2/court-redacted-v-indyke-10479/EFTA02731941/EFTA02731941.md new file mode 100644 index 0000000000000000000000000000000000000000..757c0310b07586ec4a6353248d854f313bad37bc --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731941/EFTA02731941.md @@ -0,0 +1,210 @@ +### UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK + +Plaintiff, CASE NO: + +v. + +DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +# COMPLAINT + +Bows SCHILLER FLEXNER LLP + +Plaintiff by her attorneys Boies Schiller Flexner LLP, for her Complaint against Defendants, Darren K. Indyke and Richard D. Kahn in their capacities as the executors of the Estate of Jeffrey Edward Epstein ("Epstein"), avers upon personal knowledge as to her own acts and status and upon information and belief and to all other matters as follows: + +#### NATURE OF THE ACTION + +- I. This suit arises out of Jeffrey Epstein's sexual abuse of Plaintiff beginning when Plaintiff was 20 years old that lasted years and included trafficking Plaintiff to each of his homes in the United States and Paris. +- 2. Plaintiff was a young girl living in with hopes of becoming a model when she was approached by one of Epstein's recruiters about a prospective modeling opportunity in the United States and invited to a restaurant to meet Epstein, who was dining with a former high U.S. Government official, a famous actor, and a well-known comedian. What appeared on the outside as a legitimate opportunity to break into the modeling business in the United States turned into years of horrific abuse and manipulation at the hands of Jeffrey Epstein. +- 3. Epstein's trafficking scheme involved recruiting young females by making false promises and using his wealth, power and threats to intimidate the females into submission to his demands. This same pattern was repeated numerous times with numerous young women. +- 4. As United States District Judge Kenneth Marra found, "From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls . . . at his mansion in Palm Beach Florida, and elsewhere in the United States and overseas. . . . In addition to his own sexual abuse of the victims, Epstein directed other persons to abuse the girls sexually. Epstein used paid employees to find and bring minor girls to him. Epstein worked in concert with others to obtain + +minors not only for his own sexual gratification, but also for the sexual gratification of others." Doe 1 v. United States, 359 F. Supp. 3d 1201, 1204 (S.D. Fla. 2019) (internal citations omitted). + +5. Epstein organized this sex trafficking network to obtain hundreds of young females for himself for sex, and also lent these females out to other powerful and wealthy individuals to be sexually abused. + +6. Epstein conspired with others and hired staff to maintain and keep secret this network of sexual abuse for years, which sprawled throughout Epstein's residences in New York, Florida, New Mexico, the United States Virgin Islands, and Paris. Epstein's preference was to have three different young females a day for his sexual pleasure. + +7. Despite his significant criminal activity, in 2008 Epstein received a shockingly minimal charge, pleading guilty to a single Florida state law charge of procuring a minor for prostitution and a non-prosecution agreement (a "NPA") with the U.S. Attorney for the Southern District of Florida. Unknown to the public and the victims at the time, Epstein's lawyers were pressuring the Government to commit to the NPA without informing the victims. Epstein's multiple victims were kept in the dark and told to be "patient" while Epstein's lawyers worked to protect him and other potential co-conspirators from prosecution. Epstein served one year in jail, but was afforded the privilege of being able to leave the jail to go to work for twelve hours per day, six days per week. + +8. The NPA allowed Epstein to escape proportionate punishment for his actions and to continue operating his sex trafficking enterprise with liberty. + +9. A few years later, Epstein flippantly referred to his sexual abuse of multiple minors, and the slap on the wrist he had received for it, in a 2011 interview with the New York Post: "Billionaire pervert Jeffrey Epstein is back in New York City — and making wisecracks about his just-ended jail stint for having sex with an underage girl. 'I am not a sexual predator, I'm an offender,' the financier told The Post yesterday. 'It's the difference between a murderer and a person who steals a bagel,' said Epstein." Amber Sutherland, Billionaire Jefrey Epstein: I'm a Sex Offender Not a Predator, N.Y. Post (Feb. 25, 2011), + +https://nypost.com/20I I/02/25/billionaire-jeffrey-epstein-im-a-sex-offender-not-a-predator/. + +10. In August 2018, just one year before his death, Epstein told a New York Times reporter "that criminalizing sex with teenage girls was a cultural aberration and that at times in history it was perfectly acceptable." James B. Stewart, The Day Jeffrey Epstein Told Me He Had Dirt on Powerful People, N.Y. Times (Aug. 12, 2019), + +https://www.nytimes.com/2019/08/12/business/jeffrey-epstein-interview.html. + +II. When Plaintiff was 20 years old, Epstein added her to his long list of victims by committing sexual assault and battery against her. As such, Epstein is responsible for battery and intentional infliction of emotional distress pursuant to New York common law. The damage to Plaintiff has been severe and lasting. + +12. This action has been timely filed pursuant to N.Y. C.P.L.R. § 215(8)(a), which provides that a plaintiff shall have at least one year from the termination of a criminal action against the same defendant to commence an action with respect to the event or occurrence from which the criminal action arose. A criminal action against Epstein with respect to the same sex trafficking enterprise from which Plaintiff's claims arise was terminated on August 29, 2019. + +13. This action has also been timely filed pursuant to N.Y. C.P.L.R. § 213-C, which provides that a plaintiff shall have 20 years to file civil claims "for physical, psychological or other injury or condition suffered by such person as a result of conduct which would constitute rape in the + +first degree as defined in section 130.35 of the penal law." Epstein raped Plaintiff within 20 years of filing this Complaint. + +14. Any statute of limitations applicable to Plaintiff's claims, if any, is tolled due to the continuous and active deception, duress, threats of retaliation, and other forms of misconduct that Epstein and his co-conspirators used to silence his many victims, including Plaintiff. Epstein's actions deprived Plaintiff of the opportunity to commence this lawsuit before his death. Until his death, Plaintiff feared that Epstein and his co-conspirators would harm her or her family, or ruin her life, if she came forward. + +15. Defendants are equitably estopped from asserting a statute of limitations defense. Allowing Defendants to do so would be unjust. Epstein and his co-conspirators intimidated each of his victims into silence by threatening their lives and their livelihoods. They therefore prevented Plaintiff from commencing this lawsuit before his death. By using threats, along with his wealth and power, Epstein was able to escape punishment for his intolerable and brutal crimes against countless young women and underage girls for the duration of his life. + +### PARTIES + +16. Plaintiff is a citizen and resident of + +17. Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the Estate of Jeffrey E. Epstein. + +18. Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the Estate of Jeffrey E. Epstein. + +## JURISDICTION AND VENUE + +19. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at the time of his death. Jeffrey Epstein maintained a residence in the Southern District of New + +York. As the legal representatives of the Estate of Jeffrey E. Epstein, Darren K. Indyke and Richard D. Kahn are deemed citizens of the U.S. Virgin Islands. + +20. The amount in controversy in this action exceeds the sum or value of \$75,000.00 excluding interests and costs and is between citizens of different states. Accordingly, jurisdiction is proper under 28 U.S.C. § 1332. + +21. Venue is proper in this Court as Epstein's sexual abuse of Plaintiff began in New York, New York, where he recruited her at the age of 20 and began grooming her for sex in his organized sex trafficking ring. + +22. Many of the events giving rise to these causes of action occurred in the Southern District of New York, where a substantial amount of Epstein's property is located. Thus, venue in this district is proper. 28 U.S.C. § 1391(b)(2). + +## FACTUAL ALLEGATIONS + +## A. Epstein's Sex Trafficking Enterprise + +23. Jeffrey Epstein was widely renowned as a billionaire who used his vast connections to powerful individuals, and seemingly unlimited wealth and resources, to create a web of transcontinental sex trafficking that served himself, his co-conspirators, and some of the most powerful people in the world. + +24. Epstein owned multiple residences and frequently travelled between them, including at 9 East 71' Street, New York, New York 10021, and at 49 Z,orro Ranch Road, Stanley, New Mexico 87056, where the illegal sexual crimes against Plaintiff occurred. Epstein conservatively valued his New York townhome at \$55,931,000.00. Epstein conservatively valued his New Mexico ranch at \$17,246,208.00. In addition, Epstein owned residences in the Virgin Islands, Florida, and France, and even on his own island, Great St. James Island, where his + +transcontinental sex trafficking of hundreds of young females servicing him, his co-conspirators, and wealthy and powerful individuals around the world occurred. + +25. The allegations herein concern Epstein's tortious acts against Plaintiff while at Epstein's mansion in New York, his home in Florida, his home in the Virgin Islands, his apartment in Paris, and his New Mexico ranch. + +26. At all times material to this cause of action, Jeffrey Epstein utilized his seemingly unlimited power, wealth, and resources, as well as his deep connections to powerful and politically connected individuals to intimidate and manipulate his victims of sexual abuse. + +27. Epstein and his co-conspirators had perfected a scheme for manipulation and abuse of young females. As part of the scheme, a female "recruiter" would approach a young female and strike up a conversation in an effort to quickly learn about the young female's background and any vulnerabilities they could expose. The recruiter would then manipulate the young female into coming back to one of Epstein's residences by offering the young female something she needed. At times the recruiter's lure would be a modeling opportunity, money for education, help for the young female's family, and a whole host of other related offers depending on their target's situation. Once in the residence, the recruiter and Epstein would work in concert to impress and intimidate the young female with displays of vast wealth, including having employees that were butlers and maids formally dressed around the house. They would also strategically place photographs of very powerful political and social figures amongst photographs and art displaying nude females in an effort to normalize the sexual abuse. They would also normalize the sexual abuse by placing a massage table and spa related products around the massage area in an effort to legitimize the area where the abuse was set to occur. Once abused, Epstein and his co-conspirators continued to manipulate the victims, using their + +financial power, promises, and threats to ensure that the victim returned as directed and remained compliant with their demands. + +#### B. The Arrest, Prosecution, and Death of Epstein + +28. The sexual trafficking ring described herein started at least as early as 1995 and continued up until at least July 2, 2019, when the U.S. Attorney's Office for the Southern District of New York ("SDNY") charged Epstein with sex trafficking conspiracy and sex trafficking in violation of 18 U.S.C. § 1591. He was arrested on July 8, 2019, pursuant to the SDNY's Sealed Two Count Indictment, which is attached as Exhibit A. + +29. The Indictment described Epstein's conduct and his abuse and trafficking of females in the same trafficking operation he used to abuse and traffic Plaintiff. + +30. Epstein's last will and testament (the "Will") was executed on August 8, 2019, at the Metropolitan Correctional Center. The witnesses were Mariel Colon Mire and Gulnom Tali. The Will included affidavits from Darren K. Indyke and Richard D. Kahn, in which they swear an "Oath of Willingness to Serve as Executor and Appointment of Local Counsel." + +31. Epstein was found dead in his cell at the Metropolitan Correctional Center on August 10, 2019. + +32. Epstein's last will and testament was filed on August 15, 2019, in the Probate Division of the Superior Court of the Virgin Islands. + +33. Darren K. Indyke and Richard D. Kahn filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). + +34. Epstein's will was entered into probate on September 6, 2019, and the Superior Court of the Virgin Islands accordingly authorized Darren K. Indyke and Richard D. Kahn to administer Epstein's estate. See Order for Probate, In the Matter of the Estate ofJeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Sept. 6, 2019); Letters Testamentary, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-I9-PB-80 (Super. Ct. V.I. Sept. 6, 2019). + +35. The Will's first article directs Epstein's executors "to pay from my estate all expenses of my last illness, my funeral and burial expenses, the administration expenses of my estate and all of my debts duly proven and allowed against my estate." The Will further directs that "after the payments and distributions provided in Article FIRST," Epstein "give[s] all of my property, real and personal, wherever situated ... to the then acting Trustees of The 1953 Trust." + +36. Following Epstein's death, SDNY submitted a proposed nolle prosequi order in the criminal matter against him because it was required by law to do so after Epstein was deceased. On August 29, 2019, U.S. District Judge Richard Berman formally dismissed SDNY's indictment against Epstein, terminating the criminal action against him. Plaintiff's claims are therefore timely under N.Y. C.P.L.R. § 215(8Xa). + +C. + +• was born on in + +38. In 2002, was 20 years old and an aspiring model. In Cape Town, ME, an American model, approached in an attempt to befriend her. asked if she would like to meet Epstein, who she called the "King of America." described Epstein as a well-connected billionaire who could help her with her modeling career and explained that he was visiting Africa with a former high U.S. Government official, a famous actor, and a well- known comedian. + +39. considered meeting Epstein an amazing opportunity because modeling in New York City had always been one of her biggest dreams. • brought to a restaurant to meet Epstein, who at the time was dining with the former high U.S. Government official, the famous actor, and the well-known comedian. had never met a celebrity before. She was invited to attend a speech the former high U.S. Government official was giving in Cape Town the next day, and was escorted to the speech by police cars with individuals associated with the former official. + +40. Later, Epstein asked to bring her modeling portfolio to his hotel for "casting." Epstein told that he owned a modeling agency and would get her an agent in New York. He also mentioned that his good friend, Les Wexner, owned Victoria's Secret, a lingerie conglomerate. + +41. Within a few days, Leslie Groff began calling . Groff told that Epstein wanted to bring her to New York City to model. Groff, who was in New York at the time, helped get a visa, passport, and airline tickets. It was first time traveling overseas, so she was nervous. Epstein called mother from New York to assure her that would be safe with him in New York. + +42. Within two weeks, arrived in New York. A car picked her up from the airport and brought her to an apartment building on 66th Street, where Epstein housed some of the other models who he was abusing. But was not there for long. Shortly after arriving at the apartment, ==, another one of Epstein's co-conspirators, called and told that was going to the Caribbean. did not understand why she was traveling to the Caribbean so soon after arriving in New York City, but hoped it was for a modeling job. + +| 29 | B-727-311 | N COATSE | LFPB | EGGW | 146 | SAME AS ABOVE LESS SE | | 1/1 | +|-----|-----------|----------|-------------|------|-----|-------------------------------------|--|---------------| +| 6CS | " | " | EGGW | LFPB | 147 | GM, NECK & GDWENNA SAMMUMBS | | | +| 2 | " | " | LFPB | JFK | 148 | JE/GM, [REDACTED] | | | +| 3 | " | " | JFK | PBL | 149 | JE/SE, CHARGE, TESTIMPOE | | NECK SAMMUMBS | +| 6 | G-11549 | N COATSE | PBL | TEB | 150 | JE/SK, [REDACTED], RETA P, 1 FEMALE | | | +| 11 | " | " | TEB | PBD | 151 | JE/GM, [REDACTED], RETA P, GEARY | | | +| 14 | " | " | PBL-OFF-PBL | | 152 | MARK POTTER-PPC | | 1/1 | +| 15 | " | " | PBL | TEB | 160 | JE/GM, RETA P, DENNIS | | 1/1 | +| 17 | " | " | TGO | TEST | 161 | JE, [REDACTED] | | | +| 21 | " | " | TEST | PBL | 162 | JE, [REDACTED] | | 1/1 | + +43. [REDACTED] was taken on Epstein's private plane. During the flight, Epstein began sexually touching [REDACTED] leg. She felt trapped and terrified, and feared that she would be killed. + +44. They arrived at Epstein's home in the Virgin Islands. Epstein's abuse of [REDACTED] there began when [REDACTED] sent [REDACTED] to Epstein's room to massage him. For the rest of the trip, Epstein repeatedly raped [REDACTED] by forcible compulsion. [REDACTED] repeatedly sent [REDACTED] to Epstein's room, where he would touch her, use massage devices on her, force her to perform oral sex on him, and sexually force himself on her. [REDACTED] also witnessed another young girl performing oral sex on Epstein in front of [REDACTED] while they were watching a movie. [REDACTED] was terrified of Epstein and his power. No one knew where she was and she believed that if anything happened to her, no one would ever know. + +45. Instead of fulfilling her dreams of becoming a model in New York City, [REDACTED] was subject to extreme and repeated sexual abuse. Epstein's sexual abuse of [REDACTED] was humiliating and degrading, and caused [REDACTED] to cry herself to sleep each night. She felt trapped and alone on Epstein's private island. [REDACTED] learned very quickly that Epstein was incredibly powerful and that she should not disobey his demands. + +46. Epstein's abuse of [REDACTED] lasted for years. Epstein forced her to travel to the United States many times to see Epstein and be subjected to repeated sexual abuse for one to two weeks + +at a time, sometimes staying in his New York apartment. Epstein never introduced to a modeling agent, and she was never hired for a modeling job. + +47. For those years, felt like a prisoner and was afraid of betraying Epstein because of his money and power. She was afraid he would hurt her or her family. In fact, the very first time Epstein brought to the United States, in order to scare her, he told her that when another woman had accused him of rape, he planted drugs in the woman's apartment and had her sent to prison. + +48. Epstein made very clear to that he was incredibly wealthy, powerful, and regularly in contact with world leaders. In fact, in his New York mansion he had photographs displayed of significant political figures to ensure that any young female entering the home would know that he had extensive government connections. Epstein was not to be disobeyed and he made clear by his words and actions that there would be consequences if did not comply with his demands. + +49. was also forced to travel to Epstein's home in Paris where she had to stay with Ghislaine Maxwell, one of Epstein's main recruiters of young females, and where forced her to be photographed nude for Epstein. During that trip, witnessed that young females were on call to sexually pleasure Epstein. + +50. final trip to the United States was in 2004. She flew to see Epstein at his New Mexico ranch, called "Zorro Ranch." Epstein abused at Zorro Ranch. During that trip, Epstein took with him to meet another important government official. complied and went with Epstein. At the meeting, believed that Epstein had brought her there so that the official could look her over. felt very uncomfortable and she and Epstein began to fight because he claimed she was not being obedient. Epstein then informed that he + +wanted her to travel with him on his plane to California and serve drinks to some of his scientist friends who were going to be flying with him to California. But before the flight, after an argument with Epstein, flew home to This was the last time visited Epstein. + +51. Epstein attempted to keep in contact with through e-mail over the years. For example, in 2016, Epstein e-mailed to ask if she knew another woman who was a victim of Epstein's sex trafficking scheme. In June 2019, only two months before his death, Epstein sent an e-mail asking her to send him nude photographs. + +52. was deeply affected by her harrowing experiences at the hands of Epstein. She developed eating disorders that affected her for years afterwards. She also suffered from substance abuse, debilitating panic attacks, and severe anxiety. + +53. Epstein's sexual assault and battery of continues to cause her significant distress and harm. + +## FIRST CAUSE OF ACTION + +### (Battery) + +54. Plaintiff repeats and re-alleges the allegations stated above in paragraphs 1-53 as if fully set forth herein. + +55. Epstein intentionally committed battery by sexually assaulting Plaintiff on numerous occasions at his homes in New York, New Mexico, Florida, France, and the U.S. Virgin Islands. As described above, on multiple occasions over a years-long period, Epstein raped Plaintiff and intentionally touched intimate parts of her body in an offensive and sexual manner without her consent. + +56. Epstein's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to rape in the first degree as defined in Article 130.35, inasmuch as Epstein engaged in sexual intercourse with Plaintiff by forcible compulsion. See N.Y. C.P.L.R. § 213-C. + +57. A criminal action against Epstein with respect to the same sex trafficking enterprise from which Plaintiffs first cause of action arises was terminated on August 29, 2019, less than one year prior to the filing of this Complaint. See N.Y. C.P.L.R. § 215(8Xa). + +58. As a direct and proximate result of Epstein's conduct, Plaintiff has in the past and will in the future continue to suffer extreme emotional distress, humiliation, fear, anxiety, panic attacks, psychological trauma, loss of dignity and self-esteem, and invasion of her privacy. + +### SECOND CAUSE OF ACTION + +## (Intentional Infliction of Emotional Distress) + +59. Plaintiff repeats and re-alleges the allegations stated above in paragraphs I 53 as if fully set forth herein. + +60. As a direct result of these allegations as stated, Epstein committed intentional infliction of emotional distress against Plaintiff. + +61. Epstein's actions, described above, constitute extreme and outrageous conduct that shocks the conscience. Epstein's plan to recruit, entice, rape, and assault Plaintiff on multiple occasions goes beyond all possible bounds of decency and is intolerable in a civilized community. + +62. Epstein knew or disregarded the substantial likelihood that these actions would cause Plaintiff severe emotional distress. + +63. A criminal action against Epstein with respect to the same sex trafficking enterprise from which Plaintiff's second cause of action arises was terminated on August 29, 2019, less than one year prior to the filing of this Complaint. See N.Y. C.P.L.R. § 215(8Xa). + +64. As a direct and proximate result of Epstein's conduct, Plaintiff has in the past and will in the future continue to suffer extreme emotional distress, humiliation, fear, anxiety, panic attacks, psychological trauma, loss of dignity and self-esteem, and invasion of her privacy. + +## PRAYER FOR RELIEF + +WHEREFORE, Plaintiff respectfully requests judgment against Defendants, awarding compensatory, consequential, exemplary, and punitive damages in an amount to be determined at trial; costs of suit; attorneys' fees; and such other and further relief as the Court may deem just and proper. + +### JURY DEMAND + +Plaintiff hereby demands a trial by jury on all causes of action asserted within this pleading. + +Dated: November 14, 2019. + +/s/ Joshua I. Schiller + +David Boies Bows SCHILLER FLEXNER LLP 333 Main Street Armonk, NY 10504 + +Joshua I. Schiller Bows SCHILLER FLEXNER LLP 55 Hudson Yards New York, NY 10001 + +Sigrid McCawley (Pro Hac Vice Pending) Bows SCIIILLER FL EXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. 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service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for use of the Clerk of Court for the purpose of initiating the civil docket sheet. + +**PLAINTIFFS** + +![](_page_0_Picture_812.jpeg) + +DEFENDANTS +DAKREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN + +ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER) +Joshua I. Schiller +Boies Schiller Flexner LLP +55 Hudson Yards, New York, NY 10001 (212) 446-2300 + +ATTORNEYS (IF KNOWN) +Bennet J. Moskowitz +875 Third Avenue +New York, NY 10022 + +CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE) +(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY) + +28 U.S.C. § 1332; New York causes of action + +Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY at any time? No Yes Judge Previously Assigned + +If yes, was this case Vol. Invol. Dismissed. No Yes If yes, give date \_\_\_\_\_ & Case No. \_\_\_\_\_ + +IS THIS AN INTERNATIONAL ARBITRATION CASE? No Yes + +(PLACE AN [x] IN ONE BOX ONLY) + +**NATURE OF SUIT** + +| CONTRACT | PERSONAL INJURY | PERSONAL INJURY | FORFEITURE/PENALTY | BANKRUPTCY | OTHER STATUTES | +|-----------------------------------------------------------------------------------------------------------------|--------------------------------------------------|----------------------------------------------------------------------|-------------------------------------------|----------------------------------------------------------------|--------------------------------------------------------------------------| +| [ ] 110 INSURANCE MARINE | [ ] 310 AIRPLANE | [ ] 367 HEALTHCARE/ PHARMACEUTICAL PERSONAL INJURY/PRODUCT LIABILITY | [ ] 625 DRUG RELATED SEIZURE OF PROPERTY | [ ] 422 APPEAL 28 USC 158 | [ ] 375 FALSE CLAIMS | +| [ ] 120 ACT NEGOTIABLE INSTRUMENT | [ ] 315 AIRPLANE PRODUCT LIABILITY | [ ] 365 PERSONAL INJURY PRODUCT LIABILITY | [ ] 630 OTHER | [ ] 423 WITHDRAWAL 28 USC 157 | [ ] 376 QUI TAM | +| [ ] 140 NEGOTIABLE INSTRUMENT RECOVERY OF OVERPAYMENT & ENFORCEMENT OF JUDGMENT | [ ] 320 ASSAULT, LIBEL & SLANDER | [ ] 368 ASBESTOS PERSONAL INJURY PRODUCT LIABILITY | [ ] 830 COPYRIGHTS | [ ] 442 APPEAL 28 USC 158 | [ ] 400 STATE REAPPORTIONMENT | +| [ ] 150 STUDENT LOANS (EXCL VETERANS) RECOVERY OF OVERPAYMENT OF VETERANS BENEFITS STOCKHOLDERS SUITS | [ ] 345 MARINE PRODUCT LIABILITY | [ ] 370 OTHER FRAUD | [ ] 830 PATENT | [ ] 430 BANKS & BANKING | [ ] 450 COMMERCE | +| [ ] 151 DEFAULTED STUDENT LOANS (EXCL VETERANS) RECOVERY OF OVERPAYMENT OF VETERANS BENEFITS STOCKHOLDERS SUITS | [ ] 355 MOTOR VEHICLE PRODUCT LIABILITY | [ ] 371 TRUTH IN LENDING | [ ] 840 TRADEMARK | [ ] 470 RACKETEER INFLUENCED & CORRUPT ORGANIZATION ACT (RICO) | [ ] 480 CONSUMER CREDIT | +| [ ] 153 RECOVERY OF OVERPAYMENT OF VETERANS BENEFITS STOCKHOLDERS SUITS | [ ] 362 PERSONAL INJURY - MED MALPRACTICE | [ ] 380 OTHER PERSONAL PROPERTY DAMAGE | [ ] 851 FAIR LABOR STANDARDS ACT | [ ] 480 CONSUMER CREDIT | [ ] 490 CABLE/SATELLITE TV | +| [ ] 160 STOCKHOLDERS SUITS | [ ] 365 PROPERTY DAMAGE PRODUCT LIABILITY | [ ] 380 OTHER PERSONAL PROPERTY DAMAGE | [ ] 720 LABOR/MGMT RELATIONS | [ ] 865 RSI (405(g)) | [ ] 850 SECURITIES/ COMMODITIES/ EXCHANGE | +| [ ] 190 OTHER CONTRACT CONTRACT PRODUCT LIABILITY | [ ] 443 OTHER CIVIL RIGHTS (Non-Prisoner) | [ ] 510 MOTIONS TO VACATE SENTENCE 28 USC 2255 | [ ] 750 RAILWAY LABOR ACT | [ ] 871 IRS-THIRD PARTY 26 USC 7609 | [ ] 890 OTHER STATUTORY ACTIONS | +| [ ] 195 CONTRACT PRODUCT LIABILITY | [ ] 440 OTHER CIVIL RIGHTS (Non-Prisoner) | [ ] 530 HABEAS CORPUS VACATE SENTENCE | [ ] 751 FAMILY MEDICAL LEAVE ACT (FMLA) | [ ] 870 TAXES (U.S. Plaintiff or Defendant) | [ ] 891 AGRICULTURAL ACTS | +| [ ] 196 FRANCHISE | [ ] 442 EMPLOYMENT | [ ] 535 DEATH PENALTY | [ ] 791 EMPL RET INC SECURITY ACT (ERISA) | [ ] 872 TAXES (U.S. Plaintiff or Defendant) | [ ] 893 ENVIRONMENTAL MATTERS | +| [ ] 210 LAND CONDEMNATION | [ ] 443 HOUSING/ ACCOMMODATIONS | [ ] 550 CIVIL RIGHTS | [ ] 462 NATURALIZATION APPLICATION | [ ] 871 IRS-THIRD PARTY 26 USC 7609 | [ ] 895 FREEDOM OF INFORMATION ACT | +| [ ] 220 FORECLOSURE RENT LEASE & EJECTMENT | [ ] 445 AMERICANS WITH DISABILITIES - EMPLOYMENT | [ ] 560 CIVIL DETAINEE CONDITIONS OF CONFINEMENT | [ ] 465 OTHER IMMIGRATION ACTIONS | [ ] 890 ARBITRATION | [ ] 896 ADMINISTRATIVE PROCEDURE ACT/REVIEW OR APPEAL OF AGENCY DECISION | +| [ ] 240 TORTS TO LAND TORT PRODUCT LIABILITY | [ ] 446 AMERICANS WITH DISABILITIES - OTHER | [ ] 560 CIVIL DETAINEE CONDITIONS OF CONFINEMENT | [ ] 675 FAMILY MEDICAL LEAVE ACT (FMLA) | [ ] 870 TAXES (U.S. Plaintiff or Defendant) | [ ] 895 ENVIRONMENTAL MATTERS | +| [ ] 290 ALL OTHER REAL PROPERTY | [ ] 448 EDUCATION | [ ] 550 CIVIL RIGHTS | [ ] 675 FAMILY MEDICAL LEAVE ACT (FMLA) | [ ] 871 IRS-THIRD PARTY 26 USC 7609 | [ ] 950 CONSTITUTIONALITY OF STATE STATUTES | + +Check if demanded in complaint: + + CHECK IF THIS IS A CLASS ACTION UNDER F.R.C.P. 23 + +DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y. AS DEFINED BY LOCAL RULE FOR DIVISION OF BUSINESS 13? IF SO, STATE: + +DEMAND \$ \_\_\_\_\_ OTHER \_\_\_\_\_ JUDGE \_\_\_\_\_ DOCKET NUMBER \_\_\_\_\_ + +Check YES only if demanded in complaint +JURY DEMAND: YES NO + +NOTE: You must also submit at the time of filing the Statement of Relatedness form (Form IH-32). + + 1 Original Proceeding      2 Removed from State Court      3 Remanded from Appellate Court      4 Reinstated or Reopened      5 Transferred from (Specify District)      6 Multidistrict Litigation (Transferred)      7 Appeal to District Judge from Magistrate Judge + + a. all parties represented      8 Multidistrict Litigation (Direct File) + + b. At least one party is pro se. + +(PLACE AN x IN ONE BOX ONLY) + +**BASIS OF JURISDICTION** + + 1 U.S. PLAINTIFF      2 U.S. DEFENDANT      3 FEDERAL QUESTION      4 DIVERSITY +(U.S. NOT A PARTY) + +**IF DIVERSITY, INDICATE CITIZENSHIP BELOW.** + +**CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)** + +(Place an [X] in one box for Plaintiff and one box for Defendant) + +| CITIZEN OF THIS STATE | PTF [ ] 1 [ ] 1 | DEF [ ] 1 | CITIZEN OR SUBJECT OF A FOREIGN COUNTRY | PTF DEF [x] 3 [ ] 3 | INCORPORATED and PRINCIPAL PLACE OF BUSINESS IN ANOTHER STATE | PTF [ ] 5 [ ] 5 | DEF [ ] 5 | +|--------------------------|-----------------|-----------|-----------------------------------------------------------|---------------------|---------------------------------------------------------------|-----------------|-----------| +| CITIZEN OF ANOTHER STATE | [ ] 2 [x] 2 | | INCORPORATED or PRINCIPAL PLACE OF BUSINESS IN THIS STATE | [ ] 4 [ ] 4 | FOREIGN NATION | [ ] 6 [ ] 6 | | + +PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES) + +![](_page_1_Picture_43.jpeg) + +40 Victoria Road +Cape Town, South Africa + +DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES) + +Darren K. Indyke +Richard D. Kahn +U.S. Virgin Islands + +DEFENDANT(S) ADDRESS UNKNOWN + +REPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN THE RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS: + +Defendants are sued as executors of the Estate of Jeffrey Epstein. Per 28 U.S.C. § 1332, Defendants are deemed citizens of the U.S. Virgin Islands (USVI), decedent Epstein's domicile. Defendants' residential addresses are unknown to Plaintiff. Defendants' counsel is listed above. + +**COURTHOUSE ASSIGNMENT** + +I hereby certify that this case should be assigned to the courthouse indicated below pursuant to Local Rule for Division of Business 18, 20 or 21. + +Check one: THIS ACTION SHOULD BE ASSIGNED TO: [ ] PLAINS MANHATTAN + +DATE 11/14/2019 SIGNATURE OF ATTORNEY OF RECORD + +RECEIPT # + +ADMITTED TO PRACTICE IN THIS DISTRICT + +[ ] NO +[x] YES (DATE ADMITTED Mo.08 Yr. 2009) +Attorney Bar Code # JS3315 + +Magistrate Judge is to be designated by the Clerk of the Court. + +Magistrate Judge \_\_\_\_\_ is so Designated. + +Ruby J. 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Civil Action No. + +DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN + +Defendant( + +## SUMMONS IN A CIVIL ACTION + +To: (Defendant's name and address) Darren K. Indyke and Richard D. Kahn Go Bennet J. Moskowitz, attorney 875 Third Avenue New York. NY 10022 + +A lawsuit has been filed against you. + +Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency. or an officer or employee of the United States described in Fed. R. Civ. P. 12 (aX2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney. whose name and address are: Joshua Schiller + +Boles Schiller Flexner LLP 55 Hudson Yards New York, NY 10001 (212)446-2300 jischillenabsfIlp.com + +If you fail to respond. judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: + +CLERK OF COURT + +Signature ofClark or Deputy Clerk + +Civil Action No. + +## PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Cir. P.4 (ID + +This summons for (name of indmdual and ask, if any) was received by me on (date) + +O I personally served the summons on the individual at (place) on (date) : or + +O I left the summons at the individual's residence or usual place of abode with (name) , a person of suitable age and discretion who resides there. on (date) . and mailed a copy to the individual's last known address: or + +O I served the summons on (name of Maurine!) , who is designated by law to accept service of process on behalf of (name of organization) on (date) : or + +Date: Server's signature + +O I returned the stunmons unexecuted because : or + +O Other (specify): + +My fees are \$ for travel and \$ for services, for a total of \$ 0.00 + +I declare under penalty of perjury that this information is true. + +Printed name and title + +Seer's address + +Additional information regarding attempted service. etc: \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731959/EFTA02731959.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02731959/EFTA02731959.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..049e7d5f7da5008fa69e3f7475f6ac976557144e --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731959/EFTA02731959.metadata.json @@ -0,0 +1,170 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02731959.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2277, + "elapsed_seconds": 0.99, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 169.524, + 60.6243896484375 + ], + [ + 443.97149658203125, + 60.6243896484375 + ], + [ + 443.97149658203125, + 83.3077392578125 + ], + [ + 169.524, + 83.3077392578125 + ] + ] + }, + { + "title": "SUMMONS IN A CIVIL ACTION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 220.32, + 294.84000000000003 + ], + [ + 390.83489990234375, + 294.84000000000003 + ], + [ + 390.83489990234375, + 309.1040954589844 + ], + [ + 220.32, + 309.1040954589844 + ] + ] + }, + { + "title": "PROOF OF SERVICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 249.08399999999997, + 88.28999999999999 + ], + [ + 362.3437194824219, + 88.28999999999999 + ], + [ + 362.3437194824219, + 100.97406005859375 + ], + [ + 249.08399999999997, + 100.97406005859375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 33 + ], + [ + "Text", + 16 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Line", + 28 + ], + [ + "Text", + 14 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02731959" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731961/EFTA02731961.md b/marker2/court-redacted-v-indyke-10479/EFTA02731961/EFTA02731961.md new file mode 100644 index 0000000000000000000000000000000000000000..f7cd116fa2257b762df2e9ed128be8e0f8692320 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731961/EFTA02731961.md @@ -0,0 +1,65 @@ +## UNITED STATES DISTRICT COURT + +for the + +Southern District of New York + +Plainhjj(s) + +v. Civil Action No. + +DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN + +DElendant(4( + +## SUMMONS IN A CIVIL ACTION + +To: (Defendant's name and address) Darren K. Indyke and Richard D. Kahn c/o Bennet J. Moskowitz. attorney 875 Third Avenue New York, NY 10022 + +A lawsuit has been filed against you. + +Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency. or an officer or employee of the United States described in Fed. R. Civ. P. 12 (aX2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. 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INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +Case No. 1:19-cv- 10479 (ALC) + +## NOTICE OF APPEARANCE + +PLEASE TAKE NOTICE that the undersigned attorney, David Boies, who is a member in good standing of the bar of this Court, hereby appears as counsel for Plaintiff in the above-captioned proceeding. + +Dated: New York, New York November 20, 2019 + +BOLES SCHILLER FLEXNER LLP + +By: /s/ David Boies David Boies 333 Main Street Armonk, NY 10504 Telephone: (914) 749-8200 Fax: (914) 749-8300 dboies@bsflIp.com + +Attorney for Plaintiff \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731963/EFTA02731963.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02731963/EFTA02731963.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4b789b4d83796b518716d31c726df32230f0f827 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731963/EFTA02731963.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02731963.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 689, + "elapsed_seconds": 0.67, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.78000000000003, + 71.28 + ], + [ + 418.4738464355469, + 71.28 + ], + [ + 418.4738464355469, + 100.10302734375 + ], + [ + 192.78000000000003, + 100.10302734375 + ] + ] + }, + { + "title": "NOTICE OF APPEARANCE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 359.856, + 217.07999999999998 + ], + [ + 519.3272094726562, + 217.07999999999998 + ], + [ + 519.3272094726562, + 231.7330322265625 + ], + [ + 359.856, + 231.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "Text", + 11 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02731963" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731964/EFTA02731964.md b/marker2/court-redacted-v-indyke-10479/EFTA02731964/EFTA02731964.md new file mode 100644 index 0000000000000000000000000000000000000000..b5942334becfe45d6be427f0f6d82107028d2784 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731964/EFTA02731964.md @@ -0,0 +1,111 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +vs. + +Plaintiff, + +DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +Case No. 1:19-cv- 10479 (ALC) + +#### MOTION FOR ADMISSION PRO HAC VICE + +Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern Districts of New York, I, Sigrid S. McCawley, hereby move this Court for an Order for Admission to practice Pro Hac Vice to appear as counsel for Plaintiff, in the above-captioned action. + +I am in good standing in the bar of the State of Florida and there are no pending disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3. + +Dated: November 21, 2019 Respectfully Submitted, + +/s/ Site rid S. McCawlev + +Sigrid S. McCawley Boies Schiller Flexner LLP 401 E. Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 33301 Tel: (954) 356-0011 Fax: (954) 356 0022 Email: smccawley@bsfllp.com + +Counsel for Plaintiff + +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +VS. + +Plaintiff, + +DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +I, Sigrid S. McCawley, hereby declare as follows: + +- I I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. +- 3. There are no pending disciplinary proceedings against me in any state or federal court. +- 4. I am a member in good standing of the bar of the State of Florida. + +Case No. 1:19-cv-10479 (ALC) + +DECLARATION OF SIGRID S. MCCAWLEY IN SUPPORT OF APPLICATION FOR ADMISSION PRO HAC VICE + +I hereby declare under penalty of perjury that the foregoing statements are true and correct. + +Dated: November 21, 2019 Respectfully Submitted, + +Is/ Sigrid S. McCawlev + +Sigrid S. McCawley + +Boies Schiller Flexner, LLP + +401 E. Las Olas Boulevard, Suite 1200 + +Fort Lauderdale, FL 33301 + +Tel: (954) 356-0011 + +Fax: (954) 356 0022 + +Email: smccawley@bsfllp.com + +Counsel for Plaintiff + +# Supreme Court of Florida Certificate of Good Standing + +*I JOHN A. TOMASINO, Clerk of the Supreme Court of the State of Florida, do hereby certify that* + +**SIGRID [REDACTED] MCCAWLEY** + +*was admitted as an attorney and counselor entitled to practice law in all the Courts of the State of Florida on November 6, 1997, is presently in good standing, and that the private and professional character of the attorney appear to be good.* + +*WITNESS my hand and the Seal of the Supreme Court of Florida at Tallahassee, the Capital, this November 20, 2019.* + +![](_page_2_Picture_60.jpeg) + +![]()*Clerk of the Supreme Court of Florida.* + +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +vs. + +Plaintiff, + +DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +Case No. I :19-cv- 10479 (ALC) + +### ORDER FOR ADMISSION PRO HAC VICE + +The motion of Sigrid S. McCawley, for admission to practice Pro Hac Vice in the above captioned action is granted. + +Applicant has declared that she is a member in good standing of the bar of the State of Florida; and that her contact information is as follows: + +Sigrid S. McCawley Boies Schiller Flexner LLP 401 E. Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 33301 Telephone: (954) 356-0011 Fax: (954) 356-0022 smccawley@bsfllp.com + +Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Plaintiff in the above entitled action; + +IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. + +All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. + +Dated: + +United States District Judge \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731964/EFTA02731964.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02731964/EFTA02731964.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7ff0cbb4d4090bad2ecad56f77026993f84033bc --- /dev/null +++ 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action along with a copy of the complaint, two copies of this waiver fonn, and a prepaid means of returning one signed copy of the form to you. + +I, or the entity I represent, agree to save the expense of serving a summons and complaint in this case. + +I understand that I, or the entity I represent. will keep all defenses or objections to the lawsuit, the court's jurisdiction, and the venue of the action, but that I waive any objections to the absence of a summons or of service. + +I also understand that I. or the entity I represent. must file and serve an answer or a motion under Rule 12 within 60 days from /75119 . the date when this request was sent (or 90 days if it was sent outside the United States). If I fail to do so, a default judgment will be entered against me or the entity I represent. + +Date: /2 5/O + +Darren'. Indyke and Richard D. Kahn Printed name of pony waiving service of summons Signature of the attorney or unrepresented party + +Bennet Moskowitz Printed name + +Troutman Sanders LLP. 875 Third Avenue. New York. NY 10022 + +.Iddress + +Bennet.Moskowitz@troutman.com + +Equal! address + +(212) 704-6087 + +I elephone ,,umber + +## Duty to Avoid Unnecessary Espenses of Sem ing a Summons + +Rule 4 of the Federal Rules ofCivil Procedure requires certain defendants to cooperate in saving unnecessary expensesof serving a summons and complaint. A defendant who is located in the United States and who fails to return a signed waiver of service requested by a plaintiff located in the United States will be required to pay the expenses of service. unless the defendant shows good cause for the failure. + +-Good cause" does not include a belief that the lawsuit is groundless, or that it has been brought in an improper venue, or that the court has no jurisdiction over this matter or over the defendant or the defendant's property. + +if the waiver is signed and returned. you can still make these and all other defenses and objections, but you cannot object to the absence of a summons or of service. + +Ifyou wake service, then you must. within the time specified on the waiver form, serve an answer or a motion under Rule 12 on the plaintiff and file a copy with the court. 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CARTER, JR., District Judge:** + +The above-captioned action is referred to Magistrate Judge Debra Freeman, for the following purpose[s]: + +| X | General Pretrial (includes scheduling, discovery, non-dispositive pretrial motions, and settlement) | ___ | Consent under 28 U.S.C. § 636(c) for all purposes (including trial) | +|----------|----------------------------------------------------------------------------------------------------------------------|-----|---------------------------------------------------------------------------------------------------------------------------| +| ___ | Specific Non-Dispositive Motion/Dispute | ___ | Consent under 28 U.S.C. § 636(c) for limited purpose (e.g., dispositive motion, preliminary injunction)
Purpose: _____ | +| ___ | If referral is for discovery disputes when the District Judge is unavailable, the time period of the referral: _____ | ___ | Habeas Corpus | +| ___ | Settlement | ___ | Social Security | +| ___ | Inquest After Default/Damages Hearing | ___ | Dispositive Motion (i.e., motion requiring a Report and Recommendation)
Particular Motion: _____ | + +**SO ORDERED.** + +Dated: December 26, 2019 +New York, New York + +![]()\_\_\_\_\_ + HON. ANDREW L. CARTER, JR. + United States District Judge \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731970/EFTA02731970.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02731970/EFTA02731970.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..756bdd66e8c4b61b7503c7050240cc5c913418b7 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731970/EFTA02731970.metadata.json @@ -0,0 +1,119 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02731970.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 2099, + "elapsed_seconds": 40.0, + "image_assets": [ + "_page_0_Picture_138.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 66.708, + 70.47 + ], + [ + 288.25199999999995, + 70.47 + ], + [ + 288.25199999999995, + 97.19999999999999 + ], + [ + 66.708, + 97.19999999999999 + ] + ] + }, + { + "title": "ORDER OF REFERENCE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 379.44, + 180.63 + ], + [ + 526.932, + 180.63 + ], + [ + 526.932, + 194.39999999999998 + ], + [ + 379.44, + 194.39999999999998 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 80 + ], + [ + "Line", + 38 + ], + [ + "Text", + 25 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "Picture", + 2 + ], + [ + "Table", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02731970" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731970/_page_0_Picture_138.jpeg b/marker2/court-redacted-v-indyke-10479/EFTA02731970/_page_0_Picture_138.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..cb532b67116a100e1a9015c04150a24b98cb25db --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731970/_page_0_Picture_138.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:804253d269c5d8780dbcd170a3ea5cbb8996604607ed0dac85e8075b25e1a81b +size 17688 diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731971/EFTA02731971.md b/marker2/court-redacted-v-indyke-10479/EFTA02731971/EFTA02731971.md new file mode 100644 index 0000000000000000000000000000000000000000..f18d3ba00fbf6c9a4532240a79cf07f8428d65ed --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731971/EFTA02731971.md @@ -0,0 +1,33 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW Y + +vs. + +Plaintiff, + +DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +![](_page_0_Picture_2.jpeg) + +Case No. 1: + +## ORDER FOR ADMISSION PRO HAC VICE + +The motion of Sigrid S. McCawley, for admission to practice Pro Hac Vice in the above captioned action is granted. + +Applicant has declared that she is a member in good standing of the bar of the State of Florida; and that her contact information is as follows: + +Sigrid S. McCawley Boies Schiller Flexner LLP 401 E. Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 33301 Telephone: (954) 356-0011 Fax: (954) 356-0022 smccawlev@bsflIn.com + +Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Plaintiff in the above entitled action; + +IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. + +All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. + +Dated: 12/27/19 + +![]()DEBRA FREEMAN +UNITED STATES MAGISTRATE JUDGE +SOUTHERN DISTRICT OF NEW YORK \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731971/EFTA02731971.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02731971/EFTA02731971.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fd0e6e69eef4dc03de6f51748ba4a70f06e8f06b --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731971/EFTA02731971.metadata.json @@ -0,0 +1,149 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02731971.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1280, + "elapsed_seconds": 2.61, + "image_assets": [ + "_page_0_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW Y", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 190.94400000000002, + 83.42999999999999 + ], + [ + 403.9200000000001, + 83.42999999999999 + ], + [ + 403.9200000000001, + 113.197021484375 + ], + [ + 190.94400000000002, + 113.197021484375 + ] + ] + }, + { + "title": "ORDER FOR ADMISSION \nPRO HAC VICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 334.764, + 220.32000000000005 + ], + [ + 479.7606201171875, + 220.32000000000005 + ], + [ + 479.7606201171875, + 248.197021484375 + ], + [ + 334.764, + 248.197021484375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 35 + ], + [ + "Text", + 11 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 10 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02731971" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731971/_page_0_Picture_2.jpeg b/marker2/court-redacted-v-indyke-10479/EFTA02731971/_page_0_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..8ee3544da80c0e52f4111aaf5c8d63fddf8cff70 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731971/_page_0_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:eef51c9d705dfb39e9fa1bcc02bd0b6c412b33b4cf3d574443f025269576b6ac +size 21434 diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731973/EFTA02731973.md b/marker2/court-redacted-v-indyke-10479/EFTA02731973/EFTA02731973.md new file mode 100644 index 0000000000000000000000000000000000000000..1fdb829b5b6a6bd7ce3689fd3e2f1f1851b3cf43 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731973/EFTA02731973.md @@ -0,0 +1,29 @@ +January 10, 2020 + +## VIA ECF + +The Honorable Debra Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 + +> Re: v. Darren K. Indyke and Richard D. Kahn, in their capacities as executors of the Estate ofJeffity Edward Epstein, 19-10479 Jane Doe 1000 v. Darren K. Indyke and Richard D. Kahn, in their capacities as executors of the Estate ofJetey Edward Epstein, 19-10577 Annie Farmer v. Darren K. Indyke and Richard D. Kahn, in their capacities as executors of the Estate of Jeffiey Edward Epstein, and Ghislaine Maxwell, 19- 10475 v. Darren K Indyke and Richard D. Kahn, in their capacities as executors of the Estate of Jeji-ey Edward Epstein, 19-10476 + +Dear Judge Freeman: + +Pursuant to the Court's request at the November 21, 2019, Case Management Conference, Plaintiffs and Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, jointly submit this letter to provide the Court with an update as to the progress of discussions regarding both discovery and settlement. + +The parties have thus far engaged in two productive conferences pursuant to Rule 26(f) of the Federal Rules of Civil Procedure. During those conferences, the parties agreed to exchange initial disclosures by January 23, 2020, and to exchange discovery plans one week thereafter, on January 30, 2020. + +As the Court is aware, Defendants have arranged for a Victims' Compensation Program that will be available to Plaintiffs. Plaintiffs' counsel has conferred with the Program's designers and administrators, the Program's administrators provided Plaintiffs with a proposed protocol for the Program, and Plaintiffs have provided some feedback to the administrators. The motion for the Superior Court of the United States Virgin Islands to approve the establishment of the Program will be heard on February 4, 2020. + +The parties request a conference with the Court on February 6 or 7, 2020, to resolve any potential disagreements as to how these matters should proceed. The parties will provide the Court with their proposed discovery plan(s) 48 hours before any such conference. + +Respectfully submitted, + +/s/ Joshua I. Schiller + +David Boies, Esq. Joshua I. Schiller, Esq. Sigrid S. McCawley, Esq. Boies Schiller Flexner LLP + +/s/ Bennet J. Moskowitz + +Bennet J. Moskowitz, Esq. Troutman Sanders LLP + +cc: Counsel of Record (via ECF) \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731973/EFTA02731973.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02731973/EFTA02731973.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3e24277cb0ceb9c7d03603260e3fbb0142adc179 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731973/EFTA02731973.metadata.json @@ -0,0 +1,120 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02731973.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2373, + "elapsed_seconds": 0.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 113.4 + ], + [ + 124.17080688476562, + 113.4 + ], + [ + 124.17080688476562, + 127.863037109375 + ], + [ + 68.544, + 127.863037109375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 88 + ], + [ + "Line", + 40 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 3 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "Text", + 6 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02731973" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731975/EFTA02731975.md b/marker2/court-redacted-v-indyke-10479/EFTA02731975/EFTA02731975.md new file mode 100644 index 0000000000000000000000000000000000000000..cab5b11d405bc4c48165b53b7165e720096baa77 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731975/EFTA02731975.md @@ -0,0 +1,55 @@ +The Clerk of Court of the Southern District of New York is directed to docket the within ORDER in each of the following actions: + +VE v. Nine East 71st Street et al., No. 1:19-cv-07625 (AJN) (DF) + +Katlyn Doe v. Indyke et at, No. 1:19-cv-07771 (PKC) (DF) + +Priscilla Doe v. Indyke et al, No. 1:19-cv-07772 (ALC) (DF) + +Lisa Doe v. Indyke et al., No. 1:19-cv-07773 (ER) (DF) + +Jane Doe v. Indyke et at, No. 1:19-cv-08673 (KPF) (DF) + +v. Indyke et aL, No. 1:19-cv-10475 (LGS) (DF) + +v. Indyke et aL, No. 1:19-cv-10476 (PGG) (DF) + +v. Indyke et aL, No. 1:19-cv-10479 (ALC) (DF) + +Jane Doe 1000 v. Indyke et at, No. 1:19-cv-10577 (LGS) (DF) + +Jane Doe 15 v. Indyke et aL, No. I :19-cv-10653 (PAE) (DF) + +Mary Doe v. Indyke et at, No. 1:19-cv-I 0758 (PAE) (DF) + +v. Indyke et al, No. 1:19-cv-10788 (GHW) (DF) + +Anastasia Doe v. Indyke et al, No. 1:19-cv-11869 (MN) (DF) + +![](_page_0_Picture_15.jpeg) + +## DEBRA FREEMAN, United States Magistrate Judge: + +The above-referenced cases — all brought by plaintiffs claiming that they were sexually abused by Jeffrey Epstein and seeking damages from his estate — have been neither consolidated for any purpose, nor designated as "related" by the Court. Nonetheless, these cases (together with certain other, similar cases, not listed above) have been referred to the undersigned for general pretrial supervision, so that discovery — and potentially settlement — may be coordinated as reasonable. While, at the parties' request, discovery in the other Jeffrey Epstein cases referred to this Court has been stayed pending a further report on the parties' settlement efforts, the parties to each of the above-referenced cases have requested, by submissions dated January 10, 2020, that this Court set a discovery schedule. This Court's having reviewed the parties' submissions, it is hereby ORDERED that: + +1. In each of the above-referenced cases in which the parties have not yet submitted a jointly proposed discovery plan pursuant to Rule 26(f) of the Federal Rules of Civil Procedure, the parties are directed to submit a proposed discovery schedule for this Court's review no later + +than February 6, 2020. This submission should address all of the matters set out in Rule 26(f)(3), and should specifically include proposed deadlines for: + +- a service of initial disclosures under Rule 26(a)(1); +- b. service of initial document requests and interrogatories; +- c. any motion for joinder of other parties or amendment of the pleadings; +- d. completion of fact discovery; and +- e. expert disclosures and the completion of expert discovery, if any. + +2. As to each of the above-referenced cases, this Court will hold a pretrial conference pursuant to Rule 16 of the Federal Rules of Civil Procedure on February 11, 2020, at 10:00 a.m., in Courtroom 17A at the United States Courthouse, 500 Pearl Street, New York, NY 10007. The parties should be aware, however, that the mere fact that this Court will be holding a single, joint case-management conference does not necessarily mean that this Court will set an identical discovery schedule in each case. At the conference, counsel should be prepared to address whether there are reasons why these cases should be treated differently for scheduling purposes. + +Dated: New York, New York January 14, 2019 + +SO ORDERED + +Ahles A9-7 DEBRA FREEMAN United States Magistrate Judge + +Copies to: + +All counsel in the above-referenced cases (via ECF) \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731975/EFTA02731975.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02731975/EFTA02731975.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..eed7d068c6e048ccb708289ce35c33e495b0424c --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731975/EFTA02731975.metadata.json @@ -0,0 +1,134 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02731975.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3404, + "elapsed_seconds": 1.09, + "image_assets": [ + "_page_0_Picture_15.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "DEBRA FREEMAN, United States Magistrate Judge:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 336.15 + ], + [ + 350.9979553222656, + 336.15 + ], + [ + 350.9979553222656, + 352.4830322265625 + ], + [ + 68.544, + 352.4830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 62 + ], + [ + "Line", + 31 + ], + [ + "Text", + 16 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "Text", + 7 + ], + [ + "ListItem", + 5 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02731975" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731975/_page_0_Picture_15.jpeg b/marker2/court-redacted-v-indyke-10479/EFTA02731975/_page_0_Picture_15.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..69dfe329b073834c45fde87ad910ec7dbab962fc --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731975/_page_0_Picture_15.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9a5294300c2f323d378e6e967a32ade0d612fb08cd39247565613ba11772dcbf +size 25034 diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731977/EFTA02731977.md b/marker2/court-redacted-v-indyke-10479/EFTA02731977/EFTA02731977.md new file mode 100644 index 0000000000000000000000000000000000000000..43efdd67e8fc63013c6281bb543657618491075c --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731977/EFTA02731977.md @@ -0,0 +1,69 @@ +Bennet J. Moskowitz + +bennet.moskowitz@troutman.com + +January 24, 2020 + +ECF + +Hon. Andrew L. Carter Jr. + +Thurgood Marshall + +United States Courthouse + +40 Foley Square + +New York, NY 10007 + +Re: v. Darren K. lndyke and Richard D. Kahn, in their capacities as executors of the Estate of Jeffrey E. Epstein, 1:19-cv-10479-ALC-DCF + +Dear Judge Carter: + +We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the to -Executors"), in the above-referenced action. We write pursuant to Your Honor's Individual Practice § 2(A) to set forth the bases for the Co-Executors' anticipated motion pursuant to Fed. R. Civ. P. 12(b)(6) to dismiss the time-barred claims and punitive damages demand in Plaintiff ("Plaintiff") Complaint (ECF No. 1). + +- 1. Plaintiff is a South African resident who alleges Decedent committed torts against her from 2002 to 2004 when she was an adult, in various jurisdictions. + +Plaintiff, who claims South African citizenship and residency, alleges that, from 2002 (when she was 20) to 2004, Mr. Epstein ("Decedent"), now deceased, committed various sexual offenses against her in the U.S. Virgin Islands ("USVI"), France, Florida, New Mexico and New York. (Compl. ¶¶ 16, 38, 50, 55.) Plaintiff asserts two causes of action -- battery and intentional infliction of emotional distress -- and demands punitive damages. (Id. ¶¶ 54-64, p. 15.) + +- 2. Plaintiff's causes of action are time-barred. + +CPLR § 202 provides that, when a non-N.Y. resident such as Plaintiff sues on causes of action accruing outside N.Y., the complaint must be timely under the statute of limitations ("SOL") of both N.Y. and the jurisdiction where the claim accrued.' Plaintiff's causes of action expired by: 2006 per the USVI's 2-year SOL (5 V.I.C. § 31(5)(A)); 2008 per FL's 4-year SOL (Fla. Stat. § 95.11 (3)(O)); 2007 per N.M.'s 3-year SOL (N.M. Stat. § 37-1-8); and 2005 or 2007 per N.Y.'s 1 or 3-year SOL (CPLR §§ 214(5), 215(3)). + +- 3. Plaintiff's attempts to plead around the statutes of limitations fail. + +Plaintiff erroneously alleges her claims are timely per CPLR § 213-c or § 215(8)(a), her claims were equitably tolled, and that the Co-Executors are equitably estopped from asserting an SOL defense (Compl. ¶y 12-15). Each of these arguments fails as a matter of law. + +"In diversity cases in New York, federal courts apply ... C.P.L.R. § 202." Commerzbank AG v. Deutsche Bank Nat? Tr. Co., 234 F. Supp. 3d 462, 467 (S.D.N.Y. 2017) (citation omitted). + +First, neither CPLR § 213-c nor § 215(8)(a) applies here. The 20 year SOL in CPLR § 213-c became effective as of September 18, 2019; the SOL was 5 years as of 2006 and 1 year before then. (L. 2006, ch 3, § 5(b).) However, the 20-year SOL does not apply retroactively except "where the applicable [SOL] in effect on the date of such act or omission has not yet expired." L. 2019, ch. 315, §4. Therefore, CPLR § 213-c cannot revive Plaintiff's claims arising from torts committed in N.Y. + +Separately, CPLR § 215(8)(a) provides: "Whenever it is shown that a criminal action against the same defendant has been commenced with respect to the event or occurrence from which a claim governed by this section arises, the plaintiff shall have at least one year from the termination of the criminal action ... to commence the civil action" (emphasis added). Decedent's criminal indictment (the "Indictment") attached to Plaintiff's Complaint does not concern Plaintiff's allegations. Rather, the indictment charges Decedent sexually abused "minor girls" (Compl., Ex. A at ¶ 1), stating throughout that it concerns sex trafficking of "minors." (Id., Ex. A at ¶¶2 - 4, 6, 8, 11- 15, 18 - 20, 22.) Because Plaintiff alleges she was an adult when Decedent abused her, her action and the Indictment arise from different occurrences. + +New York courts apply CPLR § 215(8)(a) narrowly. See Christodoulou v. Terdeman, 262 AD2d 595, 596 (2d Dept. 1999) (CPLR § 215(8)(a) applied only to claims based on events of February 26, 1993 and December 28, 1993, because it was only in connection with events of those two days that a criminal prosecution was commenced against defendant); Gaffina v. Thatcher, No. 2017-52980, 2018 N.Y. Misc. LEXIS 8435 (Sup. Ct. Dutchess Cnty. Oct. 23, 2018) (CPLR § 215(8)(a) inapplicable where incidents charged in criminal action and those alleged in civil action occurred on different dates): McElligott v. City of N.Y., 15-cv-7107 (LOS), 2017 U.S. Dist. LEXIS 201829, at \*13 (S.D.N.Y. Dec. 7, 2017) (CPLR § 215(8)(a) inapplicable to claims against civil defendants not charged as co-defendants in criminal action, notwithstanding same events gave rise to both actions). Plaintiff alleges a far more tenuous connection to the Indictment than the criminal-civil links unsuccessfully asserted in those cases. + +Second, even if CPLR § 213-c and § 215(8)(a) apply, which they do not, Plaintiff's claims for torts committed outside N.Y. are still untimely per the limitations periods of those jurisdictions and CPLR § 202. While Plaintiff alleges Decedent raped her within 20 years of filing her Complaint (Compl. ¶13), she does not allege that occurred in N.Y. Plaintiff's claims for torts outside N.Y. are untimely. + +Third, Plaintiff fails to meet her burden to allege extraordinary circumstances sufficient to justify tolling or equitable estoppel. Equitable tolling is only applied where a plaintiff is "prevented in some extraordinary way from exercising h[er) rights." Viti v. Guardian Life Ins. Co. of Am., 10-cv-2908 (ALC) (MHD), 2012 U.S. Dist. LEXIS 189633, at \*30 (S.D.N.Y. Oct. 5, 2012), adopted by, 2013 U.S. Dist. LEXIS 174145 (S.D.N.Y. Dec. 11, 2013) (emphasis added) (citations omitted). Under this doctrine, a court may, "under compelling circumstances, make narrow exceptions to the statute of limitations ... 'to prevent inequity.'" Id. (emphasis added) (citations omitted). "That the doctrine is to be employed only sparingly -- in 'extraordinary and 'compelling' circumstances -- is reflected in the fact that the plaintiff bears the burden of persuasion to show that tolling is justified." Id. (emphasis added) (citing Boos v. Runyon, 201 F.3d 178, 185 (2d Cir. 2000)). A late-filing party seeking equitable tolling must also demonstrate she acted with "reasonable + +diligence" in pursuing her claims during the period she seeks to toll. Id. at \*32 (citation omitted). Equitable estoppel only applies where a plaintiff knows her cause of action exists but the defendant's conduct causes her to delay in bringing her lawsuit. Yesh, 2010 U.S. Dist. LEXIS 101744, at '5 (citation omitted). Equitable estoppel requires a plaintiff to show: (i) the defendant made a definite misrepresentation of fact and had reason to believe the plaintiff would rely on it; and (ii) the plaintiff reasonably relied on the misrepresentation to her detriment. Id. (citation omitted). Tolling is inappropriate where, as here, a plaintiff fails to articulate any acts by a defendant that prevented her from timely commencing suit. Id. at '6 (citation omitted). + +Plaintiff's threadbare allegations of "deception," "threats" and the like (Compl. ¶14) do not establish "extraordinary" circumstances justifying tolling. Nor has Plaintiff alleged (i) that Decedent made a misrepresentation to her and had reason to believe she would rely on it, or (ii) that Plaintiff reasonably relied on it to her detriment. + +## 4. Plaintiff's claim for punitive damages fails as a matter of law.2 + +Plaintiff's punitive damages claim must be dismissed as a matter of law because none of the jurisdictions where the alleged torts occurred permits punitive damages against a decedent tortfeasor's estate. See Poindexter v. Zacharzewski, 18-14155, 2018 U.S. Dist. LEXIS 189861, at '6 (Nov. 5, 2018 S.D. Fla.) ("Florida law prohibits recovery of punitive damages from the estate of a wrongdoer who is deceased."); Jaramillo v. Providence Wash. Ins. Co., 117 N.M. 337, 346 (N.M. 1994) ("punishment and deterrence are not accomplished by enabling recovery of punitive damages from the estate"); NY EPTL § 11-3.2 (a)(1) ("an action may be brought or continued against the personal representative of the decedent, but punitive damages shall not be awarded nor penalties adjudged in any such action brought to recover damages for personal injury."); Powell v. Chi-Co's Distrib., ST-13-TOR-14, 2014 V.I. LEXIS 21, at \*5 n.13 (U.S.V.I. Super. Ct. Apr. 3, 2014) (Restat. §908(2) "reflects the common law of this jurisdiction").3 That is the law in most jurisdictions, as reflected in the Restatement. See Restat. (Second) Of Torts § 908 cmt. a (punitive damages not available against representatives of deceased tortfeasor).° + +2 Courts in this District regularly dismiss punitive damages claims. See The Cookware Co. (USA), LW v. Austin, 15.5796, 2016 U.S. Dist. LEXIS 177691, at '17 (S.D.N.Y. Dec. 8, 2016) (dismissing punitive damages claim without leave to replead); SJB v. N.Y.C. Dept of Educ., 03-6653, 2004 U.S. Dist. LEXIS 13227, at '25-26 (S.D.N.Y. Jul. 14, 2004) (dismissing punitive damages claims not statutorily available). + +3 To determine common law, USVI courts consider: (1) whether USVI courts previously adopted a rule; (2) the position taken by a majority of other jurisdictions; and (3) which approach is the soundest for the USVI. Gov't of Virgin Islands v. , No. S. CT. CIV. 2013-0095, 2014 WL 702639, at '1 (V.I. Feb. 24, 2014). These factors favor the Co-Executors: (1) pre-Banks, USVI courts expressed approval for Restat. § 908 (see v. Dowson Holding Co., 51 V.I. 619, 628 (D.V.I. 2009) (considering the inverse issue)): (2) a majority of other jurisdictions preclude punitive damages against a tortfeasor's estate (2 Linda L. Schlueter, Punitive Damages § 20.4 (7th ed. 2015)); and (3) post-Banks, USVI courts have held § 908 is the soundest rule (Powell, supra.). + +4 France does not recognize punitive damages. Punitive Damages, supra., at § 22.4 (citation omitted). + +Hon. Andrew L. Carter Jr. January 24, 2020 Page 4 + +Respectfully submitted, + +s/Bennet J. Moskowitz Bennet J. 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Carter Jr. District Court Judge United States District Court Southern District of New York 40 Foley Square New York, NY 10007 + +Re: v. huh he el al., Case No. 19-cv-10479 + +Dear Judge Carter, + +Pursuant to Individual Rule 2(A), Plaintiff hereby responds to Defendants' request for a pre-motion conference in connection with their anticipated motion to dismiss. Dkt. 12. Plaintiff's claims are timely under New York's statutes of limitation and the doctrine of equitable estoppel, and Defendants' proposed motion "to dismiss" Plaintiff's request for punitive damages is procedurally improper. For the following reasons, the Court should deny Defendants' anticipated motion in its entirety. + +## I. Plaintiff's Claims Are Timely Under New York Law. + +Plaintiff's claims are timely under New York's CPLR § 215(8)(a), which provides: "Whenever it is shown that a criminal action against the same defendant has been commenced with respect to the event or occurrence from which a claim governed by this section arises, the plaintiffshall have at least one year from the termination of the criminal action . . . to commence the civil action." (Emphasis added). Here, Epstein's criminal action in this District terminated on August 29, 2019. Compl. ¶ 36. Because Plaintiff filed the Complaint less than three months later, the action is timely under CPLR § 215(8Xa). Defendants' arguments against CPLR § 215(8)(a)'s application to these facts are meritless. + +First, Defendants' argument that CPLR § 215(8)(a) does not apply because Plaintiff was not named as a victim in Epstein's indictment is incorrect. New York courts have held that CPLR § 215(8)(a) is "plain, clear and unambiguous" that it does not require that the plaintiff be "the victim or the specific person upon whom the crime had been committed." Clemens v. Nealon, 202 A.D.2d 747, 749 (N.Y. App. Div. 1994). + +Second, Defendants' narrow construction of § 215(8)(a)'s "event or occurrence" language is improper, especially in light of the breadth of Epstein's indictment. The charges were not limited to crimes committed against specific victims. For example, the overt acts alleged for the sex trafficking conspiracy charge were enticing and recruiting multiple victims, "including minor victims identified herein." Compl., Ex. A (S.D.N.Y Indictment) ¶ 22(a) (emphasis added). As another example, the Indictment's sex trafficking count charged Epstein with the sex trafficking of "numerous individuals .. . including but not limited to Minor Victim-1." Id. ¶ 24. Nor did the + +# BSF + +Indictment describe the sex trafficking conspiracy as exclusively targeting minor victims—it explicitly acknowledged that some victims were not underage at the time of the sexual abuse. Id. ¶ 11 ("[Epstein] knew that many of his New York victims were underage."). The Indictment was targeted at Epstein's sex-trafficking scheme as a whole, and that scheme is the event or occurrence from which Plaintiff's civil claims arose. See Kashef v. BNP Paribas S.A., 925 F.3d 53, 56-57, 62 (2d Cir. 2019) (guilty plea conceding "knowledge of the atrocities being committed in Sudan" allowed victims of the atrocities in Sudan use 2 1 5(8Xa) because causes of action arose out of defendant's general conspiracy with Sudan to violate U.S. sanctions put in place to stop atrocities). Because Plaintiff's claims arise out of this common scheme, they fall within CPLR § 2 I 5(8Xa). + +The cases Defendants cite are inapposite because the criminal charges in those cases were much narrower than Epstein's, and related to events that occurred on specified dates. See Christodoulou v. Terdeman, 262 A.D.2d 595, 596 (N.Y. App. Div. 1999) (prosecution commenced only in connection with events on two dates); Gallina v. Thatcher, No. 2017-52980, 2018 N.Y. Misc. LEXIS 8435, at •3 (Sup. Ct. Oct. 23, 2018) (indictment "charged [the defendant] for incidents occurring on three (3) specific dates"). Epstein's Indictment was much broader, covering sexual abuse that occurred "over the course of many years" "from at least in or about 2002, up to and including at least in or about 2005." S.D.N.Y. Indictment ¶¶1-2, 8, 20, 24 (emphases added). Plaintiff's claims are therefore timely under CPLR § 215(8)(a) because the scheme the S.D.N.Y. Indictment targeted is the event or occurrence from which Plaintiff's civil claims arise. + +Plaintiff's claims are also timely under CPLR § 213-c, which provides for a twenty year limitations period for "all civil claims or causes of action brought by any person for physical, psychological or other injury or condition suffered by such person as a result of conduct which would constitute rape" or other enumerated sex crimes. The Complaint alleges that Epstein raped Plaintiff numerous times within the past twenty years. See Compl. ¶ 44 ("Epstein repeatedly raped Juliette by forcible compulsion."). Plaintiff's claims fall squarely within CPLR § 213-c's coverage. Defendants' assertion that CPLR § 213-c does not apply because "the 20-year SOL does not apply retroactively" is meritless. CPLR § 213-c's text contains no such limitation, and was revised last year (increasing the limitations period from 5 to 20 years) specifically to allow claims such as Plaintiff's to proceed. See June 17, 2019, New York Committee Report, 2019 NY S.B. 6574 (NS) (noting that "victims who have suffered in silence for decades have bravely spoken about their abuse, and have also laid bare the state's limited ability to prosecute their abusers due to the passage of time" and that "this bill would increase the time period in which the victim could bring a civil suit for these offenses to twenty years"). + +Defendants also assert that Plaintiff's claims are untimely under New York's borrowing statute, CPLR § 202. This argument fails for two reasons. First, CPLR § 202 only applies to nonresidents who are injured outside of New York, and the controlling date for determining a plaintiff's residence is the date on which the cause of action accrued, not the date on which the action was commenced. See, e.g.. DeMartino v. 148 A.D.2d 568, 570 (N.Y. App. Div. 1989). Under the borrowing statute, the phrases "resident" and "domicile" are not synonymous. "Rather, the determination of whether a plaintiff is a New York resident, for purposes of CPLR § 202, turns on whether [she] has a significant connection with some locality in the State as the result of living there for some length of time during the course of a year." Antone v. Gen. Motors Corp., 473 N.E.2d 742, 746 (N.Y. 1984). The fact that Plaintiff currently lives in South Africa is therefore irrelevant. At the time of her repeated sexual assaults, Plaintiff was a resident of New York. + +Epstein's co-conspirators got Plaintiff a visa so that she could travel to New York often, and when she visited she stayed at Epstein's New York home for one to two weeks at a time. Compl. ¶¶ 41, 46. Because Plaintiff had a significant connection with New York at the time her cause of action accrued, she was a resident of New York, and CPLR § 202 does not apply. + +Second, even if New York's borrowing statute did apply and Plaintiff's claims were otherwise untimely, they would still not be barred because CPLR § 215(8Xa) provides for civil actions to commence within "one year from the termination of the criminal action . . . notwithstanding that the time in which to commence such action has already expired." + +### II. Plaintiff Has Sufficiently Pled Facts Supporting Equitable Estoppel and Tolling. + +Even if Plaintiff's claims were otherwise time-barred under New York's statutes of limitation (they are not), they would still be timely under the doctrine of equitable estoppel. Defendants assert that Plaintiff "fails to meet her burden to allege extraordinary circumstances sufficient to justify tolling or equitable estoppel." Dkt. 12 at 2. But the Complaint alleges in detail the methods of intimidation and control that Jeffrey Epstein and his co-conspirators used to deter their victims from seeking justice. Equitable estoppel applies "where it would be unjust to allow a defendant to assert a statute of limitations defense," Zumpano v. Quinn, 849 N.E.2d 926, 929 (N.Y. 2006), due to "deception, concealment, threats, or other misconduct," Zoe G. v. Frederick F.G., 208 A.D.2d 675, 675 (N.Y. App. Div. 1994). The Complaint alleges that Epstein and his co-conspirators manipulated victims using "financial power, promises, and threats;" that Plaintiff was "afraid of betraying Epstein because of his money and power" and was "afraid he would hurt her or her family;" that Epstein tried to scare her by telling her that he had one of his accusers sent to prison; and that Epstein tried to keep in contact with Plaintiff after the abuse ended. Compl. 27, 47, 51. The allegations concerning Epstein's purposeful silencing of his victims (and Plaintiff specifically) easily provide the requisite "extraordinary circumstances" for equitable tolling. + +Because equitable estoppel and equitable tolling are fact-specific doctrines, Defendants' attempt to resolve the issue at motion to dismiss is inappropriate, and any motion challenging whether or not those doctrines apply should be reserved until after the parties have conducted discovery. See, e.g., Carelock v. United States, 2015 WL 5000816, at \*8 (S.D.N.Y. Aug. 20, 2015). + +## III. The Court Should Address Punitive Damages After Discovery + +Federal Rule 12(b)(6) allows a defendant to file a motion to dismiss for "failure to state a claim upon which relief can be granted." Defendants' request for the Court to dismiss Plaintiff's claim for punitive damages does not relate to either of Plaintiff's clams (battery and intentional infliction of emotion distress) and does not relate to the sufficiency of the allegations in the Complaint. The issue of what type of damages to which Plaintiff is entitled should therefore be dealt with at a later stage of this litigation. See. e.g., Okyere v. Palisades Collection, LLC, 961 F. Supp. 2d 522, 536 (S.D.N.Y. 2013) (denying "motion to 'dismiss' plaintiff's request for punitive damages as procedurally premature"). + +![](_page_3_Picture_1.jpeg) + +Respectfully submitted, + +Is/Joshua I. Schiller + +David Boies, Esq. Joshua I. Schiller, Esq. Sigrid S. 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INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +Pursuant to the Court's January 14, 2020, order (Dkt. 11), the parties submit the following report addressing the required topics under Rule 26(0(3) of the Federal Rules of Civil Procedure: + +- (A)The parties have already exchanged initial disclosures. +- (B) Plaintiff seeks discovery as to Jeffrey Epstein's documents concerning + - a. The Plaintiffs; + - b. Mr. Epstein's sex-trafficking conspiracy; + - c. Visitors and/or passengers at any of Mr. Epstein's multiple residences or aircraft where the sex trafficking occurred; + - d. Communications between Mr. Epstein and his co-conspirators; + - e. Communications between Mr. Epstein and his employees; + - f. Communications between Mr. Epstein and any government official regardless of country; + +- g. Mr. Epstein's flight logs and helicopter logs; +- h. Video tapes and photographs taken at Mr. Epstein's properties or on his planes; +- i. Financial records; +- j. Mr. Epstein's message pads and any phone call logs or phone/contact directories; and +- k. Amazon.com account details, including order history. + +The Co-Executors preserve all of their discovery rights including the right to object to Plaintiff's discovery requests. The Co-Executors' position is that the general subjects of discovery in this action are: (1) Mr. Epstein's alleged abuse of Plaintiff; and (2) Plaintiff's alleged damages. + +There is no need to conduct discovery in phases, or otherwise limit discovery to particular issues. + +- (C) The parties shall confer and stipulate as to a protocol for the exchange of documents including the production of electronically stored information, no later than April 13, 2020. (D)— (F) There are no further issues requiring the Court's attention at this time. + +A proposed scheduling order is attached hereto as Exhibit A. Where the parties are in disagreement regarding a particular deadline, their respective positions are noted. + +Respectfully submitted, + +Is/ Sigrid S. McCawley + +David Boies, Esq. + +Joshua I. Schiller, Esq. + +Sigrid S. McCawley, Esq. + +Is/ Bennet J. Moskowitz + +Bennet J. Moskowitz, Esq. + +cc: Counsel of Record (via ECF) + +# EXHIBIT A + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +Plaintiff, CASE NO: 19-cv-10479-ALC-DCF + +[PROPOSED] SCHEDULING ORDER + +v. + +DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +### DEBRA FREEMAN, United States Magistrate Judge: + +It is hereby ORDERED that: + +- 1. Plaintiff's proposal: The parties shall serve their initial document requests and interrogatories no later than March 12, 2020. The Co-Executors' proposal: 30 days from the Court's entry of this Order. +- 2. The Co-Executors' proposal: Plaintiffs shall provide HIPAA-compliant medical records release authorizations to the Defendants no later than 14 days from Defendants' request. Plaintiff's position: Any request for HIPAA releases shall be by motion if the parties are unable to reach agreement without Court intervention, after discovery requests are served. +- 3. Any motions to amend the pleadings or to join any additional parties shall be filed no later than March 27, 2020. +- 4. The parties shall confer and stipulate as to a protocol regarding the production of documents and electronically stored information no later than April 13, 2020. + +- 5. Plaintiff's proposal: All fact discovery shall be completed no later than June 10, 2020. The Co-Executors' proposal: 160 days from the Court's entry of this Order. +- 6. Expert discovery shall be conducted on the following schedule: + - a. Plaintiffs proposal: Each party bearing the affirmative burden of proof on a claim or defense shall serve its expert report(s) with respect to that claim or defense no later than May 27, 2020. The Co-Executors' proposal: 190 days from the Court's entry of this Order (i.e., 30 days after the close of fact discovery). + - b. Rebuttal reports shall be served no later than June 26, 2020. The Co-Executors' proposal: 220 days from the Court's entry of this Order (i.e., 60 days after the close of fact discovery). + - c. Expert discovery shall be completed no later than July 27, 2020. The Co-Executors' proposal: 240 days from the Court's entry of this Order. +- 7. The parties may stipulate to modify interim deadlines in this Scheduling Order, without seeking prior leave of Court. + +Dated: New York, New York + +February 2020 + +SO ORDERED + +DEBRA FREEMAN United States Magistrate Judge + +## Cordes to: + +All counsel (via ECF) \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731985/EFTA02731985.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02731985/EFTA02731985.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1717e9151e380ccad3e1ddbed35bfa867c2f5cce --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731985/EFTA02731985.metadata.json @@ -0,0 +1,377 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02731985.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + 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Nine East 71st Street et aL, No. 1:19-cv-07625 (AJN) (DF) + +Katlyn Doe v. Indyke et at, No. 1:19-cv-07771 (PKC) (DF) + +Priscilla Doe v. Indyke et at, No. 1:19-cv-07772 (ALC) (DF) + +Lisa Doe v. Indyke et at, No. 1:19-cv-07773 (ER) (DF) + +Jane Doe v. Indyke et at, No. 1:19-cv-08673 (KPF) (DF) + +v. Indyke et at, No. 1:19-cv-10475 (LGS) (DF) + +v. Indyke et aL, No. 1:19-cv-10476 (PGG) (DF) + +v. Indyke et at, No. 1:19-cv-10479 (ALC) (DF) + +Jane Doe 1000 v. Indyke et at, No. 1:19-cv-10577 (LGS) (DF) + +Jane Doe 15 v. Indyke et at, No. 1:19-cv-10653 (PAE) (DF) + +Mary Doe v. Indyke et at, No. 1:19-cv-10758 (PAE) (DF) + +v. Indyke et at, No. 1:19-cv-10788 (O1-1W) (DF) + +Anastasia Doe v. Indyke et aL, No. 1:19-cv-11869 (MN) (DF) + +## DEBRA FREEMAN, United States Magistrate Judge: + +The Court having held a case management conference on February 11, 2020, with counsel for all parties in the above-referenced cases, it is hereby ORDERED, as stated at the conference, that: + +- 1. To the extent not already made, the parties shall make initial disclosures under Rule 26(a)(1) of the Federal Rules of Civil Procedure no later than February 25, 2020. +- 2. The parties shall serve their initial document requests and interrogatories no later than March 10, 2020. In their initial interrogatories, the parties may, as reasonable, seek information outside the scope of Local Civil Rule 33.3(a). +- 3. Any motions to amend the pleadings or to join any additional parties shall be filed no later than April 30, 2020. + - 4. All fact discovery shall be completed no later than June 10, 2020. + +- 5. Expert discovery shall be conducted on the following schedule: + - a. Plaintiffs' expert reports shall be served no later than June 10, 2020. + - b. Defendants' rebuttal reports shall be served no later than July 10, 2020. + - c. Expert discovery shall be completed no later than July 31, 2020. +- 6. The parties may stipulate to modify interim deadlines in this Scheduling Order, without seeking prior leave of Court. +- 7. The parties to the above-referenced cases shall submit joint status reports to the Court, regarding discovery and the progress of settlement discussions, no later than April 30, + +2020. + +Dated: New York, New York February 11, 2020 + +SO ORDERED + +DEBRA FREEMAN United States Magistrate Judge + +## Copies to: + +All counsel in the above-referenced cases (via ECF) \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731990/EFTA02731990.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02731990/EFTA02731990.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f5c79c0b3c2b51473d0c65e2e1bd8bbae0d2310e --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731990/EFTA02731990.metadata.json @@ -0,0 +1,163 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02731990.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2554, + "elapsed_seconds": 0.97, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "DEBRA FREEMAN, United States Magistrate Judge:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 336.96 + ], + [ + 351.7479248046875, + 336.96 + ], + [ + 351.7479248046875, + 352.863037109375 + ], + [ + 68.544, + 352.863037109375 + ] + ] + }, + { + "title": "Copies to:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 56.304, + 467.37 + ], + [ + 110.82744598388672, + 467.37 + ], + [ + 110.82744598388672, + 482.238037109375 + ], + [ + 56.304, + 482.238037109375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "Text", + 16 + ], + [ + "ListItem", + 4 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 19 + ], + [ + "ListItem", + 6 + ], + [ + "Text", + 5 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02731990" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731992/EFTA02731992.md b/marker2/court-redacted-v-indyke-10479/EFTA02731992/EFTA02731992.md new file mode 100644 index 0000000000000000000000000000000000000000..9ca231986f9e7a48b1cd87286c885cb6a3e09b08 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731992/EFTA02731992.md @@ -0,0 +1,153 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +X Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, Defendants. X + +Index No. I :19-cv-10479-ALC-DCF + +### MOTION FOR ADMISSION PRO HAC VICE + +Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern Districts of New York, Mary "Molly" S. DiRago hereby moves this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"), in the above-captioned action. + +I am in good standing of the bar(s) of the state of Illinois and there are no pending disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule I .3. + +/s/ Mary "Molly" S. DiRago + +Mary "Molly" S. DiRago (Pro Hac Vice Pending) + +Troutman Sanders LLP + +One North Wacker Drive, Suite 2905 + +Chicago, 60606 + +(312) 759-1926 + +(312) 759-1939 (Fax) + +molly.dirago@troutman.com + +Attorneys for Defendants Darren K. Indyke and + +Richard D. Kahn, Co-Executors of the Estate of + +Jeffrey E. Epstein + +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +X + +Plaintiff, + +v. Index No. 1:19-cv-10479-ALC-DCF + +DARREN K. INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD • EPSTEIN, + +• + +Defendants. + +X + +# AFFIDAVIT IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE + +I, Mary "Molly" S. DiRago, declare as follow: + +I. I am a member in good standing of the State Bar of Illinois and an associate with the law firm Troutman Sanders LLP, counsel for Defendants, Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"). I submit this affidavit in support of my Motion for Admission Pro Hac Vice before this Court. + +2. I have never been convicted of a felony. + +3. I have never been censured, suspended, disbarred, or denied admission or readmission by any court. + +4. There are no disciplinary proceedings presently against me. + +I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. + +Dated: February 13, 2020 Respectfully Submitted, + +/il Mary "Molly" S. DiRago + +Mary "Molly" S. DiRago (Pro Hac Vice Pending) + +Troutman Sanders LLP + +One North Wacker Drive, Suite 2905 + +Chicago, 60606 + +(312) 759-1926 + +(312) 759-1939 (Fax) + +molly.dirago@troutman.com + +Attorneys for Defendants Darren K. Indyke and + +Richard D. Kahn, Co-Executors of the Estate of + +Jeffrey E. Epstein + +# Certificate of Admission To the Bar of Illinois + +I, Carolyn Taft Grosboll, Clerk of the Supreme Court of Illinois, do hereby certify that + +Mary Sharon DiRago + +has been duly licensed and admitted to practice as an Attorney and Counselor at Law within this State; has duly taken the required oath to support the CONSTITUTION OF THE UNITED STATES and of the STATE OF ILLINOIS, and also the oath of office prescribed by law, that said name was entered upon the Roll of Attorneys and Counselors in my office on 11/04/2004 and is in good standing, so far as the records of this office disclose. + +> IN WITNESS WHEREOF, I have hereunto subscribed my name and affixed the seal of said Court, this 31st day of January, 2020. + +> > Croy acitee + +Clerk, Supreme Court of the State of Illinois + +# CERTIFICATE OF GOOD STANDING + +![](_page_5_Picture_2.jpeg) + +United States of America + +}ss. Mary S DiRago + +Northern District of Illinois + +G. Bruton , Clerk of the United States District Court for the Northern District of Illinois, + +DO HEREBY CERTIFY That Mary S DiRago was duly admitted to practice in said Court on (12/08/2004) and is in good standing as a member of the bar of said court. + +Dated at Chicago, Illinois on (01/29/2020 ) + +Mlle, Bruton , Clerk, + +By: Tina Lam Deputy Clerk + +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +X + +Plaintiff, + +v. + +Index No. 1:19-cv-10479-ALC-DCF + +DARREN K. INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +X + +## ORDER FOR ADMISSION PRO HAC VICE + +The motion of Mary "Molly" S. DiRago for admission to practice Pro Hac Vice in the above captioned action is granted. + +Applicant has declared that she is a member in good standing of the bar(s) of the state(s) of Illinois; and that her contact information is as follows: + +Mary "Molly" S. DiRago Troutman Sanders LLP One North Wacker Drive, Suite 2905 Chicago, 60606 (312) 759-1926 (312) 759-1939 (Fax) molly.dirago@troutman.com + +Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors") in the above entitled action; + +IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. + +Dated: + +United States District/Magistrate Judge \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02731992/EFTA02731992.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02731992/EFTA02731992.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e0c1dca8d6e09d642ba6181d7b1119f23d924c53 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02731992/EFTA02731992.metadata.json @@ -0,0 +1,507 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02731992.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 8, 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DARREN K. INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, Defendants. X x + +USDC SDNY I )0CUMENT !:.LECTRONICALLY FILED TIOC #: DATE FILED: 42- I 202° + +Index No. 1:19-cv-I 0479-ALC-DCF + +## ORDER FOR ADMISSION PRO HAC VICE + +The motion of Mary "Molly" S. DiRago for admission to practice Pro Hac Vice in the above captioned action is granted. + +Applicant has declared that she is a member in good standing of the bar(s) of the state(s) of Illinois; and that her contact information is as follows: + +Mary "Molly" S. DiRago Troutman Sanders LLP One North Wacker Drive, Suite 2905 Chicago, 60606 (312) 759-1926 (312) 759-I 939 (Fax) molly.dirago©troutman.com + +Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"), in the above entitled action; + +IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. + +Dated: 07-AV/A 2-OAziAi 1)-2 + +United States District/Magistrate Judge + +DEBRA FREEMAN UNITED STATES MAGISTRATE JUDGE SOUTHERN DISTRICT OF NEW YORK \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732000/EFTA02732000.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02732000/EFTA02732000.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..949a00230a400acdf6ad6fdb9c1b4d9df9f235f9 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732000/EFTA02732000.metadata.json @@ -0,0 +1,120 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02732000.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1492, + "elapsed_seconds": 0.59, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "ORDER FOR ADMISSION PRO HAC VICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 187.272, + 352.193115234375 + ], + [ + 416.11224365234375, + 352.193115234375 + ], + [ + 416.11224365234375, + 365.4785461425781 + ], + [ + 187.272, + 365.4785461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 34 + ], + [ + "Text", + 8 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 98 + ], + [ + "Line", + 11 + ], + [ + "Text", + 4 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02732000" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732002/EFTA02732002.md b/marker2/court-redacted-v-indyke-10479/EFTA02732002/EFTA02732002.md new file mode 100644 index 0000000000000000000000000000000000000000..a4baea3c43311125758c464c1fcde4c5c9b2471b --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732002/EFTA02732002.md @@ -0,0 +1,23 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +vs. + +Plaintiff, + +DARREN INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +Case No. 1:19-cv- 10479 (ALC) + +## NOTICE OF APPEARANCE + +PLEASE TAKE NOTICE that the undersigned attorney, Andrew Villacastin, who is a member in good standing of the bar of this Court, hereby appears as counsel for Plaintiff in the above-captioned proceeding. + +Dated: New York, New York March 6, 2020 + +BOLES SCHILLER FLEXNER LLP + +By: /s/ Andrew Villacastin Andrew Villacastin 55 Hudson Yards Telephone: (212) 446-2300 Fax: (212) 446-2350 avillacastin@bsfllp.com + +Attorney for Plaint \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732002/EFTA02732002.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02732002/EFTA02732002.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ee5154343534f437e21486c023cfa55787900c04 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732002/EFTA02732002.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02732002.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 689, + "elapsed_seconds": 0.67, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.78000000000003, + 71.28 + ], + [ + 418.4738464355469, + 71.28 + ], + [ + 418.4738464355469, + 100.10302734375 + ], + [ + 192.78000000000003, + 100.10302734375 + ] + ] + }, + { + "title": "NOTICE OF APPEARANCE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 359.856, + 217.07999999999998 + ], + [ + 519.3272094726562, + 217.07999999999998 + ], + [ + 519.3272094726562, + 231.7330322265625 + ], + [ + 359.856, + 231.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 25 + ], + [ + "Text", + 11 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02732002" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732003/EFTA02732003.md b/marker2/court-redacted-v-indyke-10479/EFTA02732003/EFTA02732003.md new file mode 100644 index 0000000000000000000000000000000000000000..4b99355ee66b58983128c81b8abd834754f50932 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732003/EFTA02732003.md @@ -0,0 +1,23 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +vs. + +Plaintiff, + +DARREN I. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +Case No. 1:19-cv- 10479 (ALC) + +## NOTICE OF APPEARANCE + +PLEASE TAKE NOTICE that the undersigned attorney, Sabina Mariella, who is a member in good standing of the bar of this Court, hereby appears as counsel for Plaintiff in the above-captioned proceeding. + +Dated: New York, New York March 6, 2020 + +BOLES SCHILLER FLEXNER LLP + +By: /s/ Sabina Mariella Sabina Mariella 55 Hudson Yards Telephone: (212) 446-2300 Fax: (212) 446-2350 smariella®bsfllp.com + +Attorney for PlaintiA \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732003/EFTA02732003.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02732003/EFTA02732003.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3be886129acc019e0a4aec827bb8090f976bd839 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732003/EFTA02732003.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02732003.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 682, + "elapsed_seconds": 0.8, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.78000000000003, + 71.28 + ], + [ + 418.4401550292969, + 71.28 + ], + [ + 418.4401550292969, + 100.10302734375 + ], + [ + 192.78000000000003, + 100.10302734375 + ] + ] + }, + { + "title": "NOTICE OF APPEARANCE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 359.856, + 217.07999999999998 + ], + [ + 519.3272094726562, + 217.07999999999998 + ], + [ + 519.3272094726562, + 231.7330322265625 + ], + [ + 359.856, + 231.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 25 + ], + [ + "Text", + 11 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02732003" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732004/EFTA02732004.md b/marker2/court-redacted-v-indyke-10479/EFTA02732004/EFTA02732004.md new file mode 100644 index 0000000000000000000000000000000000000000..38715d19358bf7925130675928f8068642fa5ea5 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732004/EFTA02732004.md @@ -0,0 +1,57 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +Case No. 19-cv-10479-ALC + +Plaintiff, + +-against- + +Indyke, et al. Defendant. + +## NOTICE OF CHANGE OF ADDRESS + +TO ATTORNEY SERVICES CLERK AND ALL OTHER PARTIES + +z I have cases pending I have no cases pending + +Pursuant to Local Rule 1.3 of this Court, please take notice of the following attorney information change (s) for: + +Sabina Mariella + +FILL IN ATTORNEY NAME + +My SDNY Bar Number is:2212\_92\_6\_\_\_\_\_ My State Bar Number is \_5530170\_\_\_ + +I am, + +An attorney + +A Government Agency attorney + +A Pro Hac Vice attorney + +FIRM INFORMATION (Include full name of firm (OLD AND NEW), address, telephone number and fax number): + +OLD FIRM: FIRM NAME:a& Cromwell. LLP + +FIRM ADDRESS:\_12a\_Broag\_Snet Nsw York. NY 10004 + +FIRM TELEPHONE NUMBER: (719)558-4000 + +FIRM FAX NUMBER: (2121558-358g + +NEW FIRM: FIRM NAME: Boles Schiller Flexneth.. .P + +FIRM ADDRESS:) + +FIRM TELEPHONE + +FIRM FAX NUMBER:\_n\_4413-2350 + +I will continue to be counsel of record on the above-entitled case at my new firm/agency. + +I am no longer counsel of record on the above-entitled case. 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ORDER + +USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC#: DATE FILED: I • Ill - 20 + +ANDREW L. CARTER, JR., United States District Judge: + +On January 24, 2020, Defendant filed a letter motion requesting a pre-motion conference on an anticipated motion to dismiss pursuant to Fed. R. Civ. P. 121(6). On January 29, 2020, Plaintiff filed her response. Defendant's motion for a pre-motion conference is DENIED and the Court sets the following briefing schedule: + +Defendant's Motion to Dismiss: + +Plaintiff's Opposition: + +Defendant's Reply, if any: + +SO ORDERED. + +Dated: March 17, 2020 + +New York, New York + +April 14, 2020 + +May 12, 2020 + +May 26, 2020 + +7 + +ANDREW L. CARTER, JR. 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DiRago + +FILL IN ATTORNEY NAME + +My SDNY Bar Number is: My State Bar Number is 6282757 + +lam. + +An attorney A Government Agency attorney A Pro Hac Vice attorney + +FIRM INFORMATION (Include full name of firm (OLD AND NEW), address, telephone number and fax number): + +OLD FIRM: FIRM NAME: TROUTMAN SANDERS UP FIRM ADDRESS:One North Wacker Drive. Suite 2905 Chicago. IL 60606 FIRM TELEPHONE NUMBER: ovarN-IIN FIRM FAX NUMBER: awn. + +NEW FIRM: FIRM NAME:mameueNeatul rause FIRM ADDRESS: 227 StreeLltole\_3900, Chicago, 4 60606 FIRM TELEPHONE NUMBER:\_isipiss.isze FIRM FAX NUMBER: 1312)759-1939 + +I will continue to be counsel of record on the above-entitled case at my new firm/agency. + +I am no longer counsel of record on the above-entitled case. An order withdrawing my appearance was entered on by Judge + +Dated: 03/20/2020 /s/ Mary \*Molly\* S. 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INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +Case No. I:19-cv-10479 (ALC) (DCF) + +## NOTICE OF DEFENDANTS' MOTION TO DISMISS + +PLEASE TAKE NOTICE that upon the accompanying Memorandum of Law and all prior pleadings and proceedings in this action, Defendants will move this Court before the Hon. Andrew L. Carter, Jr., United States District Judge, at the Thurgood Marshall United States Courthouse, 40 Foley Square, New York, NY 10007, at a time to be scheduled by this Court, for an Order pursuant to Rule 12(13(6) of the Federal Rules of Civil Procedure dismissing Plaintiff Complaint (ECF No. 1); and for such other and further relief as may be just and proper. + +Dated: New York, New York Respectfully submitted, April 14, 2020 + +TROUTMAN SANDERS LLP 875 Third Avenue New York, NY 10022 212.704.6000 + +By:/s/Bennet J. Moskowitz Bennet J. 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INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +Case No. 1:19-cv-10479 (ALC) (DCF) + +## DEFENDANTS' MEMORANDUM OF LAW IN SUPPORT OF THEIR MOTION TO DISMISS PLAINTIFF'S COMPLAINT + +TROUTMAN SANDERS LLP 875 Third Avenue New York, New York 10022 Tel: 212-704-6000 Fax: 212-704-6288 + +Attorneys for Defendants + +# TABLE OF CONTENTS + +| | Page | +|---------------------------------------------------------------------------|------| +| PRELIMINARY STATEMENT | 1 | +| STATEMENT OF FACTS | 2 | +| I. Plaintiff Alleges Decedent Sexually Assaulted Her From 2002-2004, | | +| When She Was An Adult | 2 | +| ARGUMENT | 4 | +| I. Plaintiff's Causes Of Action Expired In 2014 At The Latest | 4 | +| II. Plaintiff's Attempts To Invoke Extraordinary Statute Of Limitations | | +| Exceptions Fail | 7 | +| A. CPLR § 215(8Xa) is inapplicable because the Indictment arises out | | +| of the alleged sex trafficking of minors, not adults such as Plaintiff | 7 | +| B. CPLR § 213-c is inapplicable because it is not retroactive | 10 | +| C. Plaintiff fails to meet her burden to allege "extraordinary" | | +| circumstances sufficient to justify tolling or equitable estoppel | 12 | +| III. Plaintiff's Claim For Punitive Damages Are Barred As A Matter Of Law | 16 | +| A. Banks factor one: previously, USVI courts favorably cited the | | +| estates | 18 | +| B. Banks factor two: a majority of U.S. jurisdictions do not permit an | | +| decedent | 19 | +| C. Banks factor three: Post-Banks, USV1 courts have favorably | | +| damages | 19 | +| CONCLUSION | 21 | + +## TABLE OF AUTHORITIES + +| Cases Abercrombie v. College, | Page(s) | +|-----------------------------------------------------------------------------------------------|------------| +| 438 F. Supp. 2d 243 (S.D.N.Y. 2006) In re Air Crash at Belle Harbor, | 15 | +| 10, 2008) Antone v. Gen. Motors Corp., Buick Motor Div., | 17 | +| 64 N.Y.2d 20, 484 N.Y.S.2d 514, 473 N.E.2d 742 (1984) Banks v. Intl Rental & Leasing Corp., | 6 | +| 55 V.I. 967 (V.I. 201 I) Blissett v. Eisensmidt, | 18, 19, 20 | +| 940 F. Supp. 449 (N.D.N.Y. 1996) Boos v. Runyon, | 17 | +| 201 F.3d 178 (2d Cir. 2000) Booth v. Bowen, | 13 | +| No. CIV. 2006-217, 2008 WL 220067 (D.V.I. Jan. 10, 2008) Brandy v. Flamboyant Inv. Co., Ltd., | 18 | +| 24 V.I. 249 (V.I. Tern Ct. 1989) Cerbone v. Intl Ladies' Garment Workers' Union, | 20 | +| 768 F.2d 45 (2d Cir. 1985) Christodoulou v. Terdeman, | 13 | +| 262 A.D.2d 595 (2d Dept. 1999) Clemens v. Nealon, | 7, 8 | +| 202 A.D.2d 747 (N.Y. App. Div. 1994) Commerzbank AG v. Deutsche Bank Nall Tr. Co., | 9 | +| 234 F. Supp. 3d 462 (S.D.N.Y. 2017) Conklin v. Maidenbaum, | 4 | +| (Ramos, J.) | 14 | + +| Crabtree v. Estate of Crabtree, | | +|-----------------------------------------------------------------------------------------------|--------| +| 837 N.E.2d 135 (Ind. 2005) v. Christian, | 19 | +| 46 V.I. 557 (D.V.I. App. Div. 2005) Dept of Econ. Dev. v. Arthur Andersen & Co., | 19 | +| 747 F. Supp. 922 (S.D.N.Y. 1990) | 15 | +| Fairley v. =, | | +| S.D.N.Y.) (Gardephe, J.) Gallina v. Thatcher, | 12 | +| 23, 2018) Gleason v. Gleason, | 7, 8 | +| 26 NY2d 28, 256 N.E.2d 513, 308 N.Y.S.2d 347 (1970) Gleason v. Holman Contract Warehousing, | 11 | +| 170 Misc. 2d 668, 649 N.Y.S.2d 647 (Sup. Ct. 1996) Gov't of Virgin Islands v. | II, 12 | +| No. S. CT. CIV. 2013-0095, 2014 WL 702639 (V.I. Feb. 24, 2014). Graham v. | I8 | +| 224 F.R.D. 59 (N.D.N.Y. 2004) v. Dowson Holding Co., | 17 | +| 51 V.I. 619 (D.V.I. 2009) Hammerman v. Louis Watch Co., | 18 | +| 7 A.D.2d 817, 181 N.Y.S.2d 65 (3rd Dept. 1958) Hammerman v Louis Watch Co., | 6 | +| 7 AD2d 817 In re Higgins, | 6 | +| 270 B.R. 147 (Bank.. S.D.N.Y. 2001) Isaac v. Crichlow, | 13 | +| 63 V.I. 38, 2015 V.I. LEXIS 15 (V.I. Super. Ct. 2015) Jaramillo v. Providence Wash. Ins. Co., | 19 | +| 117 N.M. 337 (N.M. 1994). | .17 | + +- v. Nyack Hosp., 86 F.3d 8 (2d Cir. 1996) 13 Kashef v. BNP Paribas S.A., 925 F.3d 53 (2d Cir. 2019) 10 Kunica v. St. Jean Fin., 97 Civ. 3804, 1998 U.S. Dist. LEXIS 11867 (S.D.N.Y. July 29, 1998) (Sweet, J.) 20 Lohr v. Byrd, 522 So. 2d 845 (Fla. 1988) 17 McElligott v. City of N. Y., No. 15-cv-7107 (LGS), 2017 U.S. Dist. LEXIS 201829 (S.D.N.Y. Dec. 7, 2017) 7 Moll v. U.S. Life Title Ins. Co. of N.Y., 700 F. Supp. 1284 (S.D.N.Y. 1988) 15 Pappas v. Hotel on the Cay Time-Sharing Ass 'n, 69 V.I. 3 (U.S.V.I. Super. Ct. 2015) 19 Poindexter v. Zacharzewski, No. 18-14155-CIV, 2018 U.S. Dist. LEXIS 189861 (Nov. 5, 2018 S.D. Fla.) 17 Powell v. Chi-Co's Distrib., No. ST-13-TOR-14, 2014 V.I. LEXIS 21 (U.S.V.I. Super. Ct. Apr. 3, 2014) 20 +- v. Consumers Distrib. Co., 648 F. Supp. 980 (S.D.N.Y. 1986) (Cedarbaum, J.) 21 Matter of Regina Metro. Co., LLC v. N.Y. State Div. of Hous. & Cmty. Renewal, 2020 NY Slip Op 02127 11 Siegfried v Siegfried, 92 A.D.2d 916 6 Simons v. Marriott Corp., 92 Civ. 3762 (SWK), 1993 U.S. Dist. LEXIS 14365 (S.D.N.Y. Oct. 12, 1993) 16 SIB v. N.Y.C. Dep 't of Educ., No. 03 Civ. 6653, 2004 U.S. Dist. LEXIS 13227 (S.D.N.Y. July 14, 2004) (Buchwald, J.) 20 + - v. N.Y.C. Dep't of COPT., No. 09-civ-7639, 2010 U.S. Dist. LEXIS 137152 (S.D.N.Y. 2010) 13 + +| St. House, Inc. v. Barrows, | | +|---------------------------------------------------------------------------------------------------------------|------------------------------------------------------------| +| 15 V.I. 435 (V.I. Terr. Ct. 1979) Starr Indem. & Liab. Co. v. Am. Claims Mgmt., | 70 | +| No. 14-cv-0463-JMF, 2015 U.S. Dist. LEXIS 60272 (S.D.N.Y. May 7, 2015) The Cookware Co. (USA), LLC v. Austin, | 16 | +| (Batts, J.) v. Rios, | 20 | +| 780 F. Supp. 2d 376 (D.V.I. 2011) In re U.S. Lines, Inc., | 20 | +| 318 F.3d 432 (2d Cir. 2003) Viti v. Guardian Life Ins. Co. of Am., | 13 | +| Oct. 5, 2012) Yesh Diamonds, Inc. v. Yashaya, | 12, 13 | +| Sept. 27, 2010) Statutes | 13 | +| EPTL § 11-3.2 (a)(1) | 16 | +| Fla. Stat. § 95.11 (3XO) | 1, 5 | +| McKinney's Cons. Laws | 9, 11 | +| N.M. Stat. § 37-1-8 | I, 5 | +| New York Child Victim's Act | 12 | +| New York Estates, Powers and Trusts Law | 16 | +| New York General Construction Law § 37-a Other Authorities | 17 | +| Alec A. Beech, | Adding Insult to Death: Why Punitive Damages Should Not Be | +| Imposed Against a Deceased Tortfeasor's Estate in Ohio, | 49 Akron L. Rev. | +| 553 (2016) | 19 | +| CPLR § 202 | 4, 5 | +| CPLR § 213-c | I, 2, 3, 10, II, 12 | + +| CPLR §§ 214(5), 215(3) | I, 4 | +|--------------------------------------------------------------|-------------| +| CPLR § 214-g | 12 | +| CPLR §215(8) | 8, 9 | +| CPLR § 215(8Xa) | 1,2,3,7,8,9 | +| Federal Rule of Civil Procedure 12(b)(6) | 1, 12, 21 | +| 2 Linda L. Schlueter, Punitive Damages § 20.4 (7th ed. 2015) | 19 | +| 2 Linda L. Schlueter, Punitive Damages § 22.4 (7th ed. 2015) | 18 | +| Restatement (Second) of Torts | 18, 19, 20 | +| Nonexistent Concept | 18 | +| Defendants | 19 | + +Defendants Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein (the "Co-Executors"), submit this memorandum of law in support of their motion, pursuant to Federal Rule of Civil Procedure 12(b)(6), to dismiss Plaintiff's Complaint (ECF No. I) because it is time-barred and Plaintiff's claim for punitive damages because it is prohibited by statute. + +### PRELIMINARY STATEMENT + +This action is time-barred. Plaintiff, who claims South African citizenship and residency, alleges that, from 2002 (when she was 20 years old) to 2004, Jeffrey E. Epstein ("Decedent") now deceased, committed various sexual offenses against her in the U.S. Virgin Islands ("USVI"), France, Florida,' New Mexico, and New York. (Comp!. 11 16, 38, 50, 55.) Plaintiff asserts two causes of action—battery and intentional infliction of emotional distress—and demands punitive damages. (Id. 11 54-64, p. 15.) + +However, Plaintiff's causes of action expired by: 2006 per the USVI's two-year statute of limitations (5 V.I.C. § 31(5)(A)); 2005 or 2007 per New York's one- or three-year statute of limitations (CPLR §§ 214(5), 215(3)); 2007 per New Mexico's three-year statute of limitations (N.M. Stat. § 37-1-8); 2008 per Florida's four-year statute of limitations (Fla. Stat. § 95.11 (3)(O)); and 2014 per France's ten-year statute of limitations (Art. 2226 (1) of the Civil Code). Accordingly, Plaintiff's claims are untimely and must be dismissed. + +In apparent recognition that her claims are time-barred, Plaintiff erroneously alleges that they are timely pursuant to CPLR § 215(8)(a)2 and CPLR § 213-c, they were equitably tolled, and + +I In two conclusory allegations, Plaintiff lists Florida as one of the locations where she was assaulted (Compl. 11 25, 55), but offers no factual allegations in support. + +2 CPLR § 215(8)(a) provides: "Whenever it is shown that a criminal action against the same defendant has been commenced with respect to the event or occurrence from which a claim governed by this section arises, the plaintiff shall have at least one year from the termination of the criminal action ... to commence the civil action" (emphasis added). + +that the Co-Executors are equitably estopped from asserting a statute of limitations defense. (Compl. 7J 12-15.) Each of these arguments fails as a matter of law. + +CPLR § 215(8)(a) does not apply here because Decedent's criminal indictment (the "Indictment"), which concerns alleged sexual abuse of minors, has nothing to do with Plaintiff, who alleges misconduct when she was an adult. Similarly, CPLR § 213-c fails because it does not apply retroactively, and Plaintiff's claims had already expired by the time it was enacted in September 18, 2019. Plaintiff also fails to meet her burden at the pleadings stage to allege extraordinary circumstances sufficient to justify tolling or equitable estoppel. + +Finally, Plaintiff's demand for punitive damages must also be dismissed as a matter of law. New York law, which applies here because New York has the greatest connection to this matter, expressly bars recovery of punitive damages in a personal injury action brought to recover damages from a decedent tortfeasor's estate—i.e., exactly what Plaintiff attempts to do here. However, even if Florida, New Mexico, USVI, or law applies (the only other locations where Plaintiff alleges she was harmed), Plaintiff's punitive damages claim would likewise be barred under the laws of those jurisdictions, which are in accord with New York and the majority of U.S. jurisdictions that prohibit recovery of punitive damages against a decedent tortfeasor's estate. + +## STATEMENT OF FACTS + +## I. Plaintiff Alleges Decedent Sexually Assaulted Her From 2002-2004, When She Was An Adult + +Plaintiff claims she met Decedent in 2002, when she was twenty years old, in Cape Town, South Africa. (Compl. 1 38.) She alleges that an American woman approached her and asked if she wanted to meet Decedent. (Id.) Plaintiff alleges she met Decedent and, on some later date, another woman helped Plaintiff get a visa, passport, and airline tickets so she could visit Decedent + +in New York. (Id. ¶¶ 39-41.) Plaintiff claims that, shortly after arriving in New York, she was flown to the Caribbean on Decedent's private plane. (Id. ¶¶ 4243.) Plaintiff alleges that Decedent first sexually assaulted her in the USVI. (Id. ¶¶ 43-44.) + +Plaintiff further alleges that she was sexually abused multiple times thereafter, during a period of two years, when she was forced to travel and meet Decedent in New York, Paris, and New Mexico. (Id. ¶¶ 46, 49-50.) Plaintiff claims her final trip to the United States was in 2004, when she allegedly flew to see Decedent at his New Mexico ranch. (Id. ¶ 50.) During this trip, Decedent and Plaintiff allegedly had an argument because Plaintiff was "not being obedient." (Id.) Decedent also asked Plaintiff to serve drinks on a plane headed to California, but Plaintiff and Decedent allegedly had another argument and Plaintiff flew home to South Africa instead. (Id.) This trip—sixteen years ago—was the last time she alleges she saw Decedent. (Id.) + +Apparently recognizing that her claims are time-barred under the applicable statutes of limitations, Plaintiff alleges generic legal conclusions that also appear in other time-bared complaints against the Co-Executors that Plaintiff's counsel filed in this District on behalf of other individuals. Thus, Plaintiff alleges in conclusory fashion: + +- This action has been timely filed pursuant to N.Y. C.P.L.R. § 215(8Xa), which provides that a plaintiff shall have at least one year from the termination of a criminal action against the same defendant to commence an action with respect to the event or occurrence from which the criminal action arose. A criminal action against [Decedent] with respect to the same sex trafficking enterprise from which Plaintiff's claims arise was terminated on August 29, 2019. (Id. ¶ 12.) +- This action has been timely filed pursuant to N.Y. C.P.L.R. § 213-C, which provides that a plaintiff shall have 20 years to file civil claims "for physical, psychological or other injury or condition suffered by such person as a result of conduct which would constitute rape in the first degree as defined in section 130.35 of the penal law." [Decedent] raped Plaintiff within 20 years of filing this Complaint. (Id. 1 13.) +- Any statute of limitations applicable to Plaintiff's claims is tolled due to the continuous and active deception, duress, threats of retaliation, and other forms of misconduct that [Decedent] and his co-conspirators used to silence his victims, including Plaintiff. [Decedent]'s actions deprived Plaintiff of the opportunity to commence this lawsuit before + +his death. Until his death, Plaintiff feared that [Decedent] and his co-conspirators would harm her or her family, or ruin her life, if she came forward. (Id. ¶ 14.) + +- Defendants are equitably estopped from asserting a statute of limitations defense. Allowing Defendants to do so would be unjust. [Decedent] and his co-conspirators intimidated each of his victims into silence by threatening their lives and their livelihoods, and therefore prevented Plaintiff from commencing this lawsuit before his death. By using threats, along with his wealth and power, [Decedent] was able to escape punishment for his crimes against countless young women and underage girls for the duration of his life. (Id. ¶ 15.) + +None of these threadbare allegations rescues Plaintiff's claims from being time-barred. + +## ARGUMENT + +# I. Plaintiffs Causes Of Action Expired In 2014 At The Latest + +Plaintiff claims she was sexually assaulted between 2002 and 2004 in New York, the USVI, Florida, New Mexico, and France. (Compl. ¶¶ 38, 50, 55.) Plaintiff asserts two causes of action based on these sexual assaults (battery and intentional infliction of emotional distress) and demands punitive damages. (Id. ¶¶ 54-64, p. 15.) CPLR § 202 provides that, when a non-New York resident such as Plaintiff sues on causes of action accruing outside New York, the complaint must be timely under the statute of limitations of both New York and the jurisdiction where the claim accrued.3 Here, Plaintiff's claims are not timely under New York law or any of the jurisdictions where the alleged torts occurred and the Court must dismiss her claims. + +New York. New York law applies a one-year limitations period to actions for assault and battery and a three-year limitations period to actions for personal injury. CPLR §§ 214(5), 215(3). Under either statute, Plaintiff's claims are untimely, as they expired in either 2005 or 2007. + +3 "ln diversity cases in New York, federal courts apply ... C.P.L.R. § 202." Commerzbank AG v. Deutsche Bank Nat'l Tr. Co., 234 F. Supp. 3d 462, 467 (S.D.N.Y. 2017) (citation omitted). + +USVj. Under USVI law, which is where Decedent's first sexual assault of Plaintiff allegedly occurred, the statute of limitations for battery actions is two years. 5 V.I.C. § 31(5)(A). Thus, under USVI law, Plaintiff's causes of action expired by 2006 at the latest. + +Florida. Although the Complaint does not allege any specific acts that occurred in Florida (nor even that Plaintiff was ever in Florida), even if it did, these claims would be time-barred. Under Florida law, the statute of limitations for actions "for assault, battery, false arrest, malicious prosecution, malicious interference, false imprisonment, or any other intentional tort" is four years. Fla. Stat. § 95.11 (3)(O). Accordingly, under Florida law, Plaintiff's causes of action expired by 2008 at the latest. + +New Mexico. Under New Mexico law, actions for "injury to a person" must be brought within three years. N.M. Stat. § 37-1-8. Thus, under New Mexico law, Plaintiff's claims expired in 2007 at the latest. + +France. Under law, the civil statute of limitations in the event of violence or sexual assault against an adult is 10 years. Art. 2226 (1) of the Civil Code. Therefore, under law, Plaintiff's claims expired in 2014 at the latest. + +To avoid these statutes of limitations, Plaintiff argues in her response to the Co-Executors' pm-motion letter that she was a resident of New York at the time of the alleged torts and, accordingly, CPLR § 202 is inapplicable. (ECF No. 13 at pp. 2-3.) This argument is unavailing for at least two reasons. + +First even if Plaintiff is correct—and, as explained below, she is not—her claims are still untimely under the laws of each jurisdiction that could conceivably apply to her claims. + +Second Plaintiff fails to allege any facts in her Complaint plausibly establishing she was ever a resident of New York. To the contrary, the Complaint alleges that Plaintiff is a South African + +citizen and resident (Compl ¶ 16); refers to only one specific visit to New York and that Plaintiff was "not there for long" (id. ¶ 42); and asserts that Decedent "forced [Plaintiff] to travel to the United States many times to see [Decedent] and be subjected to repeated sexual abuse for one to two weeks at a time, sometimes staying in his New York apartment" (id. ¶ 46). + +As a matter of law, New York residency requires significantly more than an occasional visit there. Rather, Plaintiff must allege facts establishing that she intended to remain in New York with some degree of permanency. + +In Antone v. Gen. Motors Corp., Buick Motor Div., 64 N.Y.2d 20, 30, 484 N.Y.S.2d 514, 518-19, 473 N.E.2d 742, 746-47 (1984), which Plaintiff cites in her pre-motion response letter, the court found that "[c]ases defining `resident' for purposes of venue under CPLR 503 are useful precedents (see, e.g., Siegfried v Siegfried, 92 AD2d 916; Hammerman v Louis Watch Co., 7 AD2d 817)." The courts in Siegfried and Hammerman found that, in order for a person to be deemed a resident of New York, "[s]he must stay there for some time and have the bona fide intent to retain the place as a residence for some length of time and with some degree of permanency." Siegfried, 92 A.D.2d 916, 916, 460 N.Y.S.2d 131, 133 (2nd Dept. 1983) (renting a room in Nassau County and party's statements regarding her intent to remain in Nassau County were insufficient to support a finding that she was a resident of Nassau County); Hammerman v. Louis Watch Co., 7 A.D.2d 817, 818, 181 N.Y.S.2d 65, 67 (3rd Dept. 1958) ("Residence requires more stability than occasional stopovers at a hotel... and the mere fact that the plaintiffs rent premises on a year round basis where they sleep while there on business, in our view, does not establish a residence."). + +Here, Plaintiff's allegations are insufficient to claim New York residency as a matter of law. Visiting New York "sometimes" over a two-year period hardly qualifies as evincing an intent to remain there with some degree of permanency. See Siegfried, 92 A.D.2d at 916. + +#### II. Plaintiff's Attempts To Invoke Extraordinary Statute Of Limitations Exceptions Fail + +### A. CPLR § 215(8)(a) is inapplicable because the Indictment arises out of the alleged sex trafficking of minors, not adults such as Plaintiff. + +Contrary to Plaintiff's contentions, CPLR § 215(8)(a) does not apply here. CPLR § 215(8)(a) provides: "Whenever it is shown that a criminal action against the same defendant has been commenced with respect to the event or occurrence from which a claim governed by this section arises, the plaintiff shall have at least one year from the termination of the criminal action ... to commence the civil action." (Emphasis added). + +Decedent's Indictment, which Plaintiff attaches to her Complaint, was not commenced with respect to Plaintiff. Rather, the Indictment alleges that Decedent sexually trafficked "minor girls" (Ex. A to Compl., ¶ 1 (emphasis added)), stating throughout that it concerns sex trafficking of "minors" (id. ¶¶ 24, 6, 8, 11-15, 18-20, 22). Because Plaintiff alleges she was between 20 and 22 years old when Decedent assaulted her (Compl. ¶¶ 1, 38, 50), this action and the Indictment necessarily arise from different events or occurrences. + +New York courts apply CPLR § 215(8Xa) narrowly. See Christodoulou v. Terdeman, 262 A.D.2d 595, 596 (2d Dept. 1999) (CPLR § 215(8)(a) applied only to claims based on events of February 26, 1993 and December 28, 1993, because it was only in connection with events of those two days that a criminal prosecution was commenced against defendant); Gallant' v. Thatcher, No. 2017-52980, 2018 N.Y. Misc. LEXIS 8435 (Sup. Ct. Dutchess Cnty. Oct. 23, 2018) (CPLR § 215(8)(a) inapplicable where incidents charged in criminal action and those alleged in civil action occurred on different dates); McElligott v. City of No. 15-cv-7107 (LGS), 2017 U.S. Dist. LEXIS 201829, at \*13 (S.D.N.Y. Dec. 7, 2017) (CPLR § 215(8Xa) inapplicable to claims against civil defendants not charged as co-defendants in criminal action, notwithstanding same events gave rise to both actions). + +GaUlna is especially instructive. In that case, an individual sued an attorney for battery and other claims based on the core allegation that, over the course of two years, the attorney committed various sexual misconduct against the plaintiff, including sexual assault. 2018 N.Y. Misc. LEXIS 8435, at \*1. Defendant had also been criminally charged with forceable touching for incidents that occurred with the plaintiff in 2017. Id. at \*3. The court dismissed as time-barred plaintiffs battery counts based on incidents alleged to have occurred in 2016. Id. at \*2-3. + +In doing so, the court rejected plaintiff's argument that CPLR § 215(8Xa) applied to the 2016 incidents, finding: + +> Plaintiff argues that the July and October 2016 incidents are part of the same ongoing course of events as the February, March and May 2017 incidents and should therefore be deemed timely commenced ... the case law does not support Plaintiffs interpretation of ... CPLR §215(8Xa). The criminal instruments ... demonstrate that Defendant was charged for incidents occurring on three (3) specific dates ... Pursuant to CPLR §215(8Xa), tolling would apply only to claims based on these dates, "because it was only in connection with the events of these [three] days that a criminal prosecution was commenced against the defendant." Christodoulou v. Terdeman, 262 AD2d 595, 596 [2d Dept. 1999]. As criminal charges were not commenced with respect to the July 2016 and October 2016 events, the tolling provisions of CPLR §215(8) do not apply. + +Id. at •3-4. Here, Plaintiff asserts a much more tenuous connection between this action and the Indictment than the one unsuccessfully asserted by the plaintiff in Galling (and the other cited cases). Therefore, the Court should reject Plaintiff's argument for the application of CPLR § 215(8)(a). + +In Plaintiff's response to the Co-Executors' pre-motion letter, Plaintiff asserts three arguments for application of CPLR § 215(8Xa). First Plaintiff argues that CPLR § 215(8)(a) does not require the Indictment to expressly identify Plaintiff as one of Decedent's victims. This is a strawman argument: no one argues otherwise. + +Plaintiff cites Clemens v. Nealon, 202 A.D.2d 747, 749 (N.Y. App. Div. 1994), for this assertion, stating that CPLR § 215(8Xa) "does not require that the plaintiff be 'the victim or the specific person upon whom the crime had been committed.' (ECF No. 13 at p. 1, quoting Clemens, 202 A.D.2d at 749, emphasis in letter). This characterization of Clemens is misleading. In Clemens, defendants were charged with criminal mischief resulting to damage to two boats. Id. at 748. The six plaintiffs in Clemens were aboard the two boats and sued to recover damages for assault and battery, infliction of emotional distress, and false imprisonment. Id. Defendant asserted that CPLR § 215(8) did not apply because the victims of the crimes were the owners of the two damaged boats—not the plaintiffs who were on the boats. Id. at 749. The court disagreed, reading the plain language of CPLR § 215(8), expressly requiring that the action arise out of the same "event or occurrence." Id. Thus, Clemens does not alter the requirement that Plaintiff must show she was a victim of the same "event or occurrence" on which the Indictment is based; she has not and cannot. The Indictment could not be clearer: it concerns sex trafficking of minors. Plaintiff does not allege she was a minor when Decedent sexually assaulted her. + +Second, Plaintiff urges a broad construction of CPLR § 215(8Xa) that effectively rewrites it by rendering the limitation therein—"with respect to the event or occurrence from which a claim governed by this section arises"—meaningless. Plaintiff effectively argues that, unless the Indictment expressly rules out that it arises from the same event as this action, then Plaintiff is entitled to invoke CPLR § 215(8)(a). That argument is contrary to basic principles of statutory interpretation prohibiting a reading of a statute that would render its words meaningless (see McKinney's Cons. Laws of NY, Book 1, Statutes § 92), the case law cited above, a plain reading of the Indictment, and common sense. + +Plaintiff cites Kashef v. BNP Paribas S.A., 925 F.3d 53 (2d Cir. 2019), in support of her erroneous argument. However, Kashef is factually distinguishable. The civil and criminal actions in that case both arose out of the same conspiracy between BNP and Sudan to violate U.S. sanctions. Id. at 63. Here, Plaintiff's allegations—that she traveled as an adult to visit Decedent in various places where he sexually assaulted her—do not comport with what is set forth repeatedly in the Indictment—namely, an alleged scheme to traffic minors. + +Acknowledging this critical defect, Plaintiff argues in her pre-motion response letter that the Indictment applies to trafficking of adults as well as minors, but deliberately misquotes the Indictment. According to Plaintiff: + +The charges were not limited to crimes committed against specific victims. For example, the overt acts alleged for the sex trafficking conspiracy charge were enticing and recruiting multiple victims, "including minor victims identified herein." + +(ECF No. 13 at p. 1, citing Indictment (emphasis added).) However, this quote, and the argument relying on it, is disingenuous. The cited portion of the Indictment actually states: + +"In or about 2004, Jefferey Epstein, the defendant, enticed and recruited multiple minor victims, including minor victims identified herein...." + +(Ex. A to Compl. ¶ 22(a) (emphasis added).) In other words, Plaintiff removed the word "minor" from the first part of the sentence to make it appear as though the latter reference to "minor victims" identified merely a subset of the former "multiple victims." Plaintiff's alteration of the text and meaning of the Indictment indicates she is aware she has a losing argument. While Plaintiff may claim she, too, is a victim of Decedent, she is not a victim by reason of the events giving rise to the Indictment. + +# B. CPLR § 213-c is inapplicable because it is not retroactive. + +Plaintiff also attempts to plead around the applicable statutes of limitations by erroneously invoking CPLR § 213-c, which currently provides for a twenty-year limitation period for certain sexual offenses. However, the twenty-year limitation set forth in CPLR § 213-c became effective September 18, 2019, and is thus inapplicable here. (The statute of limitations was five years as of 2006 and one year before then. L. 2006, ch. 3, § 5(b)). The twenty-year statute of limitations does not apply retroactively except "where the applicable !statute of limitations] in effect on the date of such act or omission has not yet expired." L. 2019, ch. 315, § 4 (emphasis added). That is not the case here. Therefore, CPLR § 213-c cannot revive Plaintiff's claims arising from torts committed in New York. + +In her pre-motion letter, Plaintiff contends—without legal authority and in complete disregard of what the enacting bill for CPLR § 213-c states very clearly—that CPLR § 213-c applies retroactively because CPLR § 213-c itself does not expressly state otherwise. This is wrong. Plaintiff provides no reason to disregard what the law amending CPLR § 213-c actually states, as quoted above. + +Plaintiff also has it backwards. Under New York law, "[i]t takes a clear expression of the legislative purpose ... to justify a retroactive application of a statute which assures that [the legislative body] itself has affirmatively considered the potential unfairness of retroactive application and determined that it is an acceptable price to pay for the countervailing benefits." Matter of Regina Metro. Co., LLC v. N.Y. State Div. of Nous. & Cmty. Renewal, 2020 NY Slip Op 02127, ¶ 12 (citing Gleason v. Gleason, 26 NY2d 28, 36, 256 N.E.2d 513, 308 N.Y.S.2d 347 (1970) (internal quotation marks and citation omitted). The rules for determining whether a statute is to be applied retroactively are contained in McKinney's Consolidated Laws of NY, Book 1, Statutes § 51 et seq. See Gleason v. Holman Contract Warehousing, 170 Misc. 2d 668, 649 N.Y.S.2d 647, 677 (Sup. Ct. 1996). McKinney's states: + +Generally, statutes are construed as prospective, unless the language of the statute, either expressly or by necessary implication, requires that it be given a retroactive + +construction. ... Stated differently, a construction of a statute which will give it a retroactive operation is not favored by the courts, but on the contrary, the laws [sic] favors a prospective interpretation wherever possible. It is well settled also that a statute will not be given a retroactive construction unless an intention to make it retroactive is to be deduced from its wording, and a law will not receive a retroactive construction unless its language, either expressly or by necessary implication, requires that it be so construed. A clear expression of the legislative purpose is required to justify a retrospective application.... + +Gleason, 649 N.Y.S.2d at 677-678. + +Here, there is no "clear expression" that the New York State legislature intended CPLR § 213-c to be applied retroactively. Rather, the legislature expressly stated the opposite. See L. 2019, ch. 315, § 4. + +By contrast, the recently-enacted New York Child Victim's Act, a revival statute that provides a one-year window in which to bring claims of sexual abuse of minors that had previously expired, expressly states it "revive[s]" claims that are "barred as of the effective date of this section because the applicable period of limitation has expired." CPLR § 214-g. This confirms the New York State Legislature is quite capable of indicating when a limitations period should be applied retroactively. Because the Legislature did not do that for CPLR § 213-c—it did the opposite— Plaintiff's claim cannot succeed. + +## C. Plaintiff fails to meet her burden to allege "extraordinary" circumstances sufficient to justify tolling or equitable estoppel. + +Plaintiff fails to meet her burden to allege extraordinary circumstances sufficient to justify tolling or equitable estoppel including on the pleadings. "Second Circuit cases discussing equitable tolling set a stringent standard for its application." Fairley v. No. 09-Civ-6894 (PGG), 2011 U.S. Dist. LEXIS 26536, at •16 (Mar. 15, 2011 S.D.N.Y.) (Gardephe, J.) (finding equitable tolling did not apply and granting defendants' Fed. R. Civ. P. 12(b)(6) motion to dismiss complaint on statute of limitations grounds). Equitable tolling only applies where a plaintiff is "prevented in some extraordinary way from exercising h[er] rights." Viti v. Guardian + +Life Ins. Co. of Am., No. 10-cv-2908 (ALC) (MHD), 2012 U.S. Dist. LEXIS 189633, at •30 (S.D.N.Y. Oct. 5, 2012), adopted by, 2013 U.S. Dist. LEXIS 174145 (S.D.N.Y. Dec. 11, 2013) (emphasis added) (citing v. N.Y.C. Dep't of Corr., No. 09-civ-7639, 2010 U.S. Dist. LEXIS 137152, at \*2 (S.D.N.Y. 2010); v. Nyack Hosp., 86 F.3d 8, 12 (2d Cir. 1996)). + +Under this doctrine, a court may, only "under compelling circumstances, make narrow exceptions to the statute of limitations ... 'to prevent inequity." Id. (emphasis added) (citing Yesh Diamonds, Inc. v. Yashaya, No. 09-CV-2016 (DLI) (RER), 2010 U.S. Dist. LEXIS 101744, at \*2 (E.D.N.Y. Sept. 27, 2010); In re U.S. Lines. Inc., 318 F.3d 432, 436 (2d Cir. 2003)). "That the doctrine is to be employed only sparingly—in 'extraordinary' and 'compelling' circumstances is reflected in the fact that the plaintiff bears the burden of persuasion to show that tolling is justified." Id. (emphasis added) (citing Boos v. Runyon, 201 F.3d 178, 185 (2d Cir. 2000)). A latefiling party seeking equitable tolling must also demonstrate she acted with "reasonable diligence" in pursuing her claims during the period she seeks to toll. Id. at \*32 (citation omitted). + +Equitable estoppel only applies where a plaintiff knows her cause of action exists, but the defendant's conduct caused her to delay bringing suit. See Yesh Diamonds, 2010 U.S. Dist. LEXIS 101744, at \*5 (citing Cerbone v. Intl Ladies' Garment Workers' Union, 768 F.2d 45, 50 (2d Cir. 1985)). "The rationale behind this equitable doctrine is to protect the person who brings their action after it would normally be barred because she was 'lulled' into believing that she should delay pursuing her cause of action." Id. (quoting In re Higgins, 270 B.R. 147, 158 (Bantu. S.D.N.Y. 2001)). Equitable estoppel requires a plaintiff to show: "(i) the defendant made a definite misrepresentation of fact and had reason to believe that the plaintiff would rely on it; and (ii) the plaintiff reasonably relied on that misrepresentation to h[er] detriment." Id. (citation omitted). Tolling is inappropriate where, as here, a plaintiff fails to articulate any acts by a defendant that prevented the plaintiff from timely commencing suit. See id. at \*6. + +Here, Plaintiff does not allege any particularized acts by Decedent that prevented her from exercising her rights. (Compl. ¶¶ 14-15.) Nor does Plaintiff allege that (i) Decedent made a misrepresentation to her and had reason to believe she would rely on it, or (ii) Plaintiff reasonably relied on it to her detriment. Therefore, there is no "extraordinary" basis alleged sufficient to toll the statute of limitations or estop the Co-Executors from asserting a statute of limitations defense. + +Plaintiff asserts in her pre-motion response letter that "the Complaint alleges in detail the methods of intimidation and control that [Decedent] and his co-conspirators used to deter their victims from seeking justice." (ECF No. 13 at 3.) This is false. Rather, the complaint merely alleges—in two conclusory paragraphs identical to paragraphs included in other plaintiff's complaints represented by the same counsel—that Decedent threatened and intimidated "his many victims, including Plaintiff." (Comp!. ¶¶ 14-15.) The remaining claims, even as retold by Plaintiff in her letter, do not allege any conduct by Decedent beyond "tr[ying] to keep in contact with Plaintiff after the abuse ended." (ECF. No. 13 at p. 3, citing Compl. ¶ 51.) The allegations Plaintiff points to as demonstrating intimidation merely describe Plaintiff's unextraordinary state of mind: Plaintiff was "afraid of betraying [Decedent] because of his money and power" (id., citing ¶ 47); Plaintiff was "afraid [Decedent] would hurt her or her family" (id.). There are no allegations explaining that Decedent did anything to impede Plaintiff from bringing this lawsuit for some fifteen years. + +Plaintiff's assertion that such thin allegations are "extraordinary" is inconsistent with numerous court decisions in which far stronger allegations were deemed insufficient to justify equitable estoppel or tolling. See, e.g., Conklin v. Maidenbaum, No. 12-cv-3606, 2013 U.S. Dist. LEXIS 113975, at •27 (S.D.N.Y. Aug. 13, 2013) (Ramos, J.) (finding equitable tolling inapplicable and dismissing complaint, notwithstanding that plaintiffs alleged they reasonably relied on defendants' representations over a period spanning more than ten months and dozens of telephone calls). + +Plaintiff alternatively argues in her pre-motion response letter that her entitlement to equitable estoppel and tolling are "fact-specific doctrines" and thus should be resolved after discovery. (ECF No. 13 at 3.) Plaintiff misunderstands New York law and understates the deficiencies in her own Complaint. Where, as here, a plaintiff fails to allege facts that support invocation of an exception to the statute of limitations, there is no issue of fact sufficient to defeat a motion to dismiss on statute of limitations grounds: + +> If properly pled, allegations of equitable estoppel normally create questions of fact which cannot be determined at a motion to dismiss ... However, without adequate pleading, the issue is not properly raised and therefore cannot defeat a motion to dismiss based on statute of limitations grounds. See Dep't of Econ. Dev. v. Arthur Andersen & Co., 747 F. Supp. 922, 943 (S.D.N.Y. 1990) (dismissing cause of action because plaintiff made no allegation in complaint that "its failure to timely institute its third-party action was due to its justified reliance upon a misrepresentation" by opposing party); Moll v. U.S. Life Title Ins. Co. of N. Y., 700 F. Supp. 1284, 1293 (S.D.N.Y. 1988) ("Plaintiffs have not alleged that defendant caused them to delay in bringing suit on a known cause of action. On the contrary, plaintiffs repeatedly emphasize that they did not discover the alleged ... violations until long after the limitations period had expired. Equitable estoppel is therefore not appropriate in this case."). + +Abercrombie v. College, 438 F. Supp. 2d 243 (S.D.N.Y. 2006) (emphasis added). + +Here, as in Abercrombie, "Plaintiff has failed to allege any facts that would support invocation of the equitable estoppel doctrine. First, Plaintiff does not identify the misrepresentations or other facts demonstrating fraudulent concealment that could serve as the basis for the claimed equitable estoppel. More particularly, Plaintiff has utterly failed to identify in the Complaint which statements led her to believe that she could delay bringing her lawsuit." Id. at 266. Nor does Plaintiff allege facts that would support invocation of equitable tolling. These are pleading deficiencies, not questions of fact. + +# III. Plaintiff's Claim For Punitive Damages Are Barred As A Matter Of Law + +Plaintiff's claim for punitive damages fails as a matter of law because it is barred by the law of each potentially applicable jurisdiction. When determining what law applies, courts look to the choice-of-law rules of the forum state. Simons v. Marriott Corp., 92 Civ. 3762 (SWK), 1993 U.S. Dist. LEXIS 14365, at \*15 (S.D.N.Y. Oct. 12, 1993). Under New York law, the law of the state where a tort occurs generally applies to punitive damages. See Starr Indent. & Liab. Co. v. Ant. Claims Mgmt., No. 14-cv-0463-JMF, 2015 U.S. Dist. LEXIS 60272, \*7 (S.D.N.Y. May 7, 2015) ("Because punitive damages are conduct-regulating, 'the law of the jurisdiction where the tort occurred will generally apply.' (quoting Deutsch v. Novartis Pharms. Corp., 723 F. Supp. 2d 521, 524 (E.D.N.Y. 2010)); Guidi v. Inter-Continental Hotels Corp., No. 95-CV-9006 (LAP), 2003 U.S. Dist. LEXIS 6390, at \*1 (S.D.N.Y. Apr. 16, 2003)). + +Here, Plaintiff alleges tortious conduct occurring in New York, Florida, New Mexico, the USVI, and France. (Compl. ¶¶ 25, 55.) None of these jurisdictions permits recovery of punitive damages against a deceased tortfeasor's estate. That is the law in most jurisdictions, as reflected in the Restatement. See Restat. (Second) Of Torts § 908 cat. a (punitive damages not available against representatives of deceased tortfeasor). Each of these jurisdictions is addressed below in turn. + +New York: New York Estates, Powers and Trusts Law provides: "No cause of action for injury to person or property is lost because of the death of the person liable for the injury. For any injury, an action may be brought or continued against the personal representative of the decedent, but punitive damages shall not be awarded nor penalties adjudged in any such action brought to recover damages for personal injury." NY EPTL § 11-3.2 (a)(1) (emphasis added). "Also, + +'there is a strong policy against the assessment of punitive damages against an estate on account of wrongful conduct of the decedent."' Graham v. , 224 F.R.D. 59, 63 (N.D.N.Y. 2004) (quoting Blissett v. Eisensmidt, 940 F. Supp. 449, 457 (N.D.N.Y. 1996)). + +New York General Construction Law § 37-a defines "personal injury" as including "an assault, battery, false imprisonment, or other actionable injury to the person either of the plaintiff, or of another." Here, Plaintiff seeks to recover damages for her alleged personal injuries. Accordingly, Plaintiff may not recover punitive damages from Decedent's estate based on alleged torts that occurred in New York. + +Florida: The result is the same under Florida law. "Florida law prohibits recovery of punitive damages from the estate of a wrongdoer who is deceased." Poindexter v. Zacharzewski, No. 18-14155-CIV, 2018 U.S. Dist. LEXIS 189861, at •6 (Nov. 5, 2018 S.D. Fla.) (citing Lohr v. Byrd, 522 So. 2d 845 (Fla. 1988) ("[A] decedent's innocent heirs should not be punished when the wrongdoer is unavailable because of death. In so holding, we join the majority of jurisdictions in this country that have considered this issue.")). + +New Mexico: Likewise, the Supreme Court of New Mexico has unequivocally held that "punishment and deterrence are not accomplished by enabling recovery of punitive damages from the estate of deceased tortfeasors." Jaramillo v. Providence Wash. Ins. Co., 117 N.M. 337, 346 (N.M. 1994). Accordingly, Plaintiff cannot recover punitive damages under New Mexico law. + +France: Plaintiff's claim for punitive damages against a tortfeasor's estate is barred under law because France prohibits punitive damages altogether. See, e.g., In re Air Crash at Belle Harbor, No. 02 MDL 1448 (RWS), 2008 U.S. Dist. LEXIS 109247, at •23-25 (S.D.N.Y. Mar. 10, 2008) ("Unlike many jurisdictions in the United States, including New York, France prohibits punitive damages claims as they are known in the United States. ... Instead of employing + +punitive damages as a mechanism for punishing and deterring potentially harmful conduct, France has instead deemed liability for compensatory damages in conjunction with penal liability (where appropriate) to be a sufficient deterrent.") (internal citations and quotation marks omitted); 2 Linda L. Schlueter, Punitive Damages § 22.4 (7th ed. 2015) (citing Rouhette, The Availability of Punitive Damages in Europe: Growing Trend or Nonexistent Concept, 74 Def. Coun. J. 320 (2007)). + +USVI:USVI courts apply a "Banks analysis" to determine U.S.V.I. common law. Banks v. Intl Rental & Leasing Corp., 55 V.I. 967, 979 (V.I. 2011). The Banks analysis includes consideration of three factors: (1) whether any USVI courts have previously adopted a particular rule; (2) the position taken by a majority of courts of other jurisdictions; and (3) most importantly, which approach represents the soundest rule for the USVI. Gov't of Virgin Islands v.=, No. S. CT. CIV. 2013-0095, 2014 WL 702639, at •1 (V.I. Feb. 24,2014). Applying the Banks factors here demonstrates that USVI courts would adopt the rule in the Restatement (Second) of Torts which is also followed in the majority of United States jurisdictions, including New York—and hold that punitive damages are not available against a deceased tortfeasor's estate. These factors are analyzed below. + +### A. Banks factor one: pre% iously, USVI courts favorably cited the Restatement section that precludes punitive damages against estates. + +USVI courts have favorably recited the Restatement's rule precluding punitive damages against a decedent tortfeasor's estate. See, e.g., v. Dowson Holding Co., 51 V.I. 619, 628 (D.V.I. 2009); Booth v. Bowen, No. CIV. 2006-217,2008 WL 220067, at •5 (D.V.I. Jan. 10, 2008). In these cases, the U.S. District Court for the Virgin Islands considered the inverse of the issue here, i.e., whether the personal representatives of an estate may obtain punitive damages in an action arising from the decedent's wrongful death. In determining that punitive damages were not available under such circumstances, the courts cited the Restatement, which provides that "[p]unitive damages are not awarded against the representatives of a deceased tortfeasor nor, ordinarily, in an action under a death statute." Restat. (Second) of Torts § 908 cmt. a (emphasis added). Accordingly, this Banks factor favors the Co-Executors. + +### B. Banks factor two: a majority of U.S. jurisdictions do not permit an award of punitive damages based on the wrongful acts of a decedent. + +This Banks factor overwhelmingly supports the Co-Executors' position. The majority of U.S. jurisdictions do not permit an award of punitive damages against the personal representatives of an estate based on the actions of the deceased tortfeasor. See, e.g., Crabtree v. Estate of Crabtree, 837 N.E.2d 135, 138 (Ind. 2005) ("The majority view denies punitive damages."); 2 Linda L. Schlueter, Punitive Damages § 20.4 (7th ed. 2015) ("[A] majority of jurisdictions will not award punitive damages against a deceased tortfeasor's estate." (citing Alec A. Beech, Adding Insult to Death: Why Punitive Damages Should Not Be Imposed Against a Deceased Tortfeasor's Estate in Ohio, 49 Akron L. Rev. 553 (2016))); Timothy R. Robicheaux and Brian H. Bornstein, Punished, Dead Or Alive: Empirical Perspectives on Awarding Punitive Damages Against Deceased Defendants, 16 Psych. Pub. Pol. and L. 393, 398 (2010) ("The Restatement (Second) of Torts (1965) is one authority stating that punitive damages should not follow the death of a wrongdoer, and the majority of courts considering the issue have provided rulings consistent with this position."). + +### C. Banks factor three: Post-Banks, USVI courts have favorably applied Restatement Section 908 to questions regarding punitive damages. + +The third Banks factor weighs strongly in favor of the Co-Executors as well. Post-Banks, USVI courts have found that Section 908 of the Restatement is "the soundest rule for the Virgin Islands with respect to the imposition of an award of punitive damages." Pappas v. Hotel on the Cay Time-Sharing Ass 'n, 69 V.I. 3, 15 n.8 (U.S.V.I. Super. Ct. 2015) (citing v. Christian, 46 V.I. 557 (D.V.I. App. Div. 2005), Isaac v. Crichlow, 63 V.I. 38, 2015 V.I. LEXIS 15 (V.I. Super. Ct. 2015), St House, Inc. v. Bat-rows, 15 V.I. 435 (V.I. Terr. Ct. 1979), Brandy v. Flamboyant Inv. Co., Ltd., 24 V.I. 249 (V.I. Terr. Ct. 1989), and v. Rios, 780 F. Supp. 2d 376, 380 (D.V.I. 2011)); Powell v. Chi-Co 's Distrib., No. ST-13-TOR-14, 2014 V.I. LEXIS 21, at \*5 n.13 (U.S.V.1. Super. Ct. Apr. 3, 2014) ("Applying a Banks analysis, the Court finds that Restatement (Second) of Torts § 908(2) reflects the common law of this jurisdiction."). There is no reason to think the USVI courts would adhere to one portion of Section 908 and not another. + +Because every Banks factor favors the Co-Executors' position, to the extent USVI law applies to the alleged tortious conduct that occurred there, Plaintiff cannot recover an award of punitive damages against the Co-Executors. Therefore, even if any of Plaintiff's claims survive, regardless of which state's law applies here, the Court must dismiss her claim for punitive damages in its entirety. + +Finally, Plaintiff does not contend that her punitive damages claims are proper. Rather, in her pre-motion response letter, she asks the Court to delay ruling on the issue of punitive damages until after discovery. (ECF No. 13 at 3.) As there are no facts that would render Plaintiff's punitive damages claim proper, there is no reason to allow it to stand. Not surprisingly, courts in this District regularly grant motions to dismiss claims for punitive damages. See, e.g., The Cookware Co. (USA), LLC v. Austin, No. 15 Civ. 5796, 2016 U.S. Dist. LEXIS 177691, at \*17 (S.D.N.Y. Dec. 8, 2016) (Batts, J.) (granting motion to dismiss claim for punitive damages without leave to replead because allegations regarding defendant's bad-faith conduct were conclusory and did not rise to the required level of malice); SIB v. N.Y.C. Dep't of Educ., No. 03 Civ. 6653, 2004 U.S. Dist. LEXIS 13227, at \*25-26 (S.D.N.Y. July 14, 2004) (Buchwald, J.) (granting motion to dismiss punitive damages claims because they were not statutorily available); Kunica v. St Jean Fin., 97 Civ. 3804, 1998 U.S. Dist. LEXIS 11867, at \*26 (S.D.N.Y. July 29, 1998) (Sweet, J.) (granting motion to dismiss claim for punitive damages because, even if conduct alleged in complaint was true, it did not rise to the level necessary to award punitive damages); v. Consumers Distrib. Co., 648 F. Supp. 980, 981, 984 (S.D.N.Y. 1986) (Cedarbaum, J.) (granting motion to dismiss claim for punitive damages). + +Plaintiff merely seeks to delay the inevitable so she may use the prospect of punitive damages—despite the legal prohibition on their availability here—as (misplaced) leverage over the Co-Executors. This would serve no legitimate purpose. It would also impede productive settlement discussions. Like the punitive damages claims in the cases cited above, Plaintiff's punitive damages claim should be dismissed. + +## CONCLUSION + +For the foregoing reasons, the Co-Executors respectfully request that the Court grant their motion to dismiss Plaintiff's Complaint pursuant to Federal Rule of Civil Procedure 12(b)(6) because it is time-barred and Plaintiff's claim for punitive damages because it is prohibited by statute. + +Dated: New York, New York Respectfully submitted, April 14, 2020 + +TROUTMAN SANDERS LLP 875 Third Avenue New York, NY 10022 212.704.6000 + +By✓s/ Bennet J. Moskowitz Bennet J. 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Moskowitz + +bennet.moskowitz@troutman.com + +April 15, 2020 + +Via ECF + +Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007 + +![](_page_0_Picture_3.jpeg) + +Re: Jane Doe 1000, 1:19-cv-10577-LJL-DCF; 1:19-cv-10476-PGG-DCF; 1:19-cv-10479-ALC-DCF + +Dear Judge Freeman: + +We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (to ether. the to -Executors"). in the above-referenced actions commenced by Jane Doe 1000, and (together "Plaintiffs", and with the Co-Executors, the "Parties"). In light of the ongoing pandemic and the various difficulties it has presented for all parties, we write with the consent of Plaintiffs to request that the Court extend the remaining deadlines in the above-referenced actions, as set by this Court's Order dated February 11, 2020, by thirty (30) days, as follows: + +- the deadline for Plaintiffs to file any motions to amend the pleadings or to join any additional parties be extended from April 30, 2020 to June 1, 2020; +- the deadline for the Parties to submit joint status reports to the Court, regarding discovery and the progress of settlement discussions, be extended from April 30, 2020 to June 1, 2020; +- the deadline for the completion of fact discovery be extended from June 10, 2020 to July 10, 2020; +- the deadline for service of Plaintiffs' expert reports be extended from June 10, 2020 to July 10, 2020; +- the deadline for service of the Defendants' rebuttal reports be extended from July 10, 2020 to August 10, 2020; and + +- the deadline for the completion of expert discovery be extended from July 31, 2020 to August 31, 2020. + +This is the first request for an extension of these deadlines. + +Respectfully submitted, + +s/Bennet J Moskowitz + +Bennet J. 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Moskowitz + +bennet.moskowitz@troutman.com + +April 15, 2020 + +Via ECF + +Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007 + +Re: Jane Doe 1000, 1:19-cv-10577-LJL-DCF; 1:19-cv-10476-PGG-DCF; 1:19-cv-10479-ALC-DCF + +Dear Judge Freeman: + +We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (to ether. the to -Executors"), in the above-referenced actions commenced by Jane Doe 1000, and (together "Plaintiffs", and with the Co-Executors, the "Parties"). In light of the ongoing pandemic and the various difficulties it has presented for all parties, we write with the consent of Plaintiffs to request that the Court extend the remaining deadlines in the above-referenced actions, as set by this Court's Order dated February 11, 2020, by thirty (30) days, as follows: + +- the deadline for Plaintiffs to file any motions to amend the pleadings or to join any additional parties be extended from April 30, 2020 to June 1, 2020; +- the deadline for the Parties to submit joint status reports to the Court, regarding discovery and the progress of settlement discussions, be extended from April 30, 2020 to June 1, 2020; +- the deadline for the completion of fact discovery be extended from June 10, 2020 to July 10, 2020; +- the deadline for service of Plaintiffs' expert reports be extended from June 10, 2020 to July 10, 2020; +- the deadline for service of the Defendants' rebuttal reports be extended from July 10, 2020 to August 10, 2020; and + +- the deadline for the completion of expert discovery be extended from July 31, 2020 to August 31, 2020. + +This is the first request for an extension of these deadlines. + +Respectfully submitted, + +s/Bennet J. 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Darren K. Indyke & Richard D. Kahn, 19-10479-ALC-DCF + +May 7, 2020 + +Dear Judge Freeman: + +We write on behalf of Plaintiff in the above-captioned litigation. Pursuant to Individual Rule II.A and Local Civil Rule 37.2, Plaintiff respectfully requests a pre-motion conference on Plaintiff's anticipated motion to compel Defendants Darren K. Indyke and Richard D. Kahn (I) to produce responsive documents from the Relevant Period as defined in Plaintiff's discovery requests; (2) to produce documents responsive to Plaintiff's requests, not simply documents that directly mention Plaintiff's name; and (3) to respond to Plaintiff's interrogatories.' The Court has made clear that discovery in this case would not be stayed pending the approval of the claims administration program or a motion to dismiss absent a contrary order from the Court. See Tr. of Nov. 21, 2019 Conf. at 26:10-12. Yet by failing to comply with their clear and unequivocal discovery obligations, including not producing a single document to date, Defendants are attempting to grant themselves a de facto stay of discovery. Defendants have provided no basis for their delay. + +### I. Background + +Plaintiff alleges that Jeffrey Epstein and his co-conspirators operated a decades-long sex-trafficking scheme by which they recruited young women for sexual abuse. Comp1.11 27, 28. Plaintiff was one of those women. Epstein and his associates trafficked her from South Africa in 2002 and sexually abused her for several years thereafter in New York, Florida, the U.S. Virgin Islands, New Mexico, and France. Id. 11 41, 55. After years of suffering in silence due to fear and Epstein's psychological manipulation, she filed a complaint against Defendants on November 14, 2019. + +On January 23, 2020, the parties exchanged initial Rule 26 disclosures. Defendants' Rule 26 Disclosures were vacuous. Defendants provided the names of two witnesses—Plaintiff and her ex-boyfriend—and stated that they were not aware of any documents, ESI, or tangible things in + +Pursuant to Individual Rule I.C., Plaintiff states that she conferred in good faith with Defendants about the issues raised in this letter by telephone on April 27, 2020. + +their possession, custody, or control that they would use to support their defenses. Exhibit A, Jan. 23, 2020 Initial Disclosures of Defendants Darren K. Indyke and Richard D. Kahn. In response to Defendants' lack of information as to what relevant documents were in their possession, custody, or control, on January 28, 2020, Plaintiff sent them a document preservation notice and identified various email accounts used by Jeffrey Epstein. Exhibit B. Jan. 28, 2020 Document Preservation Notice. Defendants responded on February 3, 2020, by stating that they were abiding by all of their discovery obligations, including their preservation obligations. Exhibit C, Feb. 3, 2020 Letter from B. Moskowitz to S. McCawley. + +On March 10, 2020, Plaintiff served 91 Requests for Production ("RFPs") and 17 Interrogatories on Defendants (collectively, Plaintiff's "discovery requests"). In Plaintiff's interrogatories, she again asked Defendants to identify potential witnesses, in addition to email accounts used by Epstein, telephone numbers used by Epstein, and other information to aid Plaintiff in identifying witnesses and the location of evidence necessary to prove her case. On April 16, 2020, after Plaintiff provided Defendants a week-long extension, Defendants served responses and objections in which they failed to respond to a single Interrogatory (aside from identifying Plaintiff as a witness to her own abuse) and failed to produce a single document. Exhibit D, Defendants' Apr. 16, 2020 Objections and Responses to Plaintiff's First Set of Interrogatories; Exhibit E, Defendants' Apr. 16, 2020 Objections and Responses to Plaintiff's First Request for Production of Documents. + +On April 27, 2020, after sending Defendants a letter regarding the clear deficiencies in their responses and objections, Plaintiff met and conferred with Defendants for an hour and a half. See Ex. F, Apr. 20, 2020 Letter from S. McCawley to B. Moskowitz. Defendants stated that they had not yet fully processed the ESI in their possession, had not run any searches on the ESI, and were not in a position to provide information about the ESI, despite having received Plaintiff's document retention notice in January and Plaintiff's discovery requests in March. During the meet and confer, Plaintiff also explained her position on the relevance and necessity of each of her discovery requests, and offered to answer any questions that Defendants had about the relevance of any of her requests. Defendants refused to accept the Relevant Period that Plaintiff defined in her discovery requests, and stated that they would only produce documents that reference Plaintiff. They also stated, without providing any legal basis for their position, that they would not produce anything relating to Epstein's sex trafficking or abuse of other victims. + +As of today, May 7, 2020, Plaintiff has yet to receive a single document or piece of information responsive to any of her discovery requests, including the documents that specifically reference Plaintiff that Defendants agreed to produce. The only information Defendants have provided to Plaintiff in the course of discovery is their statement that Plaintiff is a witness in this case. Plaintiff has produced more than 10,000 pages of documents responsive to Defendants' discovery requests to date, and has responded to all of Defendants' interrogatories to the best of her ability. + +# II. Defendants' Objection to the Relevant Period is Improver. + +Defendants have improperly objected to the Relevant Period that Plaintiff defined in her discovery requests as January 1, 2001 to the present. Without providing any legal basis for their + +position, Defendants contend that the relevant time period should be limited to the dates of Plaintiff's abuse as alleged in the Complaint.2 + +Under Rule 26 of the Federal Rules of Civil Procedure, parties may obtain discovery "regarding any nonprivileged matter that is relevant to any party's claim or defense." Fed. R. Civ. P. 26(b)(1). "[R]elevance for the purposes of discovery is an extremely broad concept." Melendez v. Greiner, No. 01 CIV.07888 SAS DF, 2003 WL 22434101, at \*1 (S.D.N.Y. Oct. 23, 2003) (Freeman, J.). + +This case turns on (1) whether Jeffrey Epstein sexually trafficked and sexually assaulted Plaintiff and (2) whether Plaintiff's claims are timely, an affirmative defense that Defendants have already raised in a motion to dismiss. ECF No. 24. Discovery from the Relevant Period as defined by Plaintiff is relevant to both Plaintiff's claims and Defendants' statute of limitations defense, and is reasonably calculated to lead to the discovery of admissible evidence. + +Epstein's sexual trafficking and abuse of Plaintiff began in 2002 and lasted through approximately 2004. But Plaintiff has reason to believe, based on publicly available documents, that Epstein and his co-conspirators began trafficking and sexually abusing young girls and women in the same manner that he trafficked and abused Plaintiff in the mid-1990s, and continued to do so up until the date of Epstein's arrest on July 8, 2019. Documents relating to the sexual trafficking and/or sexual assault of others at any point during that period would make the fact that Epstein trafficked and sexually assaulted Plaintiff, the key fact that Plaintiff bears the burden of proving in this case, more probable than it would be without such evidence. See Fed. R. Evid. 401. Plaintiff also bears the burden of proving Epstein's intent to sexually assault her. See Cerilli v. Kezis, 16 A.D.3d 363, 364 (2d Dep't 2005) ("The elements of battery are bodily contact, made with intent, and offensive in nature."). Evidence that he sexually trafficked and assaulted others would be directly relevant to proving such intent. Such evidence would also likely be admissible at trial. See Fed. R. Evid. 415. + +Further, Defendants have raised a statute of limitations defense in this matter, ECF No. 24, and Plaintiff contends that they should be equitably estopped from doing so based on Epstein's misconduct. Compl. 1 15. Although Plaintiff disagrees with Defendants' interpretation of the case law, Defendants contend that to invoke equitable estoppel, Plaintiff bears the burden of proving that Epstein's "conduct caused her to delay bringing suit," that Epstein "made a definite misrepresentation of fact and had reason to believe that the plaintiff would rely on it," and that "plaintiff reasonably relied on that misrepresentation." ECF No. 24 at 13. Documents relating to Epstein's misconduct after his abuse of Plaintiff ended could very well be relevant to equitable estoppel, including to whether Plaintiff reasonably relied on that misconduct in staying silent about her abuse until after Epstein's death. + +The fact that Epstein and his co-conspirators carried out a sex-trafficking operation, which directly injured Plaintiff, for 20 years does not mean that Plaintiff is not entitled to discovery about that operation. Yet Defendants have taken that position and have not indicated any willingness to change it. The Court should direct Defendants to search documents within their possession, + +2This is despite the fact that Defendants themselves served discovery requests on Plaintiff in which they defined the relevant time period as "the date on which you first learned of Decedent through the date of your responses to these requests." + +custody, or control from the Relevant Period as described in Plaintiff's discovery requests-2001 to the present. + +#### III. Defendants Must Produce More than Documents That Explicitly Reference Plaintiff. + +In addition to their blanket objection to the production of documents from any year during which Plaintiff was not herself sexually assaulted, Defendants contend that they will only produce one category of documents—those that specifically mention . Defendants have refused, without providing any legal basis for doing so, to produce any document that does not directly reference Plaintiff, regardless of the year. + +Defendant cannot broadly object to producing any documents that do not directly reference Plaintiff. Documents relevant to Plaintiff's claims and Defendants' defenses go well beyond documents that reference Plaintiff. The following is a small sampling of examples of relevant documents that would not necessarily mention Plaintiff: + +- As explained above, documents evidencing Epstein's trafficking and sexual assaults of others, although not about Plaintiff herself, are directly relevant to whether he trafficked and sexually assaulted Plaintiff. +- Epstein's communications with his co-conspirators are likely to evidence the scheme by which Epstein recruited and abused Plaintiff, even if they do not specifically mention Plaintiff. For example, documents in which Epstein and his co-conspirators discuss recruiting young models or arranging for the travel of foreign girls for sexual abuse would corroborate Plaintiff's allegations. +- Documents relating to payments from Epstein to his employees are relevant to whether Epstein paid his employees to keep them quiet, and would be relevant in impeaching witnesses in this case. +- Documents relating to Epstein's silencing, intimidation, and manipulation of victims other than Plaintiff is relevant to establishing whether Plaintiff reasonably feared Epstein, which is relevant to Defendants' statute of limitations defense and Plaintiff's equitable estoppel theory. +- Documents relating to Epstein's recruitment of Plaintiff while on the following trip to South Africa, including details about travel plans and itineraries, would not mention Plaintiff's name but are nevertheless highly relevant to what transpired: + +| 21 | B-727-311 | N9098JC | JFK | LPAZ | 136 | PRESIDENT WELLESM S. ECKP DID, NAB
KENN SPALEY, CHRIS TUCKER, JE GM, | +|----|-----------|---------|------|------|-----|------------------------------------------------------------------------------| +| 22 | " | " | LPAZ | DGAP | 137 | SK, CL CHANTAK DAVIS, AMANDA MEROVER
DOUG ANNA, ANNIE SLAIG, JEM KENNERY, | +| 23 | " | " | DGAP | DNAP | 138 | ERIC NOWES, RONAVEL CARLE, CHERY FLANK
WASSERMAN, ROB BURKLE (GARY SMITH) | +| 24 | " | " | DNAP | HRYR | 139 | SAME AS ABOVE LESS RON JORKLE | +| 25 | " | " | HRYR | FOMA | 140 | SAME AS ABOVE PLUS ERIA ANAGAZINKE | +| 26 | " | " | FOMA | FACT | 141 | SAME AS ABOVE | +| 27 | " | " | FACT | FAJS | 142 | SAME AS ABOVE LESS JC, CM, SL, CL
CHANTAK DAVIS, ANDREA MITROVICH | +| 28 | " | " | FAJS | FACT | 143 | SAME AS ABOVE LESS GARY SMITH,
SRA MASH ZEMOL | +| 29 | " | " | FACT | DGAP | 144 | SAME AS ABOVE ADIN, SG, CM, SL, CL
CD, AM | +| 29 | " | " | DGAP | LFPB | 145 | SAME AS ABOVE | + +Plaintiff explained these theories of relevance during a meet and confer call with Defendants. Without any legal basis, and while purporting to understand Plaintiff's position, Defendants consistently maintained that they would not produce *any document* that does not directly mention [REDACTED]. This position unwarranted, legally baseless, and unacceptable, and Defendants have not indicated that they are willing to change it. The Court should direct Defendants to search for documents within their possession, custody, or control and not allow Defendants to unilaterally and arbitrarily limit their search to documents that reference Plaintiff's name. + +**IV. Defendants Must Respond to Plaintiff's Interrogatories.** + +Plaintiff served 17 interrogatories on Defendants, and Defendants failed to answer a single one, aside from listing Plaintiff as an "individual who may have knowledge concerning the issues in this lawsuit." Ex. D at 3. Plaintiff asked Defendants to identify email accounts used by Epstein or his employees or agents on his behalf—Defendants provided no answer. *Id.* Plaintiff asked Defendants to identify telephone numbers used by Epstein or his employees or agents on his behalf—Defendants provided no answer. *Id.* at 4. Plaintiff asked Defendants to provide a list of Epstein's employees in an effort to identify potential witnesses to Epstein's abuse of Plaintiff and other victims—Defendants provided no answer. *Id.* This is despite the fact that Defendant Kahn is Epstein's longtime accountant and likely knows who was on Epstein's payroll. This total failure to answer even basic questions about the location of documents and potential witnesses is egregious. + +When asked about their failure to respond to any interrogatories, in addition to raising their meritless objections to the Relevant Period and to producing information that does not relate directly to Plaintiff, Defendants stated that they do not have responsive information because Epstein is dead and Defendants do not know where to look for responsive information. Defendants also drew a distinction between their capacities as Epstein's lawyer and accountant, as opposed to their capacities as executors of his Estate, but could not give Plaintiff a clear answer as to their position on how that distinction affects their discovery obligations. For example, Defendants' counsel could not tell Plaintiff whether Darren Indyke—Epstein's longtime lawyer who has ties to + +Epstein's co-conspirators3—or Richard Kahn—Epstein's longtime accountant who assisted him for years with both personal and professional accounting work—had ever been directly asked whether they know of any individuals who might have information about Plaintiff's claims. + +Plaintiff still has no understanding of how Defendants have attempted to fulfill their discovery obligations, or of what documents or information are within their possession, custody, or control. At this stage in the litigation, such opaqueness is unacceptable and a clear attempt by Defendants to avoid their discovery obligations in the hopes that the claims administration process comes to fruition. But Defendants cannot unilaterally decide to stay this case. The Court should direct Defendants to respond to Plaintiff's interrogatories. + +Respectfully submitted, + +/s/ Sigrid S. McCawley + +Sigrid S. McCawley, Esq. + +cc: Counsel of Record (via ECF) + +3According to public records, Indyke, for example, helped Ghislaine Maxwell buy her townhouse, was listed on documents relating to one of Maxwell's nonprofits, held a power of attorney over one of Leslie Wexner's properties, and employed Lesley Groff as an executive assistant for his law practice. See Julia La Roche et al., Jeffrey Epstein's Lawyers Deeply Involved in His Business Dealings for Decades, Documents Show, Yahoo Finance (Aug. 13, 2019), https://finance.yahoo.cominews/jeffrey-epstein-lawyers-darren-indyke-jeffrey-schantz-164305188.html. + +# Exhibit A + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +X Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, Defendants. X + +Index No. 1:19-cv-10479-ALC-DCF + +#### INITIAL DISCLOSURES OF DEFENDANTS DARREN K. INDYKE AND RICHARD D. KAHN, CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN + +Pursuant to Fed. R. Civ. P. 26(aX1), Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"), make the following initial disclosures to Plaintiff These disclosures are based on the information reasonably available to the Co-Executors at present. The Co-Executors reserve the right to supplement or modify these disclosures if additional, responsive information is obtained. + +The Co-Executors provide this information without any concession, agreement, admission or waiver of any ultimate determination of relevance or admissibility of particular information or testimony for any purpose. The Co-Executors reserve the right to, at trial, call any witness and present any exhibit or other evidence not listed here but identified through discovery or investigation during this action. The Co-Executors do not waive their rights to object to the production of any document or tangible thing based on the attorney-client privilege, the work-product doctrine, relevance, undue burden or any other valid objection. + +#### INITIAL DISCLOSURES + +#### Rule 26(a)(1)(A) + +- i. the name, and if known, the address and telephone number of each individual likely to have discoverable information — along with the subjects of that information that the disclosing party may use to support its claims or defenses, unless the use would be solely for impeachment; + +#### Response: + +- I. Plaintiff. Plaintiff is likely to have discoverable information concerning Jeffrey E. Epstein's alleged conduct and Plaintiff's claimed damages, which the Co-Executors may use to support their defenses. +- 2. Sven Stromnes. Mr. Stromnes is likely to have discoverable information concerning Jeffrey E. Epstein's alleged conduct and Plaintiffs claimed damages, which the Co-Executors may use to support their defenses. Upon information and belief, Mr. Stromnes is located in South Africa. +- ii. a copy or a description by category and location of all documents, electronically stored information, and tangible things that the disclosing party has in its possession, custody, or control and may use to support its claims or defenses, unless the use would be solely for impeachment; + +Response: At present, the Co-Executors are not aware of any such documents, electronically stored information, and tangible things. + +- iii. a computation of each category of damages claimed by the disclosing party who must also make available for inspection and copying as under Rule 34 the documents or other evidentiary material, unless privileged or protected from disclosure, on which each computation is based, including materials bearing on the nature and extent of injuries suffered; and + +Response: The Co-Executors do not claim damages. + +- iv. for inspection and copying as under Rule 34, any insurance agreement under which an insurance business may be liable to satisfy all or part of a possible judgment in the action or to indemnify or reimburse for payments made to satisfy the judgment. + +Response: At present, the Co-Executors are unaware of any such insurance agreement. + +Dated: New York, New York Respectfully submitted, January 23, 2020 + +TROUTMAN SANDERS LLP 875 Third Avenue New York, New York 10022 + +By: Is/Bennet J. Moskowitz Bennet J. Moskowitz + +Attorneys for Defendants Darren K Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein + +#### CERTIFICATE OF SERVICE + +The undersigned certifies that on January 23, 2020, I served a copy of the foregoing Initial Disclosures of Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, made pursuant to Fed. R. Civ. P. 26(a)(1), by sending them by email to: + +Sigrid McCawley Boles, Schiller & Flexner LLP 401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL, 33301 (954)-377-4223 Email: smccawley®bsfllp.com + +s/Bennet J Moskowitz + +# Exhibit B + +January 28, 2020 + +# VIA ELECTRONIC MAIL + +Bennet J. Moskowitz 875 Third Avenue New York, New York 10022 + +Re: Document Preservation Notice + +v. Darren K. Indyke and Richard D. Kahn, 19-10474; Annie Farmer v. Darren K. Indyke, Richard D. Kahn, and Ghislaine Manvell, 19-10475; + +v. Darren K. Indyke and Richard D. Kahn, 19-10476; v. Darren K. Indyke and Richard D. Kahn, 19-10479; Jane Doe 1000 v. Darren K. Indyke and Richard D. Kahn, 19-10577; + +Dear Mr. Moskowitz: + +This is a document preservation notice issued in connection with the above-captioned civil actions. Please read this notice carefully and take all steps necessary to preserve all documents that might be relevant to this dispute. You should take affirmative steps to suspend any automated deletion. The documents covered by this notice are potentially subject to discovery and production in the above-captioned litigation and will be needed as evidence and/or to enable us to prepare fully to take your clients' sworn testimony in a deposition and/or at a trial + +Pursuant to Federal Rule of Civil Procedure 26, you were required to identify "all documents, electronically stored information, and tangible things that the disclosing party has in its possession, custod or control and ma use to support its claims or defenses." In your Initial Disclosures for , and , however, you stated that "[a]t present, the Co-Executors are not aware of any such documents, electronically stored information, and tangible things." I assume that you mean that you are not aware that any "documents, electronically stored information, [or] tangible things" that would be supportive of your clients' defenses. If instead you are taking the position that your clients do not have possession, custody, or control over Mr. Epstein's documents (including his electronically stored information), please state so in your reply so that we may bring that to the Court's attention immediately. + +At the November 21, 2019, conference Judge Freeman stated: "Counsel should know what their obligations are and those obligations are pretty clear under the law and counsel should take them seriously. If you do not preserve evidence that should be preserved that you had a reason to believe was relevant to claims or defense in the case and that you didn't take steps to preserve, there can be negative consequences down the road." Nov. 21, 2019, Hearing Tr. at 33:4-10. The Court instructed that your preservation efforts should be "broad enough" to documents located at Mr. Epstein's "multiple residences in multiple countries across the world." + +Bennet J. Moskowitz + +January 28, 2020 + +Page 12 + +Effective immediately, you should ensure that your clients preserve all documents, whether they exist electronically or in paper files. This includes documents that presently exist, or that are created in the future, in your clients' possession, custody or control, including in common files maintained for your clients. + +#### Subject Matter + +Preserve all documents that refer to, relate to, mention, or discuss the allegations in Plaintiffs' complaints, including but not limited to any concerning the following subjects and found in the following repositories: + +- 1. The allegations in the Complaints filed in the above referenced matters; +- 2. The Plaintiffs; +- 3. Mr. Epstein's sex-trafficking conspiracy; +- 4. Visitors and/or passengers at any of Mr. Epstein's multiple residences or aircraft where the sex trafficking occurred; +- 5. Communications between Mr. Epstein and his co-conspirators; +- 6. Communications between Mr. Epstein and his employees; +- 7. Communications between Mr. Epstein and any government official regardless of country; +- 8. Mr. Epstein's flight logs and helicopter logs; +- 9. Video tapes and photographs taken at Mr. Epstein's properties or on his planes; +- 10. Financial records; +- 11. Mr. Epstein's message pads and any phone call logs or phone/contact directories; +- P. Amazon.com account details, including order history; +- 13. Electronic files Mark Lumberg managed on behalf of Mr. Epstein; +- 14. Mr. Epstein's email accounts, including but not limited to: + - a. "jeffreye@mindspring.com"; + - b. leeproject®yahoo.com"; + - c. "jeevacation@gmail.com"; + - d. "zorroninch@aol.com"; and + - e. "epsteinj@wanadoo.fr"; +- 15. Email accounts under the following domains: ®Mindspring.com; ®earthlin1c.net; including those used by: + - a. Ghislaine Maxwell; + - b. + - c. + +Bennet J. Moskowitz + +January 28, 2020 + +Page 13 + +- 16. Email accounts for " that Mr. Epstein controlled, including "cecilia@ellmax.com" and' + +Please construe this notice as broadly as possible and carefully read the following descriptions. + +The definition of "document" is not limited to paper files. A document is literally any kind of record, whether stored electronically or in paper form, whether useful to you or not. See S.D.N.Y. Local Civil Rule 26.3 ("Uniform Definitions in Discovery Requests"). A document is any object in your possession that relates to the subject matter identified in this notice, including: + +- Email. All of your clients' emails relating to the subject matter, both internal and external, whether in electronic or paper form; this includes anything created or stored on a wireless device or smart phone. +- Computer Files. All other electronic records relating to the subject matter, including but not limited to documents created using Microsoft Office (Word, PowerPoint, Excel, Access, and Visio, for example), and stored anywhere; this includes files stored on your clients' computers, in shared or network drives, home computers, hard disks, CDs, DVDs, flash drives, or anywhere else. +- Video and Audio. Microfilm, audio and video or other visual records, including voice mail, video tapes, DVDs, digital photographs, etc. +- Paper Documents. All paper records—presentations, notes, calendars, day planners, logs, lists, agendas, correspondence, photographs, facsimiles, data or other computer printouts and the like. +- Text Messages. All text or SMS messages, messages sent via WhatsApp or other messaging services. + +Please ensure that any of your clients' agents, such as administrative assistants, who may have access to or know of records covered by this notice, are also made aware of the obligation to preserve such material. Please confirm in writing by February 3. 2020, that your clients have preserved and will continue to preserve all documents and communications described above, and all other materials relevant or potentially relevant to the subject matter of the cases. + +Sincerely, + +/s/ Sigrid S. McCawley Sigrid S. McCawley, Esq. + +# Exhibit C + +Troutman Sanders LLP 875 Third Avenue New York, New York 10022 + +troutman.com + +Bennet J. Moskowitz + +bennetmoskowitz©troutman.com + +February 3, 2020 + +E-MAIL + +Sigrid S. McCawley, Esq. Boies Schiller Flexner LLP 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301 + +![](_page_16_Picture_3.jpeg) + +Re: -10476; 19-cv-10479; 19-cv-10475; , 19-cv-10474; Jane Doe 1000, 19-cv-10577 + +Dear Ms. McCawley: + +As you know, we represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"), in the above-referenced actions (the "Actions"). We are writing in response to your letter dated January 28, 2020. + +You state: "If ... you are taking the position that your clients do not have possession, custody, or control over Mr. Epstein's documents (including his electronically stored information), please state so in your reply so that we may bring that to the Court's attention immediately." We have never taken that position. Accordingly, there is nothing to raise with the Court. + +Separately, we confirm that our clients are abiding by all of their discovery obligations including preservation obligations. However, your list of subject matters is inappropriate because it is argumentative, assumes many unproven facts not in evidence and is overly broad.' Your interpretation of Local Rule 26.3 is likewise inappropriate; we defer to the rule itself. + +Very truly yours, + +Bennet J. Moskowitz + +Bennet J. Moskowitz + +&#x27;It bears mentioning that counsel in another action against the Co-Executors previously attempted to extract positions from us concerning a similar list and, failing that, to obtain relief from Magistrate Freeman. Such counsel obtained no such relief. Nor was any relief necessary given our identical representation in that action that our clients are abiding by their preservation obligations. + +# Exhibit D + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, Defendants. + +Case No. 1:19-cv-10479-ALC-DCF + +#### DEFENDANTS' OBJECTIONS AND RESPONSES TO PLAINTIFF FIRST SET OF INTERROGATORIES TO DEFENDANTS + +Defendants Darren K. Indyke and Richard D. Kahn, as co-executors of the estate of Jeffrey E. Epstein (the "Co-Executors"), by their attorneys, pursuant to Federal Rules of Civil Procedure 26 and 33, provide the following responses to Plaintiff ("Plaintiff') First Set of Interrogatories to Defendants (the "Interrogatories"). + +#### RESERVATION OF RIGHTS + +These responses are made solely for the purpose of and in relation to discovery in the above-captioned action. The Co-Executors submit these responses subject to, and without intending to waive, and expressly preserving: (i) any objections as to relevancy, materiality, competency, privilege and admissibility of any documents and information produced in discovery, including without limitation herein; and (ii) the right to object to any other discovery requests. The Co-Executors reserve their right to amend these responses if and when appropriate. Further, these responses are neither an admission nor acceptance of any alleged facts, including without limitation those stated in the Interrogatories. + +#### SPECIFIC OBJECTIONS TO DEFINITIONS + +The Co-Executors object to Plaintiff's definition of the term "Jeffrey Epstein" or "Epstein" on the grounds that, insofar as it includes "any entities owned or controlled by Jeffrey Epstein, any employee, agent, attorney, consultant, or representative of Jeffrey Epstein," it is overbroad, unduly burdensome, vague and ambiguous. The Co-Executors will interpret "Jeffrey Epstein" or "Epstein" as Jeffrey E. Epstein. + +The Co-Executors also object to Plaintiffs definition of the term "Ghislaine Maxwell" or "Maxwell" on the grounds that, insofar as it includes "any entities owned or controlled by Ghislaine Maxwell, any employee, agent, attorney, consultant, or representative of Ghislaine Maxwell," it is overbroad, unduly burdensome, vague and ambiguous. The Co-Executors will interpret "Ghislaine Maxwell" or "Maxwell" as Ghislaine Maxwell. + +The Co-Executors also object to Plaintiffs definition of the term "Massage" on the grounds that it is more expansive than the common use of the term and is inconsistent with the term's usage in the Complaint. + +# SPECIFIC OBJECTIONS TO INSTRUCTIONS + +The Co-Executors object to the time period stated in the Instructions, which is inconsistent with the time frame alleged in the Complaint. Unless otherwise indicated, the Co-Executors will confine their searches to the time periods at issue in Plaintiff's Complaint. + +# SPECIFIC OBJECTIONS AND RESPONSES TO INTERROGATORIES + +# INTERROGATORY NO. 1 + +List the names and addresses of all persons who arc believed or known by You, Your agents, or Your attorneys to have any knowledge concerning any of the issues in this lawsuit, and specify the subject matter about which the witness has knowledge. + +#### RESPONSE: + +The Co-Executors object to Interrogatory No. 1 on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors also object to Interrogatory No. I on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. Subject to and without waiving the foregoing objection, the Co-Executors identify the following individual who may have knowledge concerning the issues in this lawsuit: Plaintiff. The Co-Executors will supplement this response if any additional responsive information is ascertained. + +# INTERROGATORY NO. 2 + +Identify all email accounts used by Epstein or any of his employees or agents on his behalf. + +#### RESPONSE: + +The Co-Executors object to Interrogatory No. 2 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors further object to this Interrogatory on the grounds it seeks "discovery about discovery," which would result in unnecessary expense. Such matters are more appropriately and cost-effectively addressed in the context of the parties' discussions regarding document discovery. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls for the production of information outside their possession, custody, and control, and is unconstrained by time. + +# INTERROGATORY NO. 3 + +Identify all telephone numbers used by Epstein or any of his employees or agents acting on his behalf, including beepers, Blackberry or PDA devices, cellular phones and land lines in any of his residences, by stating the users name, complete telephone number(s), type of device and name of the service provider. + +# RESPONSE: + +The Co-Executors object to Interrogatory No. 3 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also vague, overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it calls for the production of information outside their possession, custody, and control, and is unconstrained by time. The Co-Executors further object to this Interrogatory on the grounds it seeks "discovery about discovery," which would result in unnecessary expense. Such matters are more appropriately and cost-effectively addressed in the context of the parties' discussions regarding document discovery. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. + +### INTERROGATORY NO. 4 + +Identify all employees, including each employee's position and dates and locations of employment, who performed work or services in or on any property owned, leased, occupied, or used by Epstein, including but not limited Epstein's homes in Palm Beach, Florida, New York City, the U.S. Virgin Islands, New Mexico, London and Paris, and provide the name and contact information of the individual who hired, trained and supervised each employee. + +#### RESPONSE: + +The Co-Executors object to Interrogatory No. 4 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the grounds that it assumes facts not in evidence and that the phrase "performed work or services in or on any property" is vague and ambiguous. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls for the production of information outside their possession, custody, and control, and is unconstrained by time. + +# INTERROGATORY NO. 5 + +Identify all employees, including each employee's position and dates and locations of employment, who performed work as an assistant, scheduler, secretary, masseuse or traveling masseuse for Epstein and provide the name and contact information of the individual who hired, trained and supervised each employee. + +# RESPONSE: + +The Co-Executors object to Interrogatory No. 5 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the grounds that the terms "scheduler" and "traveling masseuse" are vague and ambiguous. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls for the production of information outside their possession, custody, and control, and is unconstrained by time. + +#### INTERROGATORY NO. 6 + +Identify all companies and/or persons who provided transportation services to Epstein, whether as an employee or independent contractor, including without limitation drivers, chauffeurs, boat captains, pilots, and aircraft crew, and provide the contact information for each listed person or company. + +# RESPONSE: + +The Co-Executors object to Interrogatory No. 6 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors also object to this Interrogatory on the grounds that the phrase "transportation services" is vague and ambiguous. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls for the production of information outside their possession, custody, and control, and is unconstrained by time. + +# INTERROGATORY NO. 7 + +Identify all females by name and age for whom Epstein or his employees or agents provided accommodations at 301 East 66th Street, New York, New York for any period of time. + +# RESPONSE: + +The Co-Executors object to Interrogatory No. 7 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts not in evidence and on the grounds that the phrase "provided accommodations" is vague and ambiguous. The Co-Executors additionally object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls for the production of information outside their possession, custody, and control, and is unconstrained by time. + +#### INTERROGATORY NO. 8 + +Identify by name and age all persons who gave a massage or were asked to give a massage to Epstein, Maxwell or a guest, or to whom Epstein or Maxwell gave a massage, at any of Epstein's residences and provide the location of each massage. + +### RESPONSE: + +The Co-Executors object to Interrogatory No. 8 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls for the production of information outside their possession, custody, and control, and is unconstrained by time. + +#### INTERROGATORY NO. 9 + +Identify all dates when Andrew Albert Christian Edward, of York (a/k/a Prince Andrew) was present in any of Epstein's residences from 1995 to the present, and provide the location and purpose of each visit. + +#### RESPONSE: + +The Co-Executors object to Interrogatory No. 9 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to the time period stated in this Interrogatory, which is inconsistent with the time frame alleged in the Complaint. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls for the production of information outside their possession, custody, and control. + +# INTERROGATORY NO. 10 + +Identify all dates when Alan Dershowitz was present in any of Epstein's residences from 1995 to the present, and provide the location and purpose of each visit. + +# RESPONSE: + +The Co-Executors object to Interrogatory No. 10 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors additionally object to the time period stated in this Interrogatory, which is inconsistent with the time frame alleged in the Complaint. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls for the production of information outside their possession, custody, and control. + +#### INTERROGATORY NO. 11 + +Identify all dates when William "Bill" J. Clinton was present in any of Epstein's residences, on any of Epstein's helicopters or planes, at any of Epstein's offices, or at any event hosted or affiliated with Epstein from 1995 to the present, and provide the location and purpose of each encounter. + +# RESPONSE: + +The Co-Executors object to Interrogatory No. II on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the grounds that the phrase "any event hosted or affiliated with Epstein" is vague and ambiguous. The Co-Executors additionally object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to the time period stated in this Interrogatory, which is inconsistent with the time frame alleged in the Complaint. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls for the production of information outside their possession, custody, and control. + +# INTERROGATORY NO. 12 + +Identify any telecommunications, information technology, or audio-visual technology company that Epstein hired for work in any of his residences or offices and provide the name and contact information for each individual or company listed, in addition to the residence or office serviced. + +#### RESPONSE: + +The Co-Executors object to Interrogatory No. 12 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the grounds that the phrase "hired for work" is vague and ambiguous. The Co-Executors additionally object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls for the production of information outside their possession, custody, and control, and is unconstrained by time. + +# INTERROGATORY NO. 13 + +Identify the method or means in which Maxwell was paid by Epstein or any affiliated entities from 1995 to the present. + +#### RESPONSE: + +The Co-Executors object to Interrogatory No. 13 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the grounds that the phrases "method or means in which Maxwell was paid" and "affiliated entities" are vague and ambiguous. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors additionally object to the time period stated in this Interrogatory, which is inconsistent with the time frame alleged in the Complaint. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls for the production of information outside their possession, custody, and control. + +#### INTERROGATORY NO. 14 + +Provide detailed quantification for all compensation Maxwell received for any services she performed for the benefit of Epstein or any of his affiliated entities, broken down by year from 1995 to the present. + +# RESPONSE: + +The Co-Executors object to Interrogatory No. 14 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the grounds that the phrase "services she performed for the benefit of Epstein or any of his affiliated entities" is vague and ambiguous. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors additionally object to the time period stated in this Interrogatory, which is inconsistent with the time frame alleged in the Complaint. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls for the production of information outside their possession, custody, and control. + +#### INTERROGATORY NO. 15 + +Identify any loans or lines of credit issued to Maxwell from Epstein or any affiliated entities from 1995 to the present, including the amount of the loans, the term of the loans, the interest rate of the loans, and any payments made by Maxwell or on Maxwell's behalf to repay such loans. + +#### RESPONSE: + +The Co-Executors object to Interrogatory No. 15 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the grounds that the terms "lines of credit" and "any affiliated entitites" are vague and ambiguous. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors additionally object to the time period stated in this Interrogatory, which is inconsistent with the time frame alleged in the Complaint. + +# INTERROGATORY NO. 16 + +Identify the dates, recipients, and purpose of the "two . payments, one in the amount of \$250,000 and another in the amount of \$100,000 to . . . two employees or associates of Mr. Epstein's" referenced by Assistant United States Attorney Alexander Rossmiller at Epstein's bail hearing on July 15, 2019. See Transcript of July 15, 2019 Bail Hearing at 9:15-20, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). + +#### RESPONSE: + +The Co-Executors object to Interrogatory No. 16 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case. The Co-Executors also object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. + +#### INTERROGATORY NO. 17 + +Identify all persons who have made a claim, complaint, demand or threat against Epstein relating to alleged sexual abuse or misconduct on a female, and for each provide the following information: + +- a. The person's full name, last known address and telephone number; +- b. The person's attorney, if represented +- c. The date of the alleged incident(s); and +- d. If a civil case has been filed by or on behalf of the person, the case number and identifying information. + +# RESPONSE: + +The Co-Executors object to Interrogatory No. 17 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls for the production of information protected by the attorneyclient privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors object to this Interrogatory on the grounds that it seeks publicly available information and information already known to Plaintiff or her counsel. The Co-Executors also object to this Interrogatory on the grounds that the terms "claim, complaint, demand or threat" and "misconduct" are overly broad, vague and ambiguous. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls for the production of information outside their possession, custody, and control. + +Dated: New York, New York + +April 16, 2020 TROUTMAN SANDERS LLP + +By: /s/Bennet Moskowitz + +Bennet Moskowitz + +875 Third Avenue + +New York, New York 10022 + +Tel: (212) 704- 6087 + +bennet.moskowitz@troutman.com + +Attorney for Darren K. Indyke and Richard D. Kahn. as co-executors of the estate ofJeffrey E. Epstein + +#### CERTIFICATE OF SERVICE + +The undersigned certifies that on April 16, 2020, 1 served a copy of the foregoing Defendants' Objections and Responses to Plaint First Set of Interrogatories to Defendants, by sending them by email to: + +Sigrid McCawley Boies, Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Fort Lauderdale, FL, 33301 Email: smccawley@bsflIp.com + +TROUTMAN SANDERS LLP + +By: /sr Mary W. Metcalfe 875 Third Avenue New York, New York 10022 Tel: (212) 704-6029 marygrace.metcalfe@troutman.com + +> Attorney for Darren K. Indyke and Richard D. Kahn, as co-executors of the estate of Jeffrey E. Epstein + +# Exhibit E + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, Defendants. + +Case No. 1:19-cv-10479-ALC-DCF + +#### DEFENDANTS' OBJECTIONS AND RESPONSES TO PLAINTIFF FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS + +Defendants Darren K. Indyke and Richard D. Kahn, as co-executors of the estate ofJeffrey E. Epstein (the "Co-Executors"), by their attorneys, pursuant to Federal Rules of Civil Procedure 26 and 34, provide the following responses to Plaintiff ("Plaintiff") First Request for Production of Documents (the "Requests"). + +#### RESERVATION OF RIGHTS + +These responses arc made solely for the purpose of and in 'elation to discovery in the above-captioned action. The Co-Executors submit these responses subject to, and without intending to waive, and expressly preserving: (i) any objections as to relevancy, materiality, competency, privilege and admissibility of any documents and information produced in discovery, including without limitation herein; and (ii) the right to object to any other discovery requests. The Co-Executors reserve their right to amend these responses if and when appropriate. Further, these responses are neither an admission nor acceptance of any alleged facts, including without limitation those stated in the Requests. + +### SPECIFIC OBJECTIONS TO DEFINITIONS + +The Co-Executors object to Plaintiff's definition of the term "Jeffrey Epstein" or "Epstein" on the grounds that, insofar as it includes "any entities owned or controlled by Jeffrey Epstein, any employee, agent, attorney, consultant, or representative of Jeffrey Epstein," it is overbroad, unduly burdensome, vague and ambiguous. The Co-Executors will interpret "Jeffrey Epstein" or "Epstein" as Jeffrey E. Epstein. + +The Co-Executors also object to Plaintiff's definition of the term "Ghislaine Maxwell" or "Maxwell" on the grounds that, insofar as it includes "any entities owned or controlled by Ghislaine Maxwell, any employee, agent, attorney, consultant, or representative of Ghislaine Maxwell," it is overbroad, unduly burdensome, vague and ambiguous. The Co-Executors will interpret "Ghislaine Maxwell" or "Maxwell" as Ghislaine Maxwell. + +The Co-Executors also object to Plaintiff's definition of the term "Lesley Groff' or "Groff" on the grounds that, insofar as it includes "any entities owned or controlled by Lesley Groff, any employee, agent, attorney, consultant, or representative of Lesley Groff," it is overbroad, unduly burdensome, vague and ambiguous. The Co-Executors will interpret "Lesley Groff" or "Groff' as Lesley Groff. + +The Co-Executors also object to Plaintiffs definition of the term '1' or `a on the grounds that, insofar as it includes "any entities owned or controlled by In any employee, agent, attorney, consultant, or representative of " it is overbroad, unduly burdensome, vague and ambiguous. The Co-Executors will interpret = =' or + +# SPECIFIC OBJECTIONS AND RESPONSES TO REOUESTS + +# REOUEST NO. 1 + +All Documents relating to Plaintiff, whether or not they reference her by + +name. This Request includes, but is not limited to, all communications, diaries, journals, calendars, blog posts (whether published or not), notes (handwritten or otherwise), memoranda, documentation of car services, airline tickets and/or travel itineraries, accommodations, wire transfer receipts, or any other Documents that concern in any way, whether or not they reference her by name. + +### RESPONSE: + +The Co-Executors object to Request No. 1 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 1 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. + +Subject to and without waiving these objections and the parties' entry into a mutually acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors will search for and produce non-privileged documents concerning Plaintiff, if any exist and are located pursuant to mutually agreeable search parameters. The Co-Executors are working to collect and process documents for these purposes and will meet and confer with counsel for Plaintiff about the search as soon as practicable. + +# REOUEST NO. 2 + +All telephone records and other Documents reflecting telephone calls made by Epstein or to Epstein, including without limitation cell phone records, telephone logs, and message pads, to or from Epstein's employees. + +# RESPONSE: + +The Co-Executors object to Request No. 2 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co- + +Executors further object to Request No. 2 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors further object to this Request on the grounds and to the extent that it calls for the production of documents and information outside their possession, custody, and control. + +#### REOUEST NO. 3 + +All telephone records and other Documents reflecting telephone calls made by Epstein or to Epstein, includirigout limitation cell phone records, telephone logs, and message pads, to or from Maxwell, or Groff. + +# RESPONSE: + +The Co-Executors object to Request No. 3 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 3 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors further object to this Request on the grounds and to the extent that it calls for the production of documents and information outside their possession, custody, and control. + +#### REOUEST NO. 4, + +All telephone records associated with Epstein, Maxwell, =, or Groff, includhii. hone records, tele hone logs, and message pads, that show any communications with or Virginia + +### RESPONSE: + +The Co-Executors object to Request No. 4 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 4 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 5 + +All Documents relating to calendars, schedules, or appointments for Epstein. + +# RESPONSE: + +The Co-Executors object to Request No. 5 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 5 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. + +# REOUEST NO. 6 + +All Documents relating to contact lists, phone lists, or address books for Epstein. + +#### RESPONSE: + +The Co-Executors object to Request No. 6 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 6 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. + +# REQUEST NO. 7 + +All Documents relating to any Amazon.com account associated with Epstein or Maxwell, including without limitation the purchase order history for each account. + +# RESPONSE: + +The Co-Executors object to Request No. 7 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 7 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. + +# REQUEST NO. 8 + +All video tapes, audio tapes, photographs, portraits, including film negatives or film slides, CDs, or any other print or electronic media depicting Epstein, Maxwell, Groff, or in the presence of + +# RESPONSE: + +The Co-Executors object to Request No. 8 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors additionally object to this Request as duplicative of Request No. 9. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. + +Subject to and without waiving these objections and the parties' entry into a mutually acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors will search for and produce non-privileged documents concerning Plaintiff, if any exist and are located pursuant to mutually agreeable search parameters. The Co-Executors are working to collect and process documents for these purposes and will meet and confer with counsel for Plaintiff about the search as soon as practicable. + +# REOUEST NO. 9 + +All video tapes, audio tapes, photographs, including film negatives or film slides, CDs, or any other print or electronic media depicting or relating to I in any way. + +# RESPONSE: + +The Co-Executors object to Request No. 9 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors additionally object to this Request as duplicative of Request No. 8. The Co-Executors further object to Request No. 9 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. + +Subject to and without waiving these objections and the parties' entry into a mutually acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors will search for and produce non-privileged documents concerning Plaintiff, if any exist and are located pursuant to mutually agreeable search parameters. The Co-Executors are working to collect and process documents for these purposes and will meet and confer with counsel for Plaintiff about the search as soon as practicable. + +#### REOUEST NO. 10 + +All Documents relating to any communications between Epstein, Groff, Maxwell, or and or Virginia + +# RESPONSE: + +The Co-Executors object to Request No. 10 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 10 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors further object to this Request on the grounds that it seeks information already known to Plaintiff or her counsel. + +Subject to and without waiving these objections and the parties' entry into a mutually acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors will search for and produce non-privileged documents concerning Plaintiff, if any exist and are located pursuant to mutually agreeable search parameters. The Co-Executors are working to collect and process documents for these purposes and will meet and confer with counsel for Plaintiff about the search as soon as practicable. + +#### REOUEST NO. 11 + +All Documents relating to any gifts or moneta payments provided to, or for the benefit of, by Epstein, Maxwell, Groff, or any related entity. + +#### RESPONSE: + +The Co-Executors object to Request No. 11 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors further object to this Request on the grounds that it seeks information already known to Plaintiff or her counsel. + +Subject to and without waiving these objections and the parties' entry into a mutually acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors will search for and produce non-privileged documents concerning Plaintiff, if any exist and are located pursuant to mutually agreeable search parameters. The Co-Executors are working to collect and process documents for these purposes and will meet and confer with counsel for Plaintiff about the search as soon as practicable. + +#### REOUEST NO. 12 + +All Documents relating to communications between Epstein and Maxwell, Groff, or relating to + +#### RESPONSE: + +The Co-Executors object to Request No. 12 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. + +Subject to and without waiving these objections and the parties' entry into a mutually acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors will search for and produce non-privileged documents concerning Plaintiff, if any exist and are located pursuant to mutually agreeable search parameters. The Co-Executors are working to collect and process documents for these purposes and will meet and confer with counsel for Plaintiff about the search as soon as practicable. + +# REOUEST NO. 13 + +All Documents relating to communications between Epstein and Jean-Luc Brunel relating to + +#### RESPONSE: + +The Co-Executors object to Request No. 13 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. + +Subject to and without waiving these objections and the parties' entry into a mutually acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors will search for and produce non-privileged documents concerning Plaintiff, if any exist and are located pursuant to mutually agreeable search parameters. The Co-Executors are working to collect and process documents for these purposes and will meet and confer with counsel for Plaintiff about the search as soon as practicable. + +# REOUEST NO. 14 + +All Documents relating to travel to and from the United States, U.S. Virgin Islands, France, or South Africa. + +# RESPONSE: + +The Co-Executors object to Request No. 14 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors further object to this Request on the grounds that it seeks information already known to Plaintiff or her counsel. + +Subject to and without waiving these objections and the parties' entry into a mutually acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors will search for and produce non-privileged documents concerning Plaintiff, if any exist and are located pursuant to mutually agreeable search parameters. The Co-Executors are working to collect and process documents for these purposes and will meet and confer with counsel for Plaintiff about the search as soon as practicable. + +#### REQUEST NO. 15 + +All Documents relating to Epstein's 2002 trip to South Africa with President William "Bill" J. Clinton, including but not limited to travel itineraries, information about speaking engagements, lists of security staff and drivers, hotel information, and meeting information. + +# RESPONSE: + +The Co-Executors object to Request No. 15 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 15 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 16 + +All Documents relating to Groff or obtaining or preparing travel documents for travel to and from the United States. + +# RESPONSE: + +The Co-Executors object to Request No. 16 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors also object to this Request on the grounds that the term "travel documents" is vague and ambiguous. + +Subject to and without waiving these objections and the parties' entry into a mutually acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors will search for and produce non-privileged documents concerning Plaintiff, if any exist and are located pursuant to mutually agreeable search parameters. The Co-Executors are working to collect and process documents for these purposes and will meet and confer with counsel for Plaintiff about the search as soon as practicable. + +# REOUEST NO. 17 + +All Documents relating to any accommodations made by Epstein or his employees for at an apartment building located at 301 E. 66th Street, New York, NY. + +#### RESPONSE: + +The Co-Executors object to Request No. 17 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +Subject to and without waiving these objections and the parties' entry into a mutually + +acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors will search for and produce non-privileged documents concerning Plaintiff, if any exist and are located pursuant to mutually agreeable search parameters. The Co-Executors are working to collect and process documents for these purposes and will meet and confer with counsel for Plaintiff about the search as soon as practicable. + +#### REOUEST NO. 18 + +All Documents relating to any modelin referral 'ob, audition, casting, or other opportunity that Epstein or his employees assisted in obtaining. + +#### RESPONSE: + +The Co-Executors object to Request No. 18 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors further object to this Request on the grounds that it seeks information in Plaintiff's possession. + +Subject to and without waiving these objections and the parties' entry into a mutually acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors will search for and produce non-privileged documents concerning Plaintiff, if any exist and are located pursuant to mutually agreeable search parameters. The Co-Executors are working to collect and process documents for these purposes and will meet and confer with counsel for Plaintiff about the search as soon as practicable. + +# REOUEST NO. 19 + +All Documents relating to any service that Epstein, Maxwell, =, or Groff provided or funded for including but not limited to hair appointments and dentist appointments. + +#### RESPONSE: + +The Co-Executors object to Request No. 19 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors further object to this Request on the grounds that it seeks documents in Plaintiff's possession. + +Subject to and without waiving these objections and the parties' entry into a mutually acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors will search for and produce non-privileged documents concerning Plaintiff, if any exist and are located pursuant to mutually agreeable search parameters. The Co-Executors are working to collect and process documents for these purposes and will meet and confer with counsel for Plaintiff about the search as soon as practicable. + +#### REOUEST NO. 20 + +All Documents relating to any employee lists or records associated with Epstein or any related entity. + +#### RESPONSE: + +The Co-Executors object to Request No. 20 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. + +The Co-Executors further object to Request No. 20 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. + +#### REOUEST NO. 21 + +All Documents relating to payments made from Epstein, or an related entity, to Maxwell (a/k/a ), Groff, and (a/k/a ), including payments or bonuses for work performed, gifts, real estate purchases, living expenses, business ventures, and payments to Maxwell's charitable endeavors, including the TerraMar project. + +#### RESPONSE: + +The Co-Executors object to Request No. 21 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 21 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. + +# REQUEST NO. 22 + +All Documents relating to any credit card, business, or store account used by Maxwell, Groff, I or that was paid for by Epstein or any related entity. + +#### RESPONSE: + +The Co-Executors object to Request No. 22 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 22 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +#### REOUEST NO. 23 + +All Documents relating to confidentiality or separation agreements between Epstein or any associated entity and any employee or associate of Epstein. + +#### RESPONSE: + +The Co-Executors object to Request No. 23 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 23 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. + +# REOUEST NO. 24 + +All Documents relating to any house staff, employees, or individuals who were compensated by Epstein or any individual or entity affiliated with Epstein, during and/or after employment ceased, including but not limited to the followin individuals: Jean-Luc Brunel, Groff, Luciano "Jojo" Fontanilla, Rosalyn Fontanilla, Juan Alessi Maria Alessi Michael Li ffman, Cathy and Miles Alexander, Floyd Brice Michael O'Dell, Kate O'Dell, David Larry Visoski, David Rodgers, Andy Stewart, Adam Lang, Ryon Dionne, Bill Peadon, Francis Peadon and Igor Zinoviev. + +#### RESPONSE: + +The Co-Executors object to Request No. 24 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 24 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REQUEST NO. 25 + +All Documents relating to Rinaldo Rizzo from 2002 to the present. + +# RESPONSE: + +The Co-Executors object to Request No. 25 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 25 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +### REQUEST NO. 26 + +All Documents identifying any employees that performed work or services in or on any property owned, occupied, or used by Epstein. + +#### RESPONSE: + +The Co-Executors object to Request No. 26 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 26 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to Request No. 26 on the grounds of and to the extent it seeks documents necessarily held in a capacity other than as Co-Executors of the Estate. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REQUEST NO. 27 + +All Documents reflecting Your or Epstein's direct or indirect interest or control over business or personal assets of any employee or associate of Epstein, including but not limited to articles of incorporation, power of attorneys, contracts, and meeting minutes. + +#### RESPONSE: + +The Co-Executors object to Request No. 27 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 27 on the grounds that, to the extent it seeks + +documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to Request No. 27 on the grounds of and to the extent it seeks documents necessarily held in a capacity other than as Co-Executors of the Estate. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. + +#### REOUEST NO. 28 + +All video tapes, audio tapes, photographs, portraits, including film negatives or film slides, CDs, flash drives, meimirds, or any other print or electronic media depicting Epstein in the presence of Maxwell, or Groff. + +#### RESPONSE: + +The Co-Executors object to Request No. 28 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 28 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 29 + +All Documents relating to Maxwell, =, or Groff including but not limited to all Documents relating to communications between Epstein and Maxwell, M, or Groff. + +# RESPONSE: + +The Co-Executors object to Request No. 29 on the grounds and to the extent that it calls + +for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 29 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 30 + +All Documents relating to any agreements (including but not limited to confidentiality agreements, insurance policies or indemnification agreements, employment agreements, separation agreements, or agreements to pay legal fees) between Epstein and Maxwell, or Groff, whether such agreements are written, verbal, or merely understood among the parties and not otherwise expressed, and whether or not such agreements were ever executed or carried out. + +# RESPONSE: + +The Co-Executors object to Request No. 30 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 30 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors also object to this Request on the grounds that the phrase "merely understood among the parties and not otherwise expressed" is vague and ambiguous. + +# REOUEST NO. 31 + +All Documents relating to any Joint Defense Agreement entered into between Epstein and Maxwell, =, or Groff. + +# RESPONSE: + +The Co-Executors object to Request No. 31 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 31 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. + +#### REOUEST NO. 32 + +All Documents relating to or describing any work Maxwell, =, or Groff performed for or with Epstein or any affiliated entity. + +# RESPONSE: + +The Co-Executors object to Request No. 32 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 32 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. + +The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +#### REQUEST NO. 33 + +All Documents relating to any communications between Epstein or Epstein's attorneys and or attorneys related to the issue of sexual abuse of females. + +#### RESPONSE: + +The Co-Executors object to Request No. 33 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 33 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +#### REQUEST NO. 34 + +All Documents relating to any communications between Epstein or Epstein's attorneys and Groff or Groff's attorneys related to the issue of sexual abuse of females. + +#### RESPONSE: + +The Co-Executors object to Request No. 34 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 34 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 35 + +All Documents relating to any communications between Epstein or Epstein's attorneys and Maxwell or Maxwell's attorneys related to the issue of sexual abuse of females. + +# RESPONSE: + +The Co-Executors object to Request No. 35 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 35 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 36 + +All Documents relating to any communications between Epstein or Epstein's attorneys and + +or attorneys related to the recruitment of any female for any purpose, including socializing or performing any type of work or service. + +#### RESPONSE: + +The Co-Executors object to Request No. 36 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 36 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 37 + +All Documents relating to any communications between Epstein or Epstein's attorneys and Groff or Groff 's attorneys related to the recruitment of any female for any purpose, including socializing or performing any type of work or service. + +#### RESPONSE: + +The Co-Executors object to Request No. 37 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 37 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts + +not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +#### REOUEST NO. 38 + +All Documents relating to any communications between Epstein or Epstein's attorneys and Maxwell or Maxwell's attorneys related to the recruitment of any female for any purpose, including socializing or performing any type of work or service. + +#### RESPONSE: + +The Co-Executors object to Request No. 38 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 38 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 39 + +All Documents relating to any bank account, household account, or financial account identifying Maxwell in any way, including without limitation as an authorized user on the account. + +# RESPONSE: + +The Co-Executors object to Request No. 39 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 39 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors also object to this Request on the grounds that the terms "household account" and "financial account" are vague and ambiguous. + +# REOUEST NO. 40 + +All Documents or other media (including photographs) describing or depicting nude or partially nude females, including but not limited to all Documents or other media describing or depicting how such photographs were displayed in any of Epstein's various residences. + +#### RESPONSE: + +The Co-Executors object to Request No. 40 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 40 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors further object to this Request on the grounds + +that it seeks publicly available information and information already known to Plaintiff or her counsel. + +# REOUEST NO. 41 + +All Documents relating to any payments Epstein made to educational institutions or programs, visual or performing arts schools, or scholarship programs and, to the extent the payment was made for the benefit of another person, any Documents reflecting the identity of that person. + +# RESPONSE: + +The Co-Executors object to Request No. 41 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 41 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 42 + +All Documents relating to any request, proposal or inquiry made by Epstein, Maxwell, or to any modeling agency for casting, recruitment, potential employment, and/or other advancement opportunities and Documents reflecting the identity of any person responding to the request, proposal, or inquiry. + +#### RESPONSE: + +The Co-Executors object to Request No. 42 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 42 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 43 + +All Documents relating to calendars, schedules, or appointments for Epstein that relate to visits with or communications with females, excluding immediate family members. + +# RESPONSE: + +The Co-Executors object to Request No. 43 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 43 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REQUEST NO. 44 + +All Documents identifying any individuals who ever provided Epstein with a massage. + +# RESPONSE: + +The Co-Executors object to Request No. 44 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 44 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 45 + +All Documents identifying any individuals who Epstein paid for sexual acts, either with Epstein or with other individuals. + +# RESPONSE: + +The Co-Executors object to Request No. 45 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 45 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +#### REOUEST NO. 46 + +All Documents identifying any females recruited or referred by Maxwell, ME, or Groff for work, sexual acts, or companionship for Epstein. + +#### RESPONSE: + +The Co-Executors object to Request No. 46 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 46 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 47 + +All Documents relating to any females Maxwell, or Groff introduced to Epstein for work, sexual acts, or companionship for Epstein. + +# RESPONSE: + +The Co-Executors object to Request No. 47 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 47 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REQUEST NO. 48 + +All Documents relating to any females Epstein paid to perform any kind of service, including but not limited to work as an assistant, massage therapist, model, private exercise instructor, dance instructor, or companion. + +# RESPONSE: + +The Co-Executors object to Request No. 48 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 48 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 49 + +All Documents relating to massages, including but not limited to Documents reflecting recruiting or hiring masseuses, advertising for masseuses, flyers created for distribution at high schools or colleges, and Documents reflecting e-mails or calls to individuals relating to massages. + +# RESPONSE: + +The Co-Executors object to Request No. 49 on the grounds and to the extent that it calls + +for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 49 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 50 + +All Documents relating to passports applied for, obtained, or paid for by Epstein on behalf of any female recruited to work for Epstein to perform any kind of service, including but not limited to work as an assistant, massage therapist, model, private exercise instructor, dance instructor, or companion. + +#### RESPONSE: + +The Co-Executors object to Request No. 50 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 50 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +#### REOUEST NO. 51 + +All Documents relating to or (a/k/a + +#### RESPONSE: + +The Co-Executors object to Request No. 51 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 51 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession. custody, and control. + +# REOUEST NO. 52 + +All Documents relating to Epstein's travel, when that travel was either with Maxwell, Groff or other females or to meet Maxwell, MI Groff or other females, including but not limited to documentation of commercial flights, private flights, helicopters, boat charters, and car services, passport records, records indicating passengers traveling with Epstein, hotel records, and credit card receipts. + +# RESPONSE: + +The Co-Executors object to Request No. 52 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 52 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +#### REQUEST NO. 53 + +All Documents relating to Epstein's travel to South Africa between 2001 and the present. + +#### RESPONSE: + +The Co-Executors object to Request No. 53 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 53 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to the time period stated in the Request, which is inconsistent with the time frame alleged in the Complaint. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 54 + +All Documents relating to Epstein's travel to Florida between 2001 and the present. + +#### RESPONSE: + +The Co-Executors object to Request No. 54 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 54 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to the time period stated in the Request, which is inconsistent with the time frame alleged in the Complaint. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 55 + +All Documents relating to Epstein's travel to the U.S. Virgin Islands between 2001 and the present. + +#### RESPONSE: + +The Co-Executors object to Request No. 55 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 55 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to the time period stated in the Request, which is inconsistent with the time frame alleged in the Complaint. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +### REOUEST NO. 56 + +All Documents relating to Epstein's travel to France between 2001 and the present. + +# RESPONSE: + +The Co-Executors object to Request No. 56 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 56 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to the time period stated in the Request, which is inconsistent with the time frame alleged in the Complaint. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REQUEST NO. 57 + +All Documents relating to Epstein's travel to New Mexico between 2001 and the present. + +# RESPONSE: + +The Co-Executors object to Request No. 57 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 57 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to the time period stated in the Request, which is inconsistent with the time frame alleged in the Complaint. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 58 + +All Documents, including flight logs, identifying passengers, manifests, or flight plans for any helicopter or plane ever owned, leased, chartered, or controlled by Epstein or any associated entity, from 1995 to the present. + +# RESPONSE: + +The Co-Executors object to Request No. 58 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 58 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to the time period stated in the Request, which is inconsistent with the time frame alleged in the Complaint. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 59 + +All Documents relating to travel with Epstein of any female, including but not limited to documentation of commercial flights, private flights, helicopters, boat charters, and car services, passport records, records indicating passengers traveling with Epstein, hotel records, and credit card receipts. + +# RESPONSE: + +The Co-Executors object to Request No. 59 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 59 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 60 + +All video tapes, audio tapes, photographs or any other print or electronic media depicting any of Epstein's residences or aircrafts or inside of any of Epstein's residences or aircrafts. + +# RESPONSE: + +The Co-Executors object to Request No. 60 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 60 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. + +# REOUEST NO. 61 + +All Documents relating to Epstein's ownership, lease, occupancy, use, or management of property located at 301 East 66th Street, New York, New York. + +# RESPONSE: + +The Co-Executors object to Request No. 61 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 61 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. + +# REOUEST NO. 62 + +All Documents relating to any communications between Epstein or Maxwell and Alan Dershowitz relating to + +# RESPONSE: + +The Co-Executors object to Request No. 62 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 62 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. + +Subject to and without waiving these objections and the parties' entry into a mutually acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors will search for and produce non-privileged documents concerning Plaintiff, if any exist and are located pursuant to mutually agreeable search parameters. The Co-Executors are working to collect and process documents for these purposes and will meet and confer with counsel for Plaintiff about the search as soon as practicable. + +#### REQUEST NO. 63 + +All Documents relating to Eva or Glen + +#### RESPONSE: + +The Co-Executors object to Request No. 63 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 63 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession. custody, and control. + +# REQUEST NO. 64 + +All Documents relating to Miles Alexander or Cathy Alexander. + +# RESPONSE: + +The Co-Executors object to Request No. 64 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 64 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +#### REOUEST NO. 65 + +All Documents relating to Michael Bay. + +#### RESPONSE: + +The Co-Executors object to Request No. 65 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 65 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +#### REOUEST NO. 66 + +All Documents relating to former New Mexico Governor William "Bill" or persons acting on his behalf. + +#### RESPONSE: + +The Co-Executors object to Request No. 66 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. + +The Co-Executors further object to Request No. 66 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +#### REOUEST NO. 67 + +All Documents relating to Naja E. + +# RESPONSE: + +The Co-Executors object to Request No. 67 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 67 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 68 + +All Documents relating to Kevin Spacey or persons acting on his behalf. + +#### RESPONSE: + +The Co-Executors object to Request No. 68 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. + +The Co-Executors further object to Request No. 68 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +#### REOUEST NO. 69 + +All Documents relating to Chris Tucker or persons acting on his behalf. + +#### RESPONSE: + +The Co-Executors object to Request No. 69 on the grounds and to the extent that it calls Ibr the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 69 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +#### REOUEST NO. 70 + +All Documents relating to William "Bill" J. Clinton or persons acting on his behalf. + +#### RESPONSE: + +The Co-Executors object to Request No. 70 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 70 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 71 + +All Documents relating to Andrew Albert Christian Edward, of York (a/k/a Prince Andrew) or persons acting on his behalf. + +# RESPONSE: + +The Co-Executors object to Request No. 71 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 71 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 72 + +All Documents relating to communications between You or Epstein and John Doe, the intervenor in v. Maxwell, No. 15-cv-07433-LAP (S.D.N.Y.), or John Doe's attorneys. + +#### RESPONSE: + +The Co-Executors object to Request No. 72 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 72 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds of and to the extent it seeks documents necessarily held in a capacity other than as Co-Executors of the Estate. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors further object to this Request on the grounds that it seeks information already known to Plaintiff or her counsel. + +# REOUEST NO. 73 + +All Documents relating to Frederic Fekkai, as an individual or as the owner of a hair-related company, including information regarding accounts Epstein maintained for hair- related services and the identity of any females who received hair-related services at Epstein's expense. + +# RESPONSE: + +The Co-Executors object to Request No. 73 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 73 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession. custody, and control. + +#### REOUEST NO. 74 + +All Documents relating to Dr. Radford Goto. + +#### RESPONSE: + +The Co-Executors object to Request No. 74 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 74 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 75 + +All Documents relating to + +#### RESPONSE: + +The Co-Executors object to Request No. 75 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 75 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +#### REQUEST NO. 76 + +All Documents reflecting or consisting of communications between Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into the United States from other countries to pursue a career in modeling, including, but not limited to, letters, notes, and emails. + +# RESPONSE: + +The Co-Executors object to Request No. 76 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 76 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. + +#### REOUEST NO. 77 + +All Documents relating to Leslie Wexner or Abigail Wexner. + +# RESPONSE: + +The Co-Executors object to Request No. 77 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 77 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. + +The Co-Executors additionally object to this Request on the grounds of and to the extent it seeks documents necessarily held in a capacity other than as Co-Executors of the Estate. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +### REOUEST NO. 78 + +All Documents reflecting Your or Epstein's direct or indirect interest or control over business or personal assets of Leslie Wexner or Abigail Wexner, including but not limited to articles of incorporation, power of attorneys, contracts, and meeting minutes. + +#### RESPONSE: + +The Co-Executors object to Request No. 78 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 78 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds of and to the extent it seeks documents necessarily held in a capacity other than as Co-Executors of the Estate. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. + +#### REOUEST NO. 79 + +All Documents relating to any business transactions, including real estate and other financial transactions, between Epstein and Leslie Wexner from 1990 to the present. + +#### RESPONSE: + +The Co-Executors object to Request No. 79 on the grounds and to the extent that it calls + +for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 79 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to the time period stated in the Request, which is inconsistent with the time frame alleged in the Complaint. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. + +# REOUEST NO. 80 + +All Documents relating to Victoria's Secret models or actresses who were ever in the presence of Epstein. + +# RESPONSE: + +The Co-Executors object to Request No. 80 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 80 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 81 + +All Documents relating to any work that Epstein performed for Victoria's Secret or + +authority that Epstein possessed over Victoria's Secret. + +# RESPONSE: + +The Co-Executors object to Request No. 81 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 81 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 82 + +All Documents relating to modeling jobs, auditions, casting calls, or other opportunities with Victoria's Secret or any modeling agency, that Epstein assisted any person in securing. + +# RESPONSE: + +The Co-Executors object to Request No. 82 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 82 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 83 + +From January 2012 to the present, all Documents concerning any source of funding for the TerraMar Project or any other not-for-profit entities for which Epstein provided funding, including but not limited to funding for the Clinton Global Initiative, the Clinton Foundation (a/k/a William J. Clinton Foundation, a/lc/a/ the Bill, Hillary & Chelsea Clinton Foundation), and the Clinton Foundation Climate Change Initiative. + +# RESPONSE: + +The Co-Executors object to Request No. 83 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 83 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +# REOUEST NO. 84 + +All Documents relating to Epstein's estate planning, will, or any financial transactions that occurred between the date of his arrest on July 6, 2019, and his death on August 10. 2019. + +# RESPONSE: + +The Co-Executors object to Request No. 84 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 84 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. + +# REOUEST NO. 85 + +All Documents relating to communications between Epstein or Epstein's attorneys or agents and any law enforcement entity, including the FBI, NYPD, Palm Beach Police Department, and West Palm Beach Police Department, relating to any criminal investigation, cooperation in any criminal investigation, potential criminal charges, immunity, deferred prosecution, or suspected or known criminal activity. + +# RESPONSE: + +The Co-Executors object to Request No. 85 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 85 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors further object to this Request on the grounds that it seeks publicly available information and information already known to Plaintiff or her counsel. + +# REOUEST NO. 86 + +All Documents relating to communications between Epstein and Epstein's attorneys or agents and Alexander Acosta, Maria Villafana, or other attorneys associated with the United States Attorney's Office for the Southern District of Florida. + +# RESPONSE: + +The Co-Executors object to Request No. 86 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. + +The Co-Executors further object to Request No. 86 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors further object to this Request on the grounds that it seeks publicly available information and information already known to Plaintiff or her counsel. + +# REOUEST NO. 87 + +All Documents concerning any action or lawsuit brought against Epstein, Maxwell, =, or Groff, including, but not limited to, actions or lawsuits brought in foreign jurisdictions. + +# RESPONSE: + +The Co-Executors object to Request No. 87 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 87 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors further object to this Request on the grounds that it seeks publicly available information and information already known to Plaintiff or her counsel. + +# REOUEST NO. 88 + +All Documents produced by Epstein or Maxwell in discovery in v. Maxwell, No. 15-cv-07433-LAP (S.D.N.Y.). + +# RESPONSE: + +The Co-Executors object to Request No. 88 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. + +The Co-Executors further object to Request No. 88 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors further object to this Request on the grounds that it seeks publicly available information and information already known to Plaintiff or her counsel. + +#### REOUEST NO. 89 + +All Documents seized by any government agency from Epstein's home located at 9 East 71st Street, New York, New York or at 358 El Brillo Way, Palm Beach, Florida. + +#### RESPONSE: + +The Co-Executors object to Request No. 89 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 89 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. + +#### REOUEST NO. 90 + +All Documents relating to the "two . . . payments, one in the amount of \$250,000 and another in the amount of \$100,000 to ... two employees or associates of Mr. Epstein's" referenced by Assistant United States Attorney Alexander Rossmiller at Epstein's bail hearing on July 15, 2019, including Documents sufficient to identify the recipients of those payments. See Transcript of July 15, 2019 Bail Hearing at 9:15-20, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.) + +#### RESPONSE: + +The Co-Executors object to Request No. 90 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 90 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. + +# REOUEST NO. 91 + +All Documents relating to Shoppers Travel, including records of payment to Shoppers Travel, communications with Shoppers Travel, or records of any airline tickets, hotel reservations, or other travel accommodations booked through Shoppers Travel by Epstein or his agents or employees for himself or any other person. + +# RESPONSE: + +The Co-Executors object to Request No. 91 on the grounds and to the extent that it calls for the production of documents and information protected by the attorney-client privilege, attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object to Request No. 91 on the grounds that, to the extent it seeks documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors additionally object to this Request on the grounds and to the extent that it specifically calls for the production of documents and information outside their possession, custody, and control. The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts not in evidence. + +Dated: New York, New York + +April 16, 2020 TROUTMAN SANDERS LLP + +By: /s/Bennet Moskowitz Bennet Moskowitz 875 Third Avenue New York, New York 10022 Tel: (212) 704- 6087 bennet.moskowitz@troutman.com + +> Attorneys for Darren K Indyke and Richard D. Kahn, as co-executors of the estate of.kikey E. Epstein + +#### CERTIFICATE OF SERVICE + +The undersigned certifies that on April 16, 2020, I served a copy of the foregoing Defendants' Objections and Responses to Plaintiff-I First Request for Production of Documents to Defendants, by sending them by email to: + +Sigrid McCawley Boies Schiller Flexner LLP 55 Hudson Yards New York, New York 10001 Email: smccawley@bsflIp.com + +TROUTMAN SANDERS LLP + +By: /sr. Mary W. Metcalfe 875 Third Avenue New York, New York 10022 Tel: (212) 704-6029 marygrace.metcalfe@troutman.com + +> Attorneys for Darren K. Indyke and Richard D. Kahn, as co-executors of the estate ofJeffrey E. Epstein + +# Exhibit F + +April 20, 2020 + +# VIA EMAIL + +Bennet J. Moskowitz Troutman Sanders LLP 875 Third Avenue New York, New York 10022 Tel: (212) 704-6087 bennet.moskowitzetroutman.com + +Re: Intlylie et al.. Case No. 1:19-10-179 + +Dear Bennet: + +I write on behalf of Plaintiff in response to Defendants Darren K. Indyke and Richard D. Kahn, as co-executors of the Estate of Jeffrey E. Epstein (the "Estate"), responses and objections to the Plaintiff's discovery requests provided on April 16, 2020. As you likely have anticipated, I specifically write in response to your total failure to respond to your discovery obligations. I ask that we meet and confer about your lack of responses as soon as practicable. + +First, as you are aware, Plaintiff served seventeen interrogatories on Defendants. You answered none of them; rather, each interrogatory is met with an assortment of boilerplate objections, ranging from objections to relevancy or "discovery about discovery" or assuming "facts not in evidence" (which is especially puzzling, given that the very purpose of discovery is to find such facts). At best, these objections are deficient; at worst, they are meritless and borderline frivolous. + +Similarly, you have failed to adequately respond to most of Plaintiff's document requests. Again, your objections are premised on conclusory objections, ranging from objections to relevancy and claims that certain documents are outside Defendants' possession, custody, and control. As part of your discovery obligations, "generalized objections that discovery requests are vague, overly broad, or unduly burdensome are not acceptable." Shane/run Yu v. Diguojiaoyu, Inc., 18-CV-7303, 2019 WL 6174204, \*4-5 (S.D.N.Y. Nov. 20, 2019) (granting plaintiffs' motion to compel discovery after defendants "raised repeated and rote objections to Plaintiffs' document requests, [] refused to provide Plaintiffs any documents whatsoever, and []answered the interrogatories in [a] substantially similar fashion"); see also Harris v. Bronx Parent Housing Network, Inc., 18-CV-11681, 2020 WL 763740, at \*2 (S.D.N.Y. Feb. 14, 2020) ("Boilerplate objections that include unsubstantiated claims of undue burden, overbreadth and lack of relevancy, accompanied by a lack of document production or interrogatory response, are a paradigm of discovery abuse.") (internal quotation marks and citation omitted). "A party resisting discovery + +April 20, 2020 Page 2 + +has the burden of showing specifically how, despite the broad and liberal construction afforded the federal discovery rules, each interrogatory is not relevant or how each question is overly broad, burdensome or oppressive . . . by submitting affidavits or offering evidence revealing the nature of the burden." Harris, 2020 WL 763740, at \*2 (internal quotation marks and citations omitted). + +Second, your relevance objections are meritless. All of Plaintiff's requests are relevant. For example, please explain how documents relating to are not relevant to her claims or are not reasonably calculated to lead to the discovery of admissible evidence. See Request I. Plaintiff alleges that Epstein abused her for years, organized her overseas travel on many occasions, obtained travel documents for her, housed her in his apartment building, and emailed her as recently as June 2019. She is entitled to any document relating to her. Plaintiff's other requests are also directly relevant to her claims or the Estate's anticipated affirmative defenses. She is entitled to discovery, for example, about Epstein's communications and relationships with the people who accompanied him to South Africa when he recruited her to be a part of his sex-trafficking operation (e.g., RFPs 15, 53, 67-70; Interrogatory 11); documents relating to the employees who helped him transport Plaintiff to the United States and schedule Plaintiff for sex (e.g., RFPs 3, 4, 29, 30, 31-38, 46-47); his pattern of enticing young models to fly to the United States by falsely claiming that he could get them modeling opportunities (e.g., RFPs 18, 42, 76, 80-82); his communications with his associates who were present in Epstein's homes when Plaintiff was abused (e.g., RFPs 63-66); and Epstein's travel to the places in which he abused Plaintiff (e.g., RFPs 54-59). + +Moreover, Plaintiff is entitled to know the breadth and nature the sex-trafficking operation that she was victimized by. See Fed. R. Evid. 415 ("In a civil case involving a claim for relief based on a party's alleged sexual assault or child molestation, the court may admit evidence that the party committed any other sexual assault or child molestation."). Plaintiff alleges that Epstein utilized his sex-trafficking operation to recruit and abuse countless young girls and women in a methodical and similar fashion. Epstein's recruitment, trafficking, and assault of other girls in the same way that he recruited, trafficked, and assaulted Plaintiff would make Plaintiff's allegations more probable. See Fed. R. Evid. 401. Plaintiff's discovery requests are therefore directly relevant to the allegations in her Complaint, or, at a minimum, are reasonably calculated to lead to the discovery of admissible evidence. + +Third, your objections to certain of the time periods stated in the Requests are meritless for several reasons. As explained above, Epstein's other sexual assaults would be both relevant and admissible in this case, regardless of time period. Further, you have raised a statute of limitations defense in Plaintiff's case, and Plaintiff has made an equitable estoppel argument in response. Plaintiff is entitled to discovery relevant to her equitable estoppel theory, including but not limited to any threats or misrepresentations that Epstein made to Plaintiff to prevent her from filing this lawsuit, outside of the time period during which Plaintiff was physically abused by Epstein. + +Fourth, your objection to Plaintiff's definition of Jeffrey Epstein as including "any entities owned or controlled by Jeffrey Epstein, any employee, agent, attorney, consultant, or April 20, 2020 Page 3 + +representative of Jeffrey Epstein" is an improper attempt to narrow your discovery obligations in this matter. Your objection directly contradicts the Local Rules of this Court, which define the word "parties" as including a defendant's "employees, partners, . . . or affiliates." Local Rule 26.3(cX5). Plaintiff's definition is proper. + +Fifth, your responses and objections state many times that certain documents and information are outside of the Estate's possession, custody, and control. If that is the case, please explain what is and is not within the Estate's possession and control. For example, please explain in detail what computers, hard drives, email accounts, telephone records, or hard copy documents you have reviewed and provide a list of search terms that were used and specifically list what items you claim to not have access to. We know that Epstein at a minimum used the following email accounts: + +- • +- • +- • +- • +- • +- • +- • +- • +- ieffrevelamindsrtring.com• jeeoroiect@yahoo.com; jeevacation(agmail.com; ieristein(4revonet.com• zorroranch@aol.com; ceciliaRellmax.com; ieffrev.ensteinaxenturvtel.net• and epsteinj@wanadoo.fr + +Confirm that you have accessed and searched each of these accounts and provide the protocol used for the search. In the alternative, if the Estate contends that information that is responsive to Plaintiff's discovery requests was destroyed, provide all details relating to the destruction. + +Please let us know your availability for a meet and confer on the following dates and times: + +- Wednesday, April 22, 2020 between 2:00 and 3:00 EST; +- Thursday, April 23, 2020 between 3:00 EST and 6:00 EST; and +- Friday, April 24, 2020 between 3:00 EST and 5:00 EST. + +Sincerely, + +/s/ Sigrid S. McCawley Sigrid S. 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0000000000000000000000000000000000000000..ab7bc4be42f132f8778ac88e54b79b403cee0f49 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732136/EFTA02732136.md @@ -0,0 +1,40 @@ +Troutman Sanders LLP +875 Third Avenue +New York, New York 10022 + +troutman.com + +![](_page_0_Picture_18.jpeg) + +**Matthew J. Aaronson** +Matthew.aaronson@troutman.com + +May 8, 2020 + +**Via ECF** + +Hon. Debra C. Freeman +Daniel [REDACTED] Moynihan +United States Courthouse +500 Pearl St. +New York, NY 10007 + +**Re: Jane Doe 1000, 1:19-cv-10577-LJL-DCF; [REDACTED], 1:19-cv-10476-PGG-DCF; [REDACTED], 1:19-cv-10479-ALC-DCF** + +Dear Judge Freeman: + +We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"), in the above-referenced actions commenced by Plaintiffs Jane Doe 1000, [REDACTED] and [REDACTED] (the "Actions"). Plaintiffs filed a letter in each of the Actions yesterday seeking a pre-motion conference on Plaintiffs' anticipated motions to compel, among other things, interrogatory responses (the "Letters"). While we address threshold issues with the Letters below – primarily that they are premature and inconsistent with Your Honor's individual rules and directions regarding the parties' obligation to engage in meaningful efforts to resolve discovery issues before seeking the court's intervention – one of Your Honor's explicitly stated pet peeves – we respectfully request that the Court deny the requests for pre-motion conferences as an unnecessary waste of the Court's time. Alternatively, the Co-Executors request permission to submit a response to the substantive issues raised in the Letters by May 13, 2020, by which time Co-Executors expect to have supplemented their interrogatory responses, which is something the Co-Executors agreed to do as a compromise, **before Plaintiffs went ahead and filed the Letters with the Court.** + +The timing of the Letters is particularly troubling considering that the parties' meet-and-confer process was still very much on-going with respect to issues raised by both sides. In fact, we emailed Plaintiffs' counsel on May 6 seeking confirmation that, in light of the parties' continued communications to resolve certain discovery issues, **which only commenced on April 27**, neither side would seek judicial intervention at this time, consistent with Your Honor's directives. + +Plaintiffs responded to that email yesterday at 5:41PM – 35 mins before they filed the Letters – leaving us no opportunity to respond to Plaintiffs' suggestion that the Parties were at an impasse. That is perplexing, given that the Co-Executors advised Plaintiffs' counsel during our conversation on April 27 (and again as recently as May 5) that the Co-Executors would be supplementing their interrogatory responses and would consider their position on a number of the issues Plaintiffs raised and get back to them. Plaintiffs' inexplicable rush to demand a pre-motion + +conference not only violates Your Honor's rules and explicit directions, it appears designed to obtain a perceived litigation advantage in an effort to detract from Plaintiffs' refusal to comply with their own discovery obligations (including, for example, their refusal to produce all of their medical records, and not just those that Plaintiffs unilaterally deem relevant to these actions). Again, these are issues which the Co-Executors had believed the parties were still discussing in good faith. + +Accordingly, the Court should deny Plaintiffs' request for a pre-motion conference on the grounds that the Letters are premature, misconstrue the nature of the Parties' discussions and violate Your Honor's rules concerning the Parties' obligations to meet and confer in good faith in an effort to resolve or narrow discovery disputes. However, if Your Honor is inclined to consider Plaintiffs' request, then the Co-Executors respectfully request permission to submit a response to the substantive issues raised in the Letters by May 13. 2020. + +Respectfully submitted, + +s/Matthew J. Aaronson Matthew J. 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INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, Defendants. + +CASE NO. 1:19-CV-10479 ALC-DCF + +PLEASE TAKE NOTICE that the undersigned attorney hereby appears as counsel for defendants Darren Indyke and Richard D. Kahn, in their capacities as the Executors of the Estate of Jeffrey E. Epstein, in the captioned action. I certify that I am admitted to practice in this Court. All notices given or required to be given in this case shall be served upon the undersigned. + +Dated: New York, New York. May 8, 2020 + +> By: /s/Matthew J. Aaronson Matthew J. Aaronson TROUTMAN SANDERS LLP 875 Third Avenue New York, NY 10022 212.704.6000 Matthew.Aaronson@troutman.com + +Attorneys for Defendants + +To: All Counsel of Record (via ECY) \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732138/EFTA02732138.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02732138/EFTA02732138.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..582363b0ce7642b822c6bd198dee99fcdc1d3ca5 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732138/EFTA02732138.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02732138.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 869, + "elapsed_seconds": 0.49, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.78000000000003, + 71.28 + ], + [ + 418.0601501464844, + 71.28 + ], + [ + 418.0601501464844, + 100.10302734375 + ], + [ + 192.78000000000003, + 100.10302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Line", + 28 + ], + [ + "Text", + 7 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02732138" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732139/EFTA02732139.md b/marker2/court-redacted-v-indyke-10479/EFTA02732139/EFTA02732139.md new file mode 100644 index 0000000000000000000000000000000000000000..455ec974972a1845849289197d3826e983ee6773 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732139/EFTA02732139.md @@ -0,0 +1,25 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +Plaintiff, + +-against- + +DARREN I. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +CASE NO. 1:19-CV-10479 ALC-DCF + +## NOTICE OF APPEARANCE + +PLEASE TAKE NOTICE that the undersigned attorney hereby appears as counsel for defendants Darren,. Indyke and Richard D. Kahn, in their capacities as the Executors of the Estate of Jeffrey E. Epstein, in the captioned action. I certify that I am admitted to practice in this Court. All notices given or required to be given in this case shall be served upon the undersigned. + +Dated: New York, New York. May 8, 2020 + +By: /s/Charles I.. Glover + +Charles L. Glover TROUTMAN SANDERS LLP 875 Third Avenue New York, NY 10022 212.704.6000 Charles.Glover@troutman.com + +Attorneys for Defendants + +To: All Counsel of Record (via ECY) \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732139/EFTA02732139.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02732139/EFTA02732139.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..eeaf5c627089430f9003bb132cfa6e4857b3cd62 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732139/EFTA02732139.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02732139.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 894, + "elapsed_seconds": 0.72, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.78000000000003, + 71.28 + ], + [ + 418.0601501464844, + 71.28 + ], + [ + 418.0601501464844, + 100.10302734375 + ], + [ + 192.78000000000003, + 100.10302734375 + ] + ] + }, + { + "title": "NOTICE OF APPEARANCE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 353.736, + 215.46000000000004 + ], + [ + 512.5885009765625, + 215.46000000000004 + ], + [ + 512.5885009765625, + 229.4830322265625 + ], + [ + 353.736, + 229.4830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Line", + 29 + ], + [ + "Text", + 12 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02732139" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732140/EFTA02732140.md b/marker2/court-redacted-v-indyke-10479/EFTA02732140/EFTA02732140.md new file mode 100644 index 0000000000000000000000000000000000000000..5ed46640e5a18818dd7d9c5607802ddc4448b7a6 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732140/EFTA02732140.md @@ -0,0 +1,17 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +Plaintiff, -against-DARREN I. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, Defendants. + +CASE NO. 1:19-CV-10479 ALC-DCF + +PLEASE TAKE NOTICE that the undersigned attorney hereby appears as counsel for defendants Darren,. Indyke and Richard D. Kahn, in their capacities as the Executors of the Estate of Jeffrey E. Epstein, in the captioned action. I certify that I am admitted to practice in this Court. All notices given or required to be given in this case shall be served upon the undersigned. + +Dated: New York, New York. May 8, 2020 + +By: /sNalede Sirota + +Valerie Sirota TROUTMAN SANDERS LLP 875 Third Avenue New York, NY 10022 212.704.6000 valerie.sirota@troutman.com + +Attorneys for Defendants + +To: All Counsel of Record (via ECY) \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732140/EFTA02732140.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02732140/EFTA02732140.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a778c616ad24d5e138e37eacdfafd0d0686d052a --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732140/EFTA02732140.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02732140.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 856, + "elapsed_seconds": 0.53, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.78000000000003, + 72.08999999999999 + ], + [ + 418.0601501464844, + 72.08999999999999 + ], + [ + 418.0601501464844, + 100.10302734375 + ], + [ + 192.78000000000003, + 100.10302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 56 + ], + [ + "Line", + 28 + ], + [ + "Text", + 8 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02732140" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732141/EFTA02732141.md b/marker2/court-redacted-v-indyke-10479/EFTA02732141/EFTA02732141.md new file mode 100644 index 0000000000000000000000000000000000000000..bb4d471fbfedb84ee6f95669a708dc0d78d39056 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732141/EFTA02732141.md @@ -0,0 +1,31 @@ +![](_page_0_Picture_1.jpeg) + +## VIA ECF + +The Honorable Debra Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007- 13 12 + +> Re: v. Darren K. Indyke & Richard D. Kahn. 19-10479-ALC-DCF + +Sigrid S. McCawley Telephone: (954) 377-4223 Email: smccawley@bsfllp.com + +May 11, 2020 + +Dear Judge Freeman: + +We submit on behalf of Plaintiff this reply in further support of her letter motion for a conference to address Defendants' complete failure to participate in discovery to date (ECF No. 27), and in response to Defendants' letter, filed on May 8, 2020 (ECF No. 28). As set forth in Plaintiff's opening letter, Defendants refuse to produce documents concerning Jeffrey Epstein's sex-trafficking conspiracy. Instead, they offer to produce only documents that directly mention Plaintiff's name, and documents only from limited time periods surrounding the specific dates on which she was abused. ECF No. 27. Defendants also failed to respond to any of Plaintiff's Rule 33 interrogatories. Defendants' opposition admittedly offers no "response to the substantive issues," yet asks the Court to deny Plaintiff's request for a conference because it would somehow be "an unnecessary waste of the Court's time." ECF No. 28 at I. The Court should reject Defendants' transparent delay tactic and order the Defendants to address their discovery deficiencies immediately. + +Defendants' only basis for arguing that a conference would be "premature" is that, on April 30, they promised to serve amended responses to Plaintiff's interrogatories by the end of last week. But not only did Defendants fail to serve amended interrogatory responses last week (despite committing to do so), they have never even offered to amend their responses to Plaintiff's Rule 34 requests for production. Defendants also made clear at a meet and confer held on Tuesday, May 5, that they would not be changing their positions on the threshold disputes identified in Plaintiff's letter. These disputes, which the parties have already conferred over for hours, are therefore ripe for the Court's review. + +Contrary to Defendants' suggestion, Plaintiff has complied with her obligations to meet and confer in good faith. She has also already produced hundreds of documents spanning over 10,000 pages. Instead, it is Defendants' obstructionist conduct that requires immediate Court intervention. Because this case was filed six months ago and the Court's Rule 16 conference took place back in February, Defendants' failure to produce a single document or meaningfully respond to discovery requests can only be viewed as an intentional effort to delay discovery. As just one example, Defendants claim that they "expect" to be able to "supplement" their interrogatory responses by May 13. But their initial responses, which are attached as exhibits to Plaintiff's + +opening letter, speak for themselves, and make clear that Defendants have not undertaken reasonable efforts to comply with their discovery obligations or meet Court-ordered deadlines in good faith. Where, as here, Defendants (i) refused to answer interrogatories such as "Identify all email accounts used by Epstein or any of his employees or agents on his behalf'; (ii) failed to provide signatures, pursuant to Rule 33(b)(5), indicating that counsel even discussed the interrogatories with their clients before serving their responses; and (iii) did not send a single attorney involved in the drafting of their objections to the parties' April 27 meet and confer, leaving Defendants unable to explain how their responses were crafted or even articulate what they meant; it is clear that Defendants are attempting to game the process to maximize delay. Plaintiff's decision to curtail these dilatory tactics therefore does not fall within what the Court described as a "pet peeve" at the February I I, 2020, conference. + +Plaintiff respectfully requests that the Court grant her request for a conference to address these issues. + +Respectfully submitted, + +/s/ Sigrid S. McCawley + +Sigrid S. 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INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +#### PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANTS' MOTION TO DISMISS PLAINTIFF'S COMPLAINT + +### TABLE OF CONTENTS + +| PRELIMINARY STATEMENT | 1 | +|-----------------------------------------------------------------------------------------|----| +| STATEMENT OF FACTS | 1 | +| ARGUMENT | 4 | +| I. Defendants Have Not Met Their Burden of Proving that Plaintiff's Claims Are Untimely | 4 | +| A. Plaintiff's Claims Are Timely Under N.Y. C.P.L.R. § 215(8Xa) | 5 | +| I. The Indictment Was Not Restricted to Minors. | 6 | +| Concerned. | 7 | +| 3. Defendants' Attempts to Narrow the Scope of C.P.L.R. § 215(8)(a) Fail | 8 | +| B. Plaintiff's Claims are Timely Pursuant to N.Y. C.P.L.R. § 213-c | 10 | +| C. N.Y. C.P.L.R. § 202 Does Not Apply to Plaintiff's Claims. | 13 | +| I. Statutory Interpretation Precludes the Application of C.P.L.R. § 202. | 13 | +| 2. Plaintiff's Claims Did Not Accrue "Without the State" of New York. | 14 | +| 3. Plaintiff's Residency When the Cause of Action Accrued Is a Factual Issue. | 14 | +| Equitable Estoppel. | 15 | +| Equitable Tolling. | 17 | +| II. The Court Should Deny the Defendants' Motion to Dismiss Punitive Damages | 19 | +| A. Defendants' Motion to Dismiss Punitive Damages is Procedurally Improper. | 19 | +| B. Plaintiff May Recover Punitive Damages in this Case | 20 | +| I. USVI Law on Punitive Damages Governs This Case. | 20 | +| 2. USVI Law Would Allow for Punitive Damages against Defendants | 22 | +| a. Banks Factor One: Whether Any USVI Courts Have Adopted a Rule | 22 | +| b. Banks Factor Two: The Position Taken by a Majority of Courts from Other | | +| Jurisdictions | 23 | +| c. Banks Factor Three: The Soundest Rule for the USVI | 24 | +| CONCLUSION | 25 | + +#### TABLE OF AUTHORITIES + +### Cases + +- Antone v. Gen. Motors Corp., 473 N.E.2d 742 (N.Y. 1984) 15 Ashcroft v. lqbal, 556 U.S. 662 (2009) 4 Babcock v. M, 191 N.E.2d 279 (N.Y. 1963) 20 Banks v. Intl Rental & Leasing Corp., 55 V.I. 967 (V.I. 2011) 22, 25 Booth v. Bowen, No. CIV. 2006-217, 2008 WL 220067 (D.V.I. Jan. 10, 2008) 23 +- v. Parlcchester S. Condos., 287 F.3d 58 (2d Cir. 2002) 18 Burrows v. Bd. of Assessors for Town of Chatham, 98 A.D.2d 250 (3d Dep't 1983), aff'd, 473 N.E.2d 748 (N.Y. 1984) 13 Childers v. New York & Presbyterian Hosp., 36 F. Supp. 3d 292 (S.D.N.Y. 2014) 4, 17 Christodoulou v. Terdenton, 262 A.D.2d 595 (2d Dep't 1999) 9 CIT Bank N.A. v. Schtffinan, 948 F.3d 529, 537 (2d Cir. 2020), certified question accepted, No. 36, 2020 WL 729773 (N.Y. Feb. 13, 2020) 25 Clemens v. Nealon, 202 A.D.2d 747 (3d Dep't 1994) 13 Coffinan v. Coffinan, 60 A.D.2d 181 (2d Dep't 1977) 12 Crabtree ex. Rel. Kemp v. Estate of Crabtree, 837 N.E.2d 135 (Ind. 2005) 24 +- v. No. 15-cv-5359, 2016 WL 5720811 (S.D.N.Y. Sept. 30, 2016) 18 DeMartino v. 148 A.D.2d 568 (2d Dep't 1989) 15 + +| Denton v. McKee, | | +|---------------------------------------------------------------------|--------| +| 332 F. Supp. 2d 659 (S.D.N.Y. 2004) | 20 | +| 546 F.2d 643 (5th Cir. 1977) | 23 | +| Estate of Farrell ex rel. Bennett v. M, | | +| 770 A.2d 517 (Del. 2001) | 23 | +| 647 F. Supp. 2d 285 (S.D.N.Y. 2009) | 18 | +| No. 14-CV-0376 (BMC), 2019 WL 3035124 (E.D.N.Y. July 11, 2019) | 16 | +| No. 2017-52980, 2018 N.Y. Misc. LEXIS 8435 (Sup. Ct. Oct. 23, 2018) | 9 | +| 219 N.E.2d 169 (N.Y. 1966) | 16 | +| 649 N.Y.S.2d 647 (Sup. Ct. 1996) | 12 | +| No. 05-CV-1899 (IW), 2006 WL 1154817 (E.D.N.Y. Apr. 28, 2006) | 17 | +| 60 V.I. 597 (V.I. 2016) | 22. 24 | +| No. ST-15-CV-195, 2016 WL 9525609 (V.I. Super. Aug. 22, 2016) | 25 | +| 103 F. Supp. 3d 325 (E.D.N.Y. 2015) | 19 | +| 51 V.I. 619 (D.V.I. 2009) | 23 | +| 7 A.D.2d 817 (3d Dep't 1958) | 15 | +| 31 P.3d 114 (Ariz. 2001) | 23 | +| 186 F.3d 243 (2d Cir. 1999) | 4 | + +| Hofer v. Lavender, | | +|-------------------------------------------------------------------------------------------------------|-------------| +| 679 S.W.2d 470 (Tex. 1984) In re Gleason (Michael Vee, Ltd.), | 23 | +| 749 N.E.2d 724 (2001) In re S. African Apartheid Litig., | 12 | +| 617 F.Supp.2d 228 (S.D.N.Y. 2009) v. City of New York, | 18 | +| No. 18-CV-1937 (VSB), 2020 WL 1644009 (S.D.N.Y. Apr. 2, 2020) Kaopuiki v. Kealoha, | 19.20 | +| 87 P.3d 910 (Haw. Ct. App. 2003) Kashe v. BNP Paribas S.A., | 23 | +| 925 F.3d 53 (2d Cir. 2019) Klaxon Co. v. Stentor Elec. Mfg. Co., | 4, 7, 9, 10 | +| 313 U.S. 487 (1941) | 20 | +| 274 F.3d 706 (2d Cir. 2001) LaRocca v. Cohen IP, | 17 | +| No. 08 Civ. 6274, 2009 WL 10435869 (S.D.N.Y. May 6, 2009) McElligott v. City of New York, | 8 | +| No. 15 CIV. 7107 (LOS), 2017 WL 6210840 (S.D.N.Y. Dec. 7, 2017) McGuirk v. City Sch. Dist. of Albany, | 9 | +| 116 A.D.2d 363 (3d Dep't 1986) | 11 | +| Meegan S. v. Donald T., | | +| 475 N.E.2d 449 (N.Y. 1984) Nat'l Jewish Democratic Council v. Adelson, | 11, 12 | +| 417 F. Supp. 3d 416 (S.D.N.Y. 2019) Padula v. Lilarn Prop. Corp., | 21 | +| 644 N.E.2d 1001 (N.Y. 1994) Melton, | 20 | +| 299 S.E.2d 8 (W. Va. 1982) | 23 | +| =v. Boy Scouts of Am., /nc., | | +| 65 N.Y.2d 189 (1985) | 21 | + +Siegfried v. Siegfried, 92 A.D.2d 916 (2d Dep't 1983) 15 + +Tillett v. Lippert, 909 P.2d 1158 (Mont. 1996) 23 + +### Statutes + +N.Y. Penal Law § 130.35 11 + +N.Y. Stat. Law § 51 12 + +N.Y. Stat. Law § 54 12 + +N.Y. Stat. Law § 76 13 + +# Rules + +Fed. R. Civ. P. 12 19 + +N.Y. C.P.L.R. § 202 4, 13, 14, 15 + +N.Y. C.P.L.R. § 213-c passim + +N.Y. C.P.L.R. § 215 passim + +# Other Authorities + +Brief of Defendants-Appellees, Kashef v. BNP Paribas S.A., No. 18-1304 (2d Cir. Aug. 9, 2018), Dkt. 92 10 + +Complaint, GVI v. Estate of Jeffrey E. Epstein, No. ST-20-CV-014 (V.I. Sup. Ct. Jan. 15, 2020) 22 + +N.Y. Comm. Rep., 2019 N.Y. S.B. No. 6574, 42nd Legis. Sess. (June 17, 2019) 11 + +Restat. (Second) of Torts § 908 23 + +Transcript of Pre-motion Conference, v. Indyke, et al., No. 19-cv-10475 (LGS) (S.D.N.Y. Mar. 5, 2020), Dkt. 39 5 + +Plaintiff by and through her undersigned attorneys, respectfully submits this Memorandum of Law in Opposition to Defendants' Motion to Dismiss Plaintiff's Complaint.' + +#### PRELIMINARY STATEMENT + +For decades, Jeffrey Epstein and his co-conspirators recruited countless young women to his homes across the world, and forced them to give him massages that escalated into sexual assault. was just one of many victims that Epstein and his co-conspirators recruited to be a part of their sex-trafficking operation when she was a young woman. Epstein offered to help Plaintiff with her dream of modeling in New York, but instead sexually abused her for years. + +Defendants contend that Plaintiff's claims are untimely, but wholly ignore the burden that they bear to prove such an affirmative defense at this stage of this litigation. First, Plaintiff's claims are timely under N.Y. C.P.L.R. § 215(8)(a), which provided Plaintiff with one year from the termination of the criminal action again Epstein to file an action. Second, Plaintiffs claims are timely under N.Y. C.P.L.R. § 213-c, which provides rape victims with 20 years to bring an action against the perpetrator. Third, Defendants have failed to meet their burden of showing that Plaintiff will be unable to invoke equitable estoppel and equitable tolling, highly factual doctrines. Finally, Defendants' motion to "dismiss" Plaintiff's demand for punitive damages is procedurally improper and incorrect. The Court should deny Defendants' motion to dismiss in full. + +# STATEMENT OF FACTS + +In 2002, was a 20-year old aspiring model living in South Africa. Compl. 1 38. She had never left the country, but dreamed of becoming a model in New York City. Id. (AI 39, 41. One day, she met ME, an American model visiting South Africa, who offered her the opportunity to meet a man who called the 'al of America" and who could help her + +Plaintiff respectfully requests oral argument pursuant to Individual Rule 2.F. + +achieve her dream of modeling in New York City. M. 1 38. That man was Jeffrey Epstein, who was visiting South Africa with an American government official, an actor, and a comedian. Id. + +Juliette agreed, and met Epstein and his high-profile entourage at a restaurant. Id. 1 39. They invited Juliette to attend the government official's speech the next day, accompanied by a police escort. Id. Epstein asked Juliette to bring her modeling portfolio to his hotel for a "casting," told her that he owned a modeling agency and could get her an agent in New York City, and bragged that he was good friends with Les Wexner, the owner of Victoria's Secret. Id. 1 40. Because of his clear power and relationships with high-profile individuals, Juliette believed him. After assuring Juliette's mother that she would be safe with him, Epstein's employees facilitated her travel to New York City, including by getting her a passport. Id. 11 40-41. + +When Juliette arrived in New York, one of Epstein's employees, called Juliette and told her that she would be traveling to the Caribbean with Epstein on his private plane. M. 1 42. On the flight, Juliette felt terrified and trapped. Id. ¶143-45. Juliette eventually arrived at Epstein's island in the U.S. Virgin Islands ("USVI"), and sent Juliette to Epstein's room for a massage. Id. 1 44. That was when Epstein began sexually assaulting Juliette. Id. During the massages, he would touch her, use massage devices on her, force her to perform oral sex on him, and rape her. Id. She cried herself to sleep each night. Id.1 45. For years, Epstein continued to sexually traffic Juliette. Epstein sexually abused Juliette during each visit, and at all of his homes, including his New York mansion. Id.1 46. + +From the start, Juliette's interactions with Epstein were always defined by his power and control: immediately introducing her to a high-level government official who was traveling with two celebrities and a police escort, and showing her his private plane, numerous mansions, private island, and large staff that he used to give the false impression of legitimacy. Id. 11 39, 42-44. Epstein purposefully displayed photographs of powerful political figures in his mansion to show that he was well-connected and powerful. Id. 1 48. And if that was not clear enough, Epstein specifically told Juliette that he planted drugs on another girl who accused him of rape and had her sent to prison. Id. 1 47. Even after Juliette was able to distance herself from Epstein in 2004, he continued to contact her over the years, and, two months before his death, asked her to send him nude photographs. Id. 11 50, 51. The experiences Epstein subjected her to left Juliette with an eating disorder, debilitating panic attacks, anxiety, and substance abuse issues. Id.1 52. + +After decades of escaping appropriate punishment for his extraordinarily far-reaching and disturbing crimes, Epstein was indicted in July 2019 on one count of sex trafficking conspiracy and one count of sex trafficking. Compl., Ex. A (the "Indictment"). The Indictment specifically described how Epstein recruited victims to come to his New York and Florida mansions to give him massages. Indictment 11 3, 9, 15. During the massages, Epstein "would escalate the nature and scope of physical contact with his victims to include, among other things, sex acts such as groping and direct and indirect contact with the victim's genitals" with his hands or sex toys. Id. 11 9, 15. Afterwards, Epstein and his associates would continue to contact victims to schedule appointments for additional sexual encounters so that he could continue to abuse them. ld.11 11, 17. Juliette's claims arise directly from this scheme of recruitment and sexual assault. + +On August 8, 2019, shortly after Epstein's Indictment, Epstein executed his last will and testament, naming Defendants the executors of his Estate. Compl. 1 30. Two days later, Epstein was found dead in his jail cell. Id.1 31. His last will and testament was filed in the USVI on August 15, 2019. Id.1 32. The U.S. Attorney's Office submitted a proposed none prosequi order and Judge Richard M. Berman dismissed the indictment on August 29, 2019. Id.1 36. Plaintiff filed her Complaint shortly thereafter, on November 14, 2019. + +#### ARGUMENT + +Defendants' motion to dismiss Plaintiff's claims and Plaintiff's request for punitive damages should be denied. "To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face. .. . A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (internal quotation marks omitted). The Court must "accept() all factual allegations in the complaint as true and draw[] all reasonable inferences in the plaintiff's favor." Kashef v. BNP Paribas S.A., 925 F.3d 53, 58 (2d Cir. 2019). + +Drawing all reasonable inferences in Plaintiff's favor, Defendants have failed to meet their burden of proving that Plaintiff's claims are untimely. Further, Defendants' argument that the Court should "dismiss" punitive damages is procedurally improper and substantively incorrect. + +### I. Defendants Have Not Met Their Burden of 1' ro% ilia that Plaintiff's Claims Are Untimely + +Because the statute of limitations is an affirmative defense, Defendants bear the burden of proving that Plaintiff's claims are untimely. See Childers v. New York & Presbyterian Hosp., 36 F. Supp. 3d 292, 301 (S.D.N.Y. 2014). "(A] complaint does not need to anticipate potential affirmative defenses, such as the statute of limitations, and to affirmatively plead facts in avoidance of such defenses." Id. at 315 (internal quotation marks omitted). Accordingly, "dismissal is appropriate only if a complaint clearly shows the claim is out of time." Harris v. City of New York, 186 F.3d 243, 250 (2d Cir. 1999). In this case, Plaintiff's factual allegations demonstrate that (A) her claims are timely under N.Y. C.P.L.R. § 215(8)(a), (B) her claims are timely under C.P.L.R. § 213-c, (C) C.P.L.R. § 202 does not apply to her claims, (D) Defendants are equitably + +estopped from asserting a statute of limitations defense, and (E) the limitations period for bringing her claims was equitably tolled. 2 + +## A. Plaintiff's Claims Are Timely Under N.Y. C.P.L.R. § 215(8Xa). + +Plaintiff's claims fall squarely within N.Y. C.P.L.R. § 215(8)(a), which allowed Plaintiff to file her complaint within a year of the Indictment's dismissal. That provision provides that: + +> Whenever it is shown that a criminal action against the same defendant has been commenced with respect to the event or occurrence from which a claim .. . arises, the plaintiff shall have at least one year from the termination of the criminal action . . . in which to commence the civil action .... + +Id. Plaintiff filed the Complaint within one year of the Indictment's dismissal—her claims are therefore timely. Defendants' only argument to the contrary is that the Indictment did not concern the same event or transaction from which Plaintiff's civil action arose because the Indictment targeted, according to Defendants, some separate sex-trafficking operation that only involved underage girls. Defs.' Mem. at 7 ("Because Plaintiff alleges she was between 20 and 22 years old when Decedent assaulted her (Compl. yq 1, 38, 50), this action and the Indictment necessarily arise from different events or occurrences."). But Defendants mischaracterize § 215(8)(a), the case law, Plaintiff's Complaint, and, most egregiously, the vast sex-trafficking operation that the Indictment targeted. + +2In another victim's action against the Estate, the court recognized that the doctrines of equitable estoppel and equitable tolling are "very fact specific" and accordingly asked Defendants to refrain from filing a motion to dismiss prior to discovery. Transcript of Pre-Motion Conference at 3:4-8, v. Indyke, et at, No. 19-cv- 10475 (LGS) (S.D.N.Y. Mar. 5, 2020), Dkt. 39 ("[T]he doctrines of equitable estoppel and equitable tolling could, nevertheless, save the claims and make them timely and that is very fact specific, or early in the case I presumed there will be factual issues around those questions ...."). + +#### 1. The Indictment Was Not Restricted to Minors. + +As an initial matter, the Indictment covered the crimes Defendants committed against Plaintiff, notwithstanding the fact that she did not allege that she was a child when they occurred. Defendants seek to minimize the scope of the abuse alleged in the Indictment by focusing on its reference to "minors." Defs.' Mem. at 7, 9-10. But clinging to the use of the word "minors" does not change the nature of the vast and sophisticated operation alleged in the Indictment. Epstein's pattern and practice was to recruit and traffic young females that he knew he could exploit, and the Indictment spells out that pattern. Age is not the deciding factor as to whether a female was a victim of Epstein's sex-trafficking operation and the patterns of recruitment and abuse described in the Indictment. And the fact that many of the victims were minors does not mean that non-minors were not also victimized by Epstein's sophisticated sex-trafficking operation. Indeed, the Indictment states that "many" of Epstein's victims were minors, demonstrating that prosecutors were investigating Epstein's crimes against young women over the age of 18 as well. Indictment ¶ 11 ("[Epstein] knew that many of his New York victims were underage."); id. ¶ 17 ("JEFFREY EPSTEIN, the defendant, knew that certain of his victims were underage ...." (emphasis added)).3 + +The mere fact that Plaintiff did not allege that she was a minor at the time that she was recruited into Epstein's sex-trafficking scheme does not negate the fact that Plaintiff's civil claims arise from the acts described in the Indictment. Plaintiff therefore had one year from August 29, + +3The FBI confirmed this understanding of the Indictment's scope in a press release issued two days after Epstein's arrest, stating to Epstein's victims: "We want to hear from you, regardless of the age you are now, or whatever age you were then, no matter where the incident took place." https://www.justice.gov/usao-sdny/pr/jeffrey-epstein-charged-manhattan-federal-court-sextrafficking-minors (last visited March 30, 2020) (emphasis added). + +2019, the date on which Judge Berman formally dismissed the Indictment, to file the Complaint. Having filed suit on November 14, 2019, her claims fall well within that limitations period. + +### 2. Plaintiff's Claims Concern the Same Sex-Trafficking Operation that the Indictment Concerned. + +Even if the Indictment was for some reason limited to Epstein's trafficking of minors (to the exclusion of other victims), Plaintiffs claims would nonetheless arise from the same "event or occurrence" for the purposes of § 215(8)(a). See, e.g., Kashef, 925 F.3d at 62 (noting that "a New York appellate court explicitly rejected the theory that the tolling provisions of CPLR 215(8) are exclusively for the benefit of the victims of the crime charged in the criminal proceeding" (internal quotation marks omitted)). Contrary to Defendants' suggestion, the Court should not construe the Indictment "narrowly," Defs.' Mem. at 7, where the Indictment itself describes a pattern of abuse against numerous victims spanning a number of years. Epstein repeated the same patterns of recruitment and abuse time and time again on countless young females, including Plaintiff. See, e.g., Indictment ¶ 7 (explaining that Epstein "perpetuated [the] abuse in similar ways" against victims). The Indictment was therefore not limited to neatly categorized events that happened on specified dates—it covered a sprawling sex-trafficking operation that occurred "over the course of many years" and affected an unspecified number of victims. Id. 1 I. + +Defendants' contention that the Indictment does not concern the same sex-trafficking operation that victimized her is incorrect. Defs.' Mem. at 9-10. The sex-trafficking operation that the Indictment described is precisely the same sex-trafficking operation that Plaintiff was lured into. Just as the Indictment alleged that Epstein enticed and recruited females to engage in sex acts with him in multiple locations, Indictment1 1, Epstein enticed and recruited Plaintiff to engage in sex acts with him in New York, the USVI, France, Florida, and New Mexico. Compl. 11 25, 55. Just as the Indictment alleges that the abuse would start out with the victim performing a + +massage on Epstein, Indictment ¶¶ 9, 15, Plaintiff's abuse started when sent her to massage Epstein. Compl. 1 44. The Indictment alleges that Epstein would escalate the nature and scope of physical contact during the massages to include sex acts such as groping and touching victims with sex toys, Indictment 11 9, 15, and Epstein escalated the nature and scope of Plaintiff's massages to include touching her and using massage devices on her, among other things. Compl. 1 44. And, finally, just as Epstein or his employees would contact victims to schedule their return to his home for additional sexual encounters, Indictment 1 11, Epstein contacted Plaintiff many times to arrange for her to travel back to the United States for sex. Compl. 1 46. The conduct alleged in the Indictment is precisely the conduct alleged in the Complaint. + +# 3. Defendants' Attempts to Narrow the Scope of C.P.L.R. § 215(8)(a) Fail. + +Defendants seek to advance a strained interpretation of § 215(8)(a)'s "event or occurrence" requirement, asserting that this Court must "apply C.P.L.R. § 215(8)(a) narrowly" to limit its availability to the crimes committed against the specific victims identified in the Indictment. Defs.' Mem. at 7. But § 215(8) "is a remedial measure intended to alleviate victims of crime from the strict and arbitrary nature of the statute of limitations and to make it easier for such victims to obtain civil redress for the criminal wrongs that they have endured." LaRocca v. Callen IP, No. 08 Civ. 6274, 2009 WL 10435869, at \*2 (S.D.N.Y. May 6, 2009). New York courts "are instructed to give broad and liberal construction to remedial statutes" like § 215(8). Id. Defendants' narrow interpretation of § 215(8)(a) "would frustrate the Legislature's goal of making it easier for victims of crimes to obtain civil redress for the criminal wrongs that they have endured." Id. + +Further, the cases that Defendants cite to narrow § 215(8Xa)'s scope are inapposite. The criminal actions in those cases focused on crimes that occurred on specified dates and both cases explicitly recognized that the relevant criminal prosecutions were commenced "only in connection with the events of these [specific] days." See Christodoulou v. Terdeman, 262 A.D.2d 595, + +595-596 (2d Dep't 1999) (criminal prosecution against defendant commenced only in connection with events on two specific days); Gallina v. Thatcher, No. 2017-52980, 2018 N.Y. Misc. LEXIS 8435, at \*3-4 (Sup. Ct. Oct. 23, 2018) (plaintiff sued for assault and battery that occurred over the course of two years but the indictment "charged [the defendant] for incidents occurring on three (3) specific dates"). By contrast, the Indictment in this case was not limited to a specific day or discrete event. Rather, the Indictment covered sexual abuse that occurred "over the course of many years." Indictment ¶¶ 1-2, 8, 20, 24. Further, the Indictment charged Epstein with conspiracy and a broad sex-trafficking scheme, while the criminal actions in Christodoulou and Gallina charged the defendants with crimes stemming from isolated incidents.° + +In contrast, the Second Circuit's opinion in Kashef controls and demonstrates why Plaintiff's claims fall within § 215(8)(a) here. In Kashef, BNP Paribas ("BNPP") entered a guilty plea conceding "knowledge of the atrocities being committed in Sudan and of the consequences of providing Sudan access to U.S. financial markets." Kashef, 925 F.3d at 56. The plaintiffs, Sudanese victims of mass rape, torture, deliberate infection with HIV, and other atrocities, filed a complaint against BNPP within a year of the judgment of conviction, contending that their claims were timely under C.P.L.R. § 215(8)(a). Id. at 57, 62-63. BNPP attempted to argue—similar to Defendants' argument here—that § 215(8)(a) did not apply because the plaintiffs "played no role in the proceedings surrounding BNP Paribas's plea agreement," the criminal action "required no investigation of or briefmg on any injuries sustained by Plaintiffs," and the facts in the criminal + +4Defendants also cite McElligott v. City of New York, No. 15 CIV. 7107 (LGS), 2017 WL 6210840, at \*5 (S.D.N.Y. Dec. 7, 2017), but that case is inapplicable because it hinged on whether the defendant in the civil action was the same defendant charged in the criminal action. + +case and the civil case were not "identical." Brief of Defendants-Appellees at 51-52, Kashef v. BNP Paribas S.A., No. 18-1304 (2d Cir. Aug. 9, 2018), Dkt. 92. + +The Second Circuit rejected BNPP's argument, and instead found that the "event or occurrence" for § 215(8) purposes was more generally "BNPP's conspiracy with Sudan to violate U.S. sanctions" for humanitarian violations. 925 F.3d at 62-63. The court therefore held that the victims of those humanitarian violations could bring timely claims under § 215(8)(a). Id. That conspiracy, like the one here, was a broad scheme spanning many years, rather than a single event (such as an assault on a specified date). Just as BNPP's conspiracy to violate sanctions was the relevant event or occurrence in Kashef, Epstein's widespread sex-trafficking scheme is the event or occurrence at issue in Plaintiff's case for the purposes of applying § 215(8)(a). Defendants attempt to distinguish Kashef by pointing out that "the civil and criminal actions in that case both arose out of the same conspiracy between BNP and Sudan to violate U.S. sanctions," Defs.' Mem. at 10, but that fact only highlights Kashefs applicability to this case, which also involves a civil action and a criminal action arising from the same conspiracy. Defendants have failed to meet their burden of proving that Plaintiffs claims do not arise from the same event or occurrence as the Indictment, and therefore that § 215(8)(a) does not apply to her claims.5 + +# B. Plaintiff's Claims are Timely Pursuant to N.Y. C.P.L.R. § 213-c. + +Plaintiff's claims are also timely under N.Y. C.P.L.R. § 213-c, which provides that: + +Notwithstanding any other limitation set forth in this article, . . . all civil claims or causes of action brought by any person for physical, psychological or other injury or condition suffered by such person + +5 Defendants argue that a broad construction of § 215(8)(a) would make the "event or occurrence" language "meaningless." Defs.' Mem. at 9. But Plaintiff does not ask the Court to disregard the "event or occurrence" limitation. Rather, she contends that the "event or occurrence" in this case is a sex-trafficking scheme, not the abuse of a delineated victim, and that because she was a victim of that sex-trafficking scheme, her claims arise from it. + +as a result of conduct which would constitute rape in the first degree as defined in section 130.35 of the penal law, . . . may be brought ... within twenty years. + +N.Y. C.P.L.R. § 213-c, Plaintiff alleges that Epstein sexually assaulted her multiple times within 20 years of the filing of this lawsuit, and that the assaults constituted one or more sex crimes listed in § 213-c. Compl. IN 44, 56. Her claims are therefore timely under § 213-c. + +Defendants contend that the 20-year statute of limitations of § 213-c does not apply to Plaintiff's claims because it was adopted in 2019 and does not apply retroactively. Defs.' Mem. at 10-12. But New York "[c]ourts have employed customary tools of construction to find the requisite intent to give retroactive effect to new laws affecting periods of limitation." McGuirk v. City Sch. Dist. of Albany, 116 A.D.2d 363, 365 (3d Dep't 1986). Using those tools, New York courts have held that certain amendments to limitations periods apply retroactively. See, e.g., Meegan S. v. Donald T., 475 N.E.2d 449, 450 (N.Y. 1984) ("[T]he enlargement of the Statute of Limitations for paternity suits is to be applied retroactively."). + +Contrary to Defendants' argument, the text and legislative history of § 213-c demonstrate the New York Legislature's intent for it to apply retroactively. The bill's legislative history highlights the "ticking clock" that the former statute of limitations imposed on victims of sexual abuse: "For crimes of sexual violence in particular, the clock ticks against the trauma and culture of silence that prevents victims from speaking out. Over the last year, victims who have suffered in silence for decades have bravely spoken about their abuse .. . ." N.Y. Comm. Rep., 2019 N.Y. S.B. No. 6574, 242nd Legis. Sess. (June 17, 2019). The Legislature's explicit reference to "victims who have suffered in silence for decades," like Plaintiff, and victims that have been prevented + +6"A person is guilty of rape in the first degree when he or she engages in sexual intercourse with another person ... [b]y forcible compulsion." N.Y. Penal Law § 130.35. + +"from speaking out," also like Plaintiff, evince an intent for the provision to apply retroactively to victims like Plaintiff. In light of the legislative goals behind the amendment to § 213-c, the Court should hold that it applies retroactively to Plaintiff's claims. + +Moreover, "remedial legislation should be given retroactive effect in order to effectuate its beneficial purpose." In re Gleason (Michael Vee, Ltd.), 749 N.E.2d 724, 726 (N.Y. 2001). In citing N.Y. Stat. Law § 51 for the proposition that statutes are construed as applying only prospectively, Defendants wholly ignore § 54, which explicitly states that "[r]emedial statutes constitute an exception to the general rule that statutes are not to be given a retroactive operation." The primary case the Defendants cite also recognizes that remedial statutes are given retroactive effect. See Deft.' Mem. at 11 (citing Gleason v. Holman Contract Warehousing, Inc., 649 N.Y.S.2d 647, 651 (Sup. Ct. 1996) (recognizing that whether statute is remedial "does greatly impact upon the decision as to whether or not the new statute should be held to be retroactive")). + +Legislative history establishes that the amendment to § 213-c was remedial in nature—it extended the statute of limitations for certain sexual offenses in order to correct the injustice that the shorter limitations period imposed on victims. See Coffinan v. Coffinan, 60 A.D.2d 181, 188 (2d Dep't 1977) ("Remedial statutes are those designed to correct imperfections in prior law, by generally giving relief to the aggrieved party." (internal quotation marks omitted)); see also Meegan S., 475 N.E.2d at 450 (finding that amendment extending statute of limitations in paternity suits was remedial legislation); leaders-times-movement-signs-legislation-extending-rape-statute (last visited March 30, 2020) ("This new law recognizes the injustice that has gone on for far too long . . ."). "[I]nsofar as remedial statutes are concerned, the court should consider the mischief sought to be remedied and should favor the construction which will suppress the evil and advance the remedy." Burrows + +v. Bd. of Assessors for Town of Chatham, 98 A.D.2d 250, 253 (3d Dep't 1983) (internal quotation marks and citations omitted), aff'd, 473 N.E.2d 748 (N.Y. 1984). The remedial purpose of the amendment to § 213-c, to correct the injustice of providing rape victims who were prevented from speaking out with only five years to bring actions, would be undermined if the amendment were only applied prospectively. Plaintiff's claims are therefore timely under § 213-c. + +### C. N.Y. C.P.L.R. § 202 Does Not Apply to Plaintiff's Claims. + +By its express terms, New York's borrowing statute, N.Y. C.P.L.R. § 202, only applies to "rain action based upon a cause of action accruing without the state." Contrary to Defendants' argument, § 202 does not apply to or bar Plaintiff's claims for three independent reasons. + +## I. Statutory Interpretation Precludes the Application of C.P.L.R. § 202. + +Under principles of statutory interpretation, § 202 does not apply. In both § 215(8)(a) and § 213-c, both of which apply to Plaintiff's claims as argued above, the New York Legislature included language that explicitly precludes § 202's application. Section 215(8)(a) specifically states that a plaintiff has one year after an indictment's dismissal to assert her claims, "notwithstanding that the time in which to commence such action has already expired." (Emphasis added). That the Legislature intended to afford plaintiffs the ability to pursue civil actions in connection with a prosecuted crime, even if the statute of limitations had expired, is clear and unambiguous, and the Court need go no further to find that § 215(8)(a) precludes the application of § 202. N.Y. Stat. Law § 76 ("Where words of a statute are free from ambiguity and express plainly, clearly and distinctly the legislative intent, resort may not be had to other means of interpretation."); see also Clemens v. Nealon, 202 A.D.2d 747, 749 (3d Dep't 1994) (citing Stat. Law § 76 and finding that § 215(8) is clear and unambiguous). + +Similarly, § 213-c provides that victims of certain criminal sexual acts have 20 years to assert a cause of action, "[n]otwithstanding any other limitation set forth in" Article 2, and § 202 + +is a limitation set forth in Article 2. (Emphasis added). Under the unambiguous language of § 215(8)(a) and § 213-c, Plaintiff's claims would be timely even if § 202 would otherwise render Plaintiff's claims untimely under the statute of limitations of another jurisdiction. + +### 2. Plaintiff's Claims Did Not Accrue "Without the State" of New York. + +Section 202 only applies to claims "accruing without the state." Defendants wholly ignore the concept of accrual, and argue that because Plaintiff was sexually assaulted in many places, her claims must fall within the limitations periods of all of the jurisdictions in which Epstein ever harmed her. Defs.' Mem. at 4-5. This is incorrect. As an initial matter, Defendants' arguments on this point concede that Plaintiff's claims are timely when based on the multiple assaults Plaintiff suffered in the state of New York. See Compl. ¶ 46 ("Epstein forced her to travel to the United States many times to see Epstein and be subjected to repeated sexual abuse for one to two weeks at a time, sometimes staying in his New York apartment."). And as to the instances where Plaintiff was raped or abused in other locations, those crimes still accrued inside the state, as they were planned and initiated in New York, which served as the epicenter of Epstein's sex-trafficking conspiracy. For example, Epstein and his co-conspirators lured Plaintiff to New York, and it was from New York that Epstein sent Plaintiff to other locations to be abused. See id. ¶ 41 ("Epstein called Juliette's mother from New York to assure her that Juliette would be safe with him in New York."); id. ¶ 42 ("Shortly after arriving at the apartment, , another one of Epstein's co-conspirators, called and told Juliette that Juliette was going to the Caribbean."). + +### 3. Plaintiff's Residency When the Cause of Action Accrued Is a Factual Issue. + +Finally, § 202 does not apply if the plaintiff is a New York resident, and the controlling date for determining a plaintiff's residence is the date on which the cause of action accrued, not the date on which the action was commenced. See, e.g., DeMartino v. 148 A.D.2d 568, + +570 (2d Dep't 1989). "[Tjhe determination of whether a plaintiff is a New York resident, for purposes of CPLR 202, turns on whether [she] has a significant connection with some locality in the State as the result of living there for some length of time during the course of a year." Antone v. Gen. Motors Corp., 473 N.E.2d 742, 746 (N.Y. 1984). The Complaint alleges that Plaintiff was a New York resident at all relevant times, as she had always wanted to live in New York, Epstein's co-conspirators got Plaintiff a visa so that she could travel to New York often, and when she visited she stayed at Epstein's New York home for one to two weeks at a time. Comp1.1 39 ("Juliette considered meeting Epstein an amazing opportunity because modeling in New York City had always been one of her biggest dreams"); 1 41 ("Groff told Juliette that Epstein wanted to bring her to New York City to model" and "Epstein called Juliette's mother from New York to assure her that Juliette would be safe with him in New York."); 1 46. Whether Plaintiff can establish that she was a New York resident at the time her cause of action accrued is a factual issue. In fact, in each of the cases Defendants cite in contending that Plaintiff was not a New York resident at the time her cause of action accrued (two of which did not address § 202), the residency determination was made after fact-finding on the issue. See Antone, 473 N.E.2d at 745 (hearing held on residence); Siegfried v. Siegfried, 92 A.D.2d 916, 916 (2d Dep't 1983) ("residency hearing" held in connection with motion to transfer venue); Hammerman v. Louis Watch Co., 7 A.D.2d 817, 818 (3d Dep't 1958) (relying on affidavits in connection with motion to transfer venue). + +### D. Defendants Have Not Met Their Burden of Proving that Plaintiff Cannot Invoke Equitable Estoppel. + +Even if the Court were to hold that C.P.L.R. § 215(8)(a) and § 213-c do not apply to Plaintiff's claims, or that § 202 does, it should hold that they are still timely under the doctrine of equitable estoppel. The Complaint alleges in detail the methods of intimidation and control that Jeffrey Epstein and his co-conspirators used to deter their victims from seeking justice, and the + +scare tactics that he used on Plaintiff. Due to Epstein's conduct, Plaintiff did not take action until after she knew that Epstein was dead, and timely filed her claim approximately three months later. + +Defendants' contend that the doctrine of equitable estoppel applies only to situations in which the defendant makes a misrepresentation of fact. Defs.' Mem. at 13-14. But "courts have long had the power, both at law and equity, to bar the assertion of the affirmative defense of the Statute of Limitations where it is the defendant's affirmative wrongdoing—a carefully concealed crime here—which produced the long delay between the accrual of the cause of action and the institution of the legal proceeding." Gen. Stencils. Inc. v. Chiappa, 219 N.E.2d 169, 171 (N.Y. 1966). A defendant is therefore equitably estopped from asserting a statute of limitations defense if the defendant "wrongfully induced the plaintiff to refrain from timely commencing an action by deception, concealment, threats or other misconduct." Funk v. Belneftekhim, No. 14-CV-0376 (BMC), 2019 WL 3035124, at ■2 **(E.D.N.Y. July 11, 2019) (citation omitted) (emphasis added).** + +**Assuming the truth of the allegations in Plaintiff's Complaint and drawing all inferences in her favor, Plaintiff has sufficiently pleaded misconduct that should equitably estop Defendants from asserting a statute of limitations defense. Plaintiff was terrified of disobeying Epstein. Compl. 11 43-44, 47-48. Defendants' claim that Plaintiff has not alleged "any conduct" by Epstein beyond trying to keep into contact with her is incorrect—Epstein** expressly told Plaintiff that he had a rape victim sent to prison. Defs.' Mem. at 14; Compl. 1 47. Epstein also flaunted his connections to powerful government officials, introduced her to a high government official and two celebrities while accompanied by a police escort, kept nude photographs of her, and continued to harass her via email up until he died. Compl. 11 39-40, 42, 45, 47-51. + +Plaintiff's allegations are more than sufficient to allow her claims to proceed under an equitable estoppel theory at this early stage of the litigation. And even if they were not, Plaintiff + +was not required to "affirmatively plead facts in avoidance of Defendants' statute of limitations defense. Childers, 36 F. Supp. 3d at 315 (internal quotation marks and citation omitted). Further, "[w]hether equitable estoppel applies in a given case is ultimately a question of fact." Kosakow v. New Rochelle Radiology Assocs., P.C., 274 F.3d 706, 725 (2d Cir. 2001). Courts applying New York law have therefore reserved the highly factual issue of equitable estoppel for after discovery. See, e.g., Gotlin v. Lederman, No. 05-CV-1899 (ILO), 2006 WL 1154817, at \*13 (E.D.N.Y. Apr. 28, 2006) ("A vast majority of the cases on equitable estoppel permit plaintiffs to defeat a motion to dismiss on the pleadings, deferring the question until some discovery can be had."). + +For example, Defendants unilaterally conclude that Plaintiff's state of mind of fearing the man behind a transcontinental sex-trafficking operation who (1) manipulated and assaulted her and countless other victims for years, (2) specifically told her that he could have his accusers sent to jail, (3) introduced her to a former government official and two celebrities the very first time they met, and (4) used power to escape punishment for crimes committed over decades is "unextraordinary." Defs.' Mem. at 14. Whether Plaintiffs' state of mind was "extraordinary" is a factual issue that should be decided after discovery, not by Defendants. Defendants have failed to meet their burden of proving that Plaintiff can prove no set of facts demonstrating her entitlement to equitably estopping Defendants from asserting a statute of limitations defense. + +#### E. Defendants Have Not Met Their Burden of Proving that Plaintiff Cannot Invoke Equitable Tolling. + +Plaintiff's claims are also timely under the doctrine of equitable tolling. While equitable estoppel focuses on a defendant's affirmative misconduct, equitable tolling focuses on the plaintiff and applies as a matter of fairness where the plaintiff has been "prevented in some extraordinary way from exercising [her] rights." Flight Set, Inc. v. Cathay Pac. Airways Ltd., 647 F. Supp. 2d + +285, 289 (S.D.N.Y. 2009) (internal quotation marks and citations omitted). In this case, Plaintiff's fear of retaliation prevented her from filing her claims prior to Epstein's death. + +Defendants' contention that Plaintiff has not alleged any compelling circumstances justifying equitable tolling is incorrect. Defs.' Mem. at 12-13. A "reasonable fear of retaliation may be sufficient to constitute extraordinary circumstances warranting equitable tolling, particularly if the person threatening retaliation is a defendant." v. No. 15-cv-5359, 2016 WL 5720811, at \*11 (S.D.N.Y. Sept. 30, 2016). In =, the court reasoned that fear of retaliation could support equitable tolling in the prison context because "sustained control tends to result in adverse psychological effects that invariably have behavioral consequences" and that "fear of retaliation [is a] natural consequence() of this unique psychological environment." Id. at \*10 (internal quotation marks omitted). + +Epstein's pattern of controlling, manipulating, and intimidating his victims caused similar psychological effects in his countless victims as described in And Plaintiff alleges that Epstein's abuse and psychological manipulation had such effects on her. Compl. fl 4448, 52-53. The Court should therefore extend equitable tolling to reach fear of retaliation in the context of Epstein's unprecedented abuse of and control over his victims, including Plaintiff. + +In any event, as with equitable estoppel, "when plaintiffs raise an equitable tolling argument, a court must deny a motion to dismiss based on the statute of limitations unless all assertions of the complaint, as read with required liberality, would not permit the plaintiffs to prove that this statute was tolled." In re S. African Apartheid Litig., 617 F. Supp. 2d 228, 287 (S.D.N.Y. 2009) (internal quotation marks omitted). Plaintiff's allegations are sufficient to defeat a motion to dismiss and to proceed to discovery on the issue of equitable tolling. See, e.g., v. Parkchester S. Condos., 287 F.3d 58, 60-61 (2d Cir. 2002) (evidentiary hearing appropriate to determine whether limitations period was equitably tolled); Guobadia v. Irowa, 103 F. Supp. 3d 325, 341 (E.D.N.Y. 2015) (equitable tolling "is a question appropriately reserved for a jury" due to "genuine issues of material fact"). Defendants are not factfinders in this case and cannot decide whether the circumstances of Epstein's sex-trafficking operation are "extraordinary" enough to warrant tolling. They have failed to meet their burden of proving that Plaintiff can prove no set of facts demonstrating entitlement to equitable tolling. + +#### II. The Court Should Deny the Defendants' Motion to Dismiss Punitive Damages. + +Defendants' argument that Plaintiff's claim for punitive damages fails as a matter of law is incorrect. Not only are such damages available, they are warranted in this case. Beyond the procedural impropriety of Defendants' purported motion to dismiss punitive damages—that on its own warrants its denial—under New York choice-of-law principles the law of the USVI applies to the issue of punitive damages. Under USVI law, a court may allow for punitive damages against the estate of a deceased tortfeasor, especially when that tortfeasor went to great lengths during his life to avoid punishment for causing immeasurable harm to countless victims. + +### A. Defendants' Motion to Dismiss Pu nit is L. Damages is Procedurally Improper. + +As an initial matter. the Court should not decide whether punitive damages are available at this early stage. A motion to dismiss is not the proper vehicle for determining the availability of punitive damages. Rule 12(b)(6) allows a defendant to file a motion to dismiss for "failure to state a claim upon which relief can be granted." Fed. R. Civ. P. 12(b)(6). Accordingly, "[a] motion to dismiss is addressed to a `claim'—not to a form of damages." v. City of New York, No. 18-CV-1937 (VSB), 2020 WL 1644009, at \*17 (S.D.N.Y. Apr. 2, 2020) (internal quotation marks omitted). Defendants' request for the Court to dismiss Plaintiff's demand for punitive damages does not relate to whether Plaintiff has failed to state a claim for battery or intentional infliction of emotional distress. Addressing the issue of punitive damages at this stage would therefore be premature. See, e.g., Denton v. McKee, 332 F. Supp. 2d 659, 667 (S.D.N.Y. 2004) (finding "any discussion of damages, compensatory, punitive or otherwise, to be premature" at the motion to dismiss stage). And Defendants' argument that punitive damages are prohibited by law does not make their "motion to dismiss" a form of damages proper. M, 2020 WL 1644009, at \*17 (holding that although punitive damages are not available against government entities, motion to dismiss punitive damages was premature). + +# B. Plaintiff May Recover Punitive Damages in this Case. + +Even if a motion to dismiss punitive damages was an adequate way to address this issue, Defendants' motion still fails. Plaintiff may recover punitive damages because the USVI has the strongest interest in whether punitive damages are available in this case' And, under USVI law, Plaintiff can recover punitive damages. + +## I. USVI Law on Punitive Damages Governs This Case. + +Federal courts look to the choice-of-law rules of the forum state in deciding choice-of-law disputes. See Klaxon Co. v. Stentor Elec. Mfg. Co., 313 U.S. 487, 4% (1941). "In the context of tort law, New York utilizes interest analysis to determine which of two competing jurisdictions has the greater interest in having its law applied in the litigation. The greater interest is determined by an evaluation of the facts or contacts which relate to the purpose of the particular law in conflict." Padula v. Lilarn Prop. Corp., 644 N.E.2d 1001, 1002 (N.Y. 1994) (internal quotation marks and alterations omitted). New York courts seek "Wustice, fairness and the best practical result." Babcock v.=I, 191 N.E.2d 279, 283 (N.Y. 1963). + +7As explained below, under the doctrine of depecage New York law still governs as to the underlying claims and as to compensatory damages. + +"Punitive damages are conduct regulating," and "[u]nder the doctrine of depecage, then, the choice-of law analysis for punitive damages is distinct from the analysis for compensatory damages." Nat'l Jewish Democratic Council v. Adelson, 417 F. Supp. 3d 416, 425-26 (S.D.N.Y. 2019). "[U]nder New York law—for punitive damages in particular—a court must consider the object or purpose of the wrongdoing to be punished and give controlling weight to the law of the jurisdiction with the strongest interest in the resolution of the particular issue presented." Id. at 426 (internal quotation marks and alterations omitted). "[T]he choice-of-law inquiry for punitive damages provisions is necessarily `defendant-focused."' Id. + +In this case the USVI has a stronger interest in the resolution of whether punitive damages can be awarded in this case than New York, Florida, New Mexico, or France.\* In addition to flying Plaintiff to the USVI and sexually assaulting her there, Compl. l 42-44, Epstein was domiciled in the USVI. Id. 1 19; see also v. Boy Scouts of Am., Inc., 65 N.Y.2d 189, 201 (1985) (holding that, although New York was the place of the wrong, New Jersey law applied because it "would further [New Jersey's] interest in enforcing the decision of its domiciliaries to accept the burdens as well as the benefits of New Jersey law). Epstein also had a private island in the USVI, where he abused countless young females, including Plaintiff. Compl. IN 24, 44. Defendants then chose to probate his Estate in and under the laws of the USVI. M.132. Having availed themselves of all the benefits and protections that USVI probate and estate law have to offer, Defendants + +To the extent Defendants rely on Judge Engelmayer's recent decisions in Mary Doe v. Indyke et at, 19-cv-10758 (PAE) (DCF) (S.D.N.Y. Apr. 28, 2020) and Jane Doe 15 v. Indyke, et at, 19-cv-10653 (PAE) (DCF) (S.D.N.Y. Apr. 30, 2020), those cases are easily distinguishable. Neither of the victims in those cases was injured in the USVI. Here, not only was Epstein domiciled in the USVI and his Estate probated in the USVI, but he flew Plaintiff to the USVI and injured her there on numerous occasions. Compl. 1 55. + +cannot also seek to escape its drawbacks. New York, Florida, New Mexico, and France have no conceivable interest in denying the USVI from advancing that interest. As such, New York's choice-of-law rules dictate the application of USVI law to the issue of punitive damages.' + +### 2. USVI Law Would Allow for Punitive Damages against Defendants. + +USVI law would allow for an award of punitive damages in this case. When determining how best to apply common law, courts in the USVI apply what is known as the Banks analysis. See Gov't of the V.I. v. =, 60 V.I. 597, 600, 602 (2016); Banks v. Intl Rental & Leasing Corp., 55 V.I. 967, 979 (2011). Under the Banks analysis, "instead of mechanistically following the Restatements, courts should consider three non-dispositive factors to determine Virgin Islands common law: (1) whether any Virgin Islands courts have previously adopted a particular rule; (2) the position taken by a majority of courts from other jurisdictions; and (3) most importantly, which approach represents the soundest rule for the Virgin Islands." M, 60 V.I. at 600 (internal quotation marks omitted). Applying the Bat analysis, Plaintiff can pursue punitive damages against Defendants. + +#### a. Banks Factor One: Whether Any USVI Courts Have Adopted a Rule + +USVI courts have not adopted a rule as to whether a plaintiff can pursue punitive damages against the estate of a deceased tortfeasor. And Defendants' position that "USVI courts have favorably recited the Restatement's rule precluding punitive damages against a decedent tortfeasor's estate" is simply wrong. Defs.' Mem. at 18. First, the Restatement's position is + +As an indication of the Virgin Islands' interest in matters concerning Epstein's Estate, the Attorney General of the United States Virgin Islands filed suit against the Estate on January 15, 2020, seeking, among other things, punitive damages. Complaint, GVI v. Estate of Jeffrey E. Epstein, No. ST-20-CV-014 (V.I. Sup. Ct. Jan. 15, 2020), Dkt. No. 1. + +included only in commentary, and not the text of the Restatement itself. Restat. (Second) of Torts § 908 cmt. a. Second, in both of the cases that Defendants cite, the issue before the court was whether punitive damages are available in wrongful death actions, and therefore whether an estate can recover punitive damages, not whether punitive damages are available against an estate. See, e.g., v. Dowson Holding Co., 51 V.I. 619, 628 (D.V.I. 2009); Booth v. Bowen, No. CIV. 2006-217, 2008 WL 220067, at \*5 (D.V.I. Jan. 10, 2008). Defendants have not cited a single USVI case adopting the Restatement's commentary's position on that specific issue, or addressing that issue at all. Given the lack of any rule in the Virgins Islands, this Banks factor is neutral. + +### b. Banks Factor Two: The Position Taken by a Majority of Courts from Other Jurisdictions + +As to the second Banks factor, Defendants overstate the number of jurisdictions that do not permit the award of punitive damages against an estate. Defs.' Mem. at 19. Numerous courts have held that plaintiffs may recover punitive damages against the estate of a deceased tortfeasor. See, e.g., Haralson v. Fisher Surveying, Inc., 31 P.3d 114, 117 (Ariz. 2001) (concluding that "there are situations in which it would be appropriate, and perhaps even necessary, to express society's disapproval of outrageous conduct by rendering such an award against the estate of a deceased tortfeasor" (internal quotation marks omitted)); Tillett v. Lippert, 909 P.2d 1158, 1162 (Mont. 1996); v. Melton, 299 S.E.2d 8, 12 (W. Va. 1982). Those courts have reasoned that punitive damages do not only serve to punish wrongdoers, but also to "motivate others not to engage in similar action in the future." Kaopuiki v. Kealoha, 87 P.3d 910, 928 (Haw. Ct. App. 2003).10 In + +to See also, e.g., Ellis v. Zuck, 546 F.2d 643, 644-45 (5th Cir. 1977) (punitive damages allowed against estate because they provide "deterrents to others similar) from taking steps of the character condemned"); Estate of Farrell ex reL Bennett v. , 770 A.2d 517, 521-22 (Del. 2001); Hofer v. Lavender, 679 S.W.2d 470, 474 (Tex. 1984). + +this case, general deterrence is of the utmost importance—Epstein spent decades abusing countless young women and girls, intimidating them into silence, and gaming the justice system with his wealth and power to avoid punishment. No person should be able to commit such acts while at the same time considering himself to be above the law. + +Further, in a case that Defendants cite, see Defs.' Mem. at 19, the court recognized that punitive damages might be available where, as here, the deceased tortfeasor takes his own life "as an escape from punitive damages." Crabtree ex. Rel. Kemp v. Estate of Crabtree, 837 N.E.2d 135, 139 (Ind. 2005) ("If we ever encounter a case where a tortfeasor seems to have considered his own death as an escape from punitive damages incident to some intentional tort, we can address that issue at that time."). Again, Epstein spent his life avoiding proportionate punishment for his countless crimes, and once he was finally imprisoned pending trial for his sex-trafficking operation, he signed his will and then almost immediately caused his own demise. See Compl. 11 8,14,30,31. Given the unique facts surrounding Epstein's crimes and death and the importance of general deterrence, the second Banks factor weighs heavily in favor of allowing for punitive damages under these facts. + +# c. Banks Factor Three: The Soundest Rule for the USVI + +Although none of the three Banks factors is dispositive, the third factor—"which approach represents the soundest rule for the Virgin Islands"—is the most important. See , 60 V.I. at 600. Defendants cite seven cases to support the proposition that USVI courts have found that the Restatement is the soundest rule for the USVI, Defs.' Mem. at 19-20, but not one of those cases addresses the question of whether punitive damages are available against an estate, nor do they consider the Restatement's position on that point. + +Instead, the soundest rule for the USVI is to allow for punitive damages against an estate in circumstances as extraordinary as those in this case. The USVI has expressly recognized the dual purpose of punitive damages to both punish wrongdoing and promote general deterrence. See, e.g., Guardian Ins. Co. v. Gurnbs, No. ST-15-CV-195, 2016 WL 9525609, at \*10 (V.I. Super. Aug. 22, 2016) ("[A] primary purpose behind punitive damages [is] . . . to further deter [the tortfeasor] and others like him from similar conduct in the future."). Allowing punitive damages in this case would be consistent with this view—punitive damages would deter other predators I tun manipulating the justice system and silencing victims of sexual abuse to avoid punishment. The absence of any USVI case adopting the Restatement's commentary about punitive damages against estates, coupled with the extraordinary nature of Epstein's transcontinental sex-trafficking enterprise, suggest that allowing for punitive damages in this case would be the soundest rule for the USVI." The Court should therefore deny Defendants' motion to dismiss punitive damages. + +# CONCLUSION + +For the foregoing reasons, the Court should deny Defendants' Motion to Dismiss Plaintiff's Complaint. Because Defendants seek to dismiss Plaintiff's Complaint in full, Plaintiff requests oral argument on Defendants' motion. + +To the extent necessary, United States courts may certify questions to the Supreme Court of the Virgin Islands if there is "a question of law which may be determinative" and if "it appears there is no controlling precedent in the decisions of the Supreme Court." Banks, 55 V.I. at 972 (internal citations omitted). Because the issue would be a matter of first impression in the Virgin Islands, and given the split in common law authorities concerning the availability of punitive damages against a deceased tortfeasor's estate, the Court should certify the question to the Supreme Court of the Virgin Islands if it deems it necessary to resolve the issue at this stage of the case. See CIT Bank N.A. v. Schiffinan, 948 F.3d 529, 537 (2d Cir. 2020), certified question accepted, No. 36, 2020 WL 729773 (N.Y. Feb. 13, 2020) (certifying questions where no precedent from state's highest court is available, and the state court was better situated to make "value judgments and important public policy choices"). + +Dated: May 12, 2020 Respectfully Submitted, + +1st Sigrid S. McCabvlev + +David Boies BOWS SCHILLER FLEXNER LLP 333 Main Street Annonk, NY 10504 (914) 749-8200 + +Sigrid McCawley (Pro Hac Vice) BOWS SCHILLER FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 + +Joshua I. Schiller Andrew Villacastin Sabina Mariella Bows SCHILLER FLEXNER LLP 55 Hudson Yards New York, NY 10001 (212) 446-2300 + +Counsel for Plaintiff \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732143/EFTA02732143.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02732143/EFTA02732143.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c727108087a08185ec7fd0357ec1ab6018d14596 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732143/EFTA02732143.metadata.json @@ -0,0 +1,1981 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02732143.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 32, + "chars": 62381, + "elapsed_seconds": 3.85, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.78000000000003, + 70.47 + ], + [ + 418.09381103515625, + 70.47 + ], + [ + 418.09381103515625, + 100.10302734375 + ], + [ + 192.78000000000003, + 100.10302734375 + ] + ] + }, + { + "title": "PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO \nDEFENDANTS' MOTION TO DISMISS PLAINTIFF'S COMPLAINT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 118.72800000000001, + 375.03000000000003 + ], + [ + 493.18670654296875, + 375.03000000000003 + ], + [ + 493.18670654296875, + 404.2330322265625 + ], + [ + 118.72800000000001, + 404.2330322265625 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 238.06800000000004, + 72.08999999999999 + ], + [ + 374.134521484375, + 72.08999999999999 + ], + [ + 374.134521484375, + 86.9830322265625 + ], + [ + 238.06800000000004, + 86.9830322265625 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 229.5, + 72.08999999999999 + ], + [ + 383.5723571777344, + 72.08999999999999 + ], + [ + 383.5723571777344, + 86.2330322265625 + ], + [ + 229.5, + 86.2330322265625 + ] + ] + }, + { + "title": "Cases", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 69.156, + 97.19999999999999 + ], + [ + 105.0146484375, + 97.19999999999999 + ], + [ + 105.0146484375, + 112.4830322265625 + ], + [ + 69.156, + 112.4830322265625 + ] + ] + }, + { + "title": "Statutes", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 67.932, + 150.66 + ], + [ + 117.18220520019531, + 150.66 + ], + [ + 117.18220520019531, + 165.7330322265625 + ], + [ + 67.932, + 165.7330322265625 + ] + ] + }, + { + "title": "Rules", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 67.932, + 278.64 + ], + [ + 104.23119354248047, + 278.64 + ], + [ + 104.23119354248047, + 294.7330322265625 + ], + [ + 67.932, + 294.7330322265625 + ] + ] + }, + { + "title": "Other Authorities", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 67.932, + 407.43 + ], + [ + 167.3088836669922, + 407.43 + ], + [ + 167.3088836669922, + 423.7330322265625 + ], + [ + 67.932, + 423.7330322265625 + ] + ] + }, + { + "title": "PRELIMINARY STATEMENT", + "heading_level": null, + "page_id": 6, + "polygon": [ + [ + 220.32, + 127.17 + ], + [ + 391.8983154296875, + 127.17 + ], + [ + 391.8983154296875, + 141.7330322265625 + ], + [ + 220.32, + 141.7330322265625 + ] + ] + }, + { + "title": "STATEMENT OF FACTS", + "heading_level": null, + "page_id": 6, + "polygon": [ + [ + 235.00799999999998, + 532.1700000000001 + ], + [ + 378.2560119628906, + 532.1700000000001 + ], + [ + 378.2560119628906, + 547.8630218505859 + ], + [ + 235.00799999999998, + 547.8630218505859 + ] + ] + }, + { + "title": "ARGUMENT", + "heading_level": null, + "page_id": 9, + "polygon": [ + [ + 267.44399999999996, + 72.08999999999999 + ], + [ + 344.63134765625, + 72.08999999999999 + ], + [ + 344.63134765625, + 86.2330322265625 + ], + [ + 267.44399999999996, + 86.2330322265625 + ] + ] + }, + { + "title": "I. Defendants Have Not Met Their Burden of 1' ro% ilia that Plaintiff's Claims \nAre Untimely", + "heading_level": null, + "page_id": 9, + "polygon": [ + [ + 105.26399999999998, + 393.65999999999997 + ], + [ + 526.4309692382812, + 393.65999999999997 + ], + [ + 526.4309692382812, + 423.7330322265625 + ], + [ + 105.26399999999998, + 423.7330322265625 + ] + ] + }, + { + "title": "A. Plaintiff's Claims Are Timely Under N.Y. C.P.L.R. \u00a7 215(8Xa).", + "heading_level": null, + "page_id": 10, + "polygon": [ + [ + 140.76, + 126.35999999999999 + ], + [ + 505.2575988769531, + 126.35999999999999 + ], + [ + 505.2575988769531, + 141.7330322265625 + ], + [ + 140.76, + 141.7330322265625 + ] + ] + }, + { + "title": "1. The Indictment Was Not Restricted to Minors.", + "heading_level": null, + "page_id": 11, + "polygon": [ + [ + 141.372, + 71.28 + ], + [ + 407.1121826171875, + 71.28 + ], + [ + 407.1121826171875, + 85.93353271484375 + ], + [ + 141.372, + 85.93353271484375 + ] + ] + }, + { + "title": "2. 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} + ], + "debug_data_path": "debug_data/EFTA02732143" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732175/EFTA02732175.md b/marker2/court-redacted-v-indyke-10479/EFTA02732175/EFTA02732175.md new file mode 100644 index 0000000000000000000000000000000000000000..84be3a4714caab05e86a6951a80385b4bc44a6b1 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732175/EFTA02732175.md @@ -0,0 +1,66 @@ +MatthewJ. Aaronson + +Matthew.aaronson@troutman.com + +May 13, 2020 + +Via ECF + +Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007 + +Re: 1:19-cv-10479-ALC-DCF + +Dear Judge Freeman: + +We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"), in the above-referenced action (the "Action"). We write to address the substantive issues raised in Plaintiffs letters to the Court dated May 7 and May 11, prematurely requesting a pre-motion conference on Plaintiffs anticipated motion to compel. For the reasons set forth below and in our May 8 letter, we respectfully request that the Court deny Plaintiffs request. + +The picture Plaintiff paints is a false one. On their face, Plaintiffs interrogatories are clearly overbroad and unduly burdensome. However, as a compromise and as the Co-Executors said they would do before Plaintiff filed her letter, the Co-Executors have supplemented their responses to those interrogatories. Notwithstanding that Plaintiff has provided no transparency into her own efforts to produce responsive materials (something the Co-Executors hope to resolve before filing letters with the Court), the Co-Executors have collected and are, in connection with this and the numerous other cases against them before Your Honor, reviewing a database of over 730,000 documents. We address Plaintiffs specific points below. + +First, Plaintiff's proposed 18-year time frame for discovery is not proportional to the needs of this case and would impose an undue burden on the Co-Executors. Although Plaintiff asserts that her alleged abuse by Mr. Epstein occurred from 2002 to 2004, she demands discovery from 2001 through July 2019. Plaintiffs proposed time frame is contrary to the goals of the 2015 amendments to the Federal Rules of Civil Procedure, which emphasize the pre-existing but often-unheeded requirement that all civil discovery be proportional to the needs of the case. See State Farm Mut. Auto. Ins. Co. v. Fayda, No. 14CIV9792WHPJCF, 2015 WL 7871037, at \*2 (S.D.N.Y. Dec. 3, 2015), + +![](_page_1_Picture_12.jpeg) + +--- + +*aff'd*, No. 14CV9792, 2016 WL 4530890 (S.D.N.Y. Mar. 24, 2016) ("[T]he amended rule is intended to encourage judges to be more aggressive in identifying and discouraging discovery overuse; by emphasizing the need to analyze proportionality before ordering production of relevant information."). Requiring the Co-Executors to conduct a search for and produce documents over an 18-year time period is not proportional to the needs of this case – which relates to Mr. Epstein's alleged conduct over a **two-year** period that concluded in 2004. The Co-Executors advised Plaintiff's counsel that the appropriate time period for discovery is the time period during which Plaintiff alleges she was abused and during which time her claims would have accrued. Moreover, the Co-Executors will search for and produce all non-privileged communications between Mr. Epstein and Plaintiff or otherwise concerning Plaintiff, regardless of the year. + +Plaintiff's position, that all information relating to what Plaintiff describes as a "sex trafficking" scheme -- which is based on unproven allegations in the S.D.N.Y.'s 2019 indictment of Mr. Epstein -- is relevant to Plaintiff's alleged abuse, is untenable. Plaintiff does not assert sex trafficking claims. Rather, her claims are limited to battery and intentional infliction of emotional distress. + +Moreover, conduct that occurred **after** Plaintiff's alleged abuse cannot possibly be used to support her claims. While Plaintiff posits that discovery relating to Mr. Epstein's conduct with other individuals is "relevant" to her claims, that does not mean that such discovery is proper. *See Mamakos v. United Airlines, Inc.*, No. CV147294JFBAKT, 2018 WL 4861392, at \*2 (E.D.N.Y. Sept. 28, 2018) ("[A]lthough Rule 26 still permits a wide range of discovery based upon relevance and proportionality, the provision authorizing the court ... to order discovery of any matter relevant to the subject matter involved in the action has been eliminated.") (internal citations omitted). Accordingly, the Court should reject Plaintiff's attempt to grossly expand the scope of discovery to obtain documents that extend "far beyond the scope of Plaintiff's claims and would significantly burden" the Co-Executors. *See Robertson v. People Magazine*, No. 14 CIV. 6759 (PAC), 2015 WL 9077111, at \*2 (S.D.N.Y. Dec. 16, 2015) (denying discovery requests that are "burdensome and disproportionate" where Plaintiff sought "nearly unlimited" discovery that was not addressed to alleged discriminatory conduct and/or comments). + +Contrary to her counsel's assertion, Plaintiff does not need discovery about Mr. Epstein's interactions with other individuals to meet her burden to prove her claims for battery or intentional infliction of emotional distress allegedly committed *against her*. The mere fact that certain testimony regarding a defendant's prior conduct could theoretically be admissible at trial does not mean that Plaintiff is entitled to wide-ranging discovery. Plaintiff cites no authority for that proposition. + +Nor does Plaintiff need discovery about Mr. Epstein's interactions with other individuals to invoke her equitable estoppel defense to the Co-Executor's assertion that her claims are barred by the statute of limitations. In order to prevail on her equitable estoppel defense, Plaintiff is required to show that Mr. Epstein's conduct *towards Plaintiff* + +![](_page_2_Picture_11.jpeg) + +--- + +prevented her from bringing her suit earlier; his conduct towards others has no bearing on such a defense. "To invoke equitable estoppel, a plaintiff must show that: '(i) the defendant made a definite misrepresentation of fact and had reason to believe that the plaintiff would rely on it; and (ii) the plaintiff reasonably relied on that misrepresentation to h[er] detriment.'" *See Yesh Diamonds, Inc. v. Yashaya*, No. 09-CV-2016 (DLI) (RER), 2010 U.S. Dist. LEXIS 101744, at \*5 (E.D.N.Y. Sept. 27, 2010) (*quoting Kavowras v. New York Times Co.*, 328 F.3d 50, 56-57 (2d Cir. 2003). + +**Second**, Plaintiff suggests that the Co-Executors agreed to produce only documents that expressly reference Plaintiff. That is an inaccurate representation of the parties' conversations during the meet-and-confer sessions. As we explained during the parties' April 27 and May 5 meet-and-confers, the Co-Executors have and will continue to search for and produce documents that relate to Plaintiff and her claims of battery and intentional infliction of emotional distress, regardless of whether they specifically reference Plaintiff. For example, if the Complaint alleges that Plaintiff traveled on Mr. Epstein's plane, then flight logs for the relevant time period will be produced. Similarly, where phone records exist from the relevant time period and Plaintiff provides Co-Executors with phone numbers that she used during the Relevant Time Period, Co-Executors will search for calls to/from such phone numbers. To the extent Plaintiff bases her argument on the Co-Executors' search-term proposal for ESI, her counsel never engaged with us. Rather than continue discussions that include bilateral search-term proposals – as is customary in this District and something other counsel in the other lawsuits against the Estate have done – Plaintiff burdened the Court in an apparent effort to obtain a wide-ranging Court order that would unduly burden the Co-Executors. If Plaintiff had simply made a single proposal or engaged in any effort to compromise on her positions, this could have all been avoided. + +**Third**, Plaintiff's request that the Co-Executors supplement their interrogatory responses is moot. Again, this is exactly the situation the Court warned against. The Co-Executors supplemented their interrogatory responses earlier today, as they agreed to do before Plaintiff went ahead and burdened the Court with her initial lengthy letter on this issue. The Co-Executors provided their initial and supplemental responses to Plaintiff's interrogatories in the capacity in which they were sued. Plaintiff provides no support for her position that the Co-Executors' responses should be made in their personal or other professional capacity. Plaintiff also misrepresents the parties' communications regarding information provided by Co-Executors in connection with their interrogatory responses. As we advised Plaintiff on several occasions, the Co-Executors reviewed and approved the interrogatory responses before they were served. + +Plaintiff incorrectly states that counsel for Co-Executors represented that the Co-Executors "do not know where to look for responsive documents." To the contrary, we stated that, despite the fact that obtaining documents and information from a large, complicated estate is more involved and thus takes longer than the collection of documents from an individual party such as Plaintiff, the Co-Executors retrieved hundreds + +![](_page_3_Picture_16.jpeg) + +--- + +of thousands of documents and were reviewing the voluminous database in preparation for production, but that the task had been complicated by the need to track down such information and the attendant delays caused by the current pandemic. The Co-Executors have compiled a database with over 730,000 documents that they have been searching for documents responsive to this and discovery requests in numerous other lawsuits. Subject to the execution of a mutually acceptable ESI protocol and confidentiality order (something made abundantly clear in the Co-Executors' written responses to Plaintiff's requests for production), they expect to begin production within the next week. The only reason a confidentiality order was not already entered in this action (but was in several other lawsuits against the Co-Executors) is that, unlike the plaintiffs' counsel in the other actions, Plaintiff's counsel here insisted until shortly before filing their letter that the Co-Executors accept unsupportable changes, such as the removal of several categories of confidentiality that the Co-Executors require but which Plaintiff does not believe she needs—a vexatious tactic. + +**Finally**, contrary to her representations to the Court, Plaintiff has not complied with her discovery obligations. Rather, Plaintiff produced a small set of self-selected, and useless materials so she could rush to Court under the guise of having made a meaningful production in the face of what she falsely claims was stonewalling from her adversaries. Approximately half of the documents Plaintiff produced are irrelevant documents from another case that was handled by Plaintiff's counsel that has nothing to do with Plaintiff's claims in this action.1 There appears to have been no reason for the production of these documents other than to inflate the size of Plaintiff's production. Those same documents were also produced by the other Plaintiffs that Plaintiff's counsel represents in actions against Mr. Epstein's estate. They do not appear to be documents that were in Plaintiff's personal possession. + +Accordingly, we request that the Court deny Plaintiff's request for a pre-motion conference and instead direct Plaintiff to engage in a good-faith meet-and-confer session to resolve the parties' discovery disputes. + +Respectfully submitted, + +*s/Matthew J. Aaronson* +Matthew J. Aaronson + +cc: Counsel of Record (via ECF) + +--- + +1 The Court should be aware that the Hon. Lorretta A. 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McCawley +Telephone: (954) 377-4223 +Email: [smccawley@bsfllp.com](mailto:smccawley@bsfllp.com) + +May 14, 2020 + +**VIA ECF** + +The Honorable Debra Freeman +Daniel [REDACTED] Moynihan +United States Courthouse +500 Pearl St. +New York, NY 10007-1312 + +**Re: [REDACTED] v. Darren K. Indyke & Richard D. Kahn, 19-10479-ALC-DCF** + +Dear Judge Freeman: + +We submit on behalf of Plaintiff [REDACTED] this reply in further support of her letter motion for a conference to address Defendants' failure to comply with their discovery obligations (ECF No. 27), and in response to Defendants' second letter in opposition, filed on May 13, 2020 (ECF No. 34). As an initial matter, the Court should disregard Defendants' latest response as untimely. Pursuant to Individual Rule 1.D., "[u]nless the Court orders otherwise, opposition to any letter motion shall be filed within three (3) days of the moving letter." Notwithstanding this rule, Defendants filed an incomplete and non-substantive opposition on May 8, and requested "permission to submit a response to the substantive issues raised in the Letters by May 13, 2020." ECF No. 28. Defendants' letter did not comply with Individual Rule 1.B., which governs "requests for adjournments or extensions of time." In any event, the Court did not issue an order extending Defendants' time to respond, much less grant Defendants leave to file two oppositions as opposed to one. But even if the Court were to consider Defendants' untimely filing, each of their arguments is meritless, and confirms the need for immediate Court intervention to resolve the parties' disputes. + +***First***, Defendants refuse to engage in discovery for more than a narrow, two-year period (2002-2004). This is improper, as information concerning Epstein's abuse of other girls and young women throughout the span of his sex-trafficking conspiracy is plainly relevant, and therefore discoverable under Rule 26. Defendants deride Plaintiff's allegations as a "sex trafficking scheme—which," according to Defendants, "is based on *unproven allegations* in the S.D.N.Y.'s 2019 indictment of Mr. Epstein." ECF No. 34 at 2 (emphases added). But given all that has been discovered about the scope of Epstein's operations and the numerous ways in which Plaintiff's abuse mirrored Epstein's abuse of others, Defendants' argument that Plaintiff "does not need discovery about Mr. Epstein's interactions with other individuals" is baseless. As set forth in Plaintiff's opening letter, "[d]ocuments relating to the sexual trafficking and/or sexual assault of others at any point during that period would make the fact that Epstein trafficked and sexually assaulted Plaintiff, the key fact that Plaintiff bears the burden of proving in this case, more probable than it would be without such evidence." ECF No. 27 at 2. Moreover, Rule 415 (which Defendants fail to address) unambiguously provides that "[i]n a civil case involving a claim for relief based on a party's alleged sexual assault or child molestation, the court may admit evidence that the party + +Page 2 + +committed any other sexual assault or child molestation.” Fed. R. Evid. 415. Defendants are free to attempt to prove Epstein innocent, and can try to prove that the allegations set forth in Plaintiff’s complaint and the S.D.N.Y.’s indictment are false. They cannot, however, prevent Plaintiff from accessing the information that would prove otherwise. + +Defendants argue that allowing discovery into a period of time greater than two years is somehow “not proportional to the needs of this case and would impose an undue burden on the Co-Executors.” ECF No. 34 at 1. But “unsubstantiated claims of undue burden, overbreadth and lack of relevancy” in situations where a party has “produced no documents and answered no interrogatories . . . are a paradigm of discovery abuse.” *Jacoby v. Hartford Life & Acc. Ins. Co.*, 254 F.R.D. 477, 478 (S.D.N.Y. 2009). Defendants do not even attempt to quantify what the burden of reviewing documents through the present would be, or how that number would compare to that for the two-year time period they propose. The only information Defendants offer in their letter is a representation that they are “reviewing a database of **over 730,000 documents**.” ECF No. 34 at 1 (emphasis in original). That representation is ambiguous, however, as it sheds no light on (i) how many of those documents Defendants will review (as opposed to just being a number of documents housed on a “database”); (ii) how those documents were collected; or (iii) whether any of those documents are currently being reviewed in response to the discovery requests Plaintiff served in this case (as opposed to those served in cases brought by other victims). And the fact that Epstein’s Estate is “large and complicated” does not change Defendants’ discovery obligations or the deadlines that this Court imposed. Absent any particularized showing that compliance with Plaintiff’s discovery requests would pose an undue burden, Defendants’ proposal to limit the discovery period to two years is unfounded. Again, to date Defendants ***have not produced a single document—not one.*** + +***Second***, Defendants improperly refuse to answer interrogatories or produce documents that do not specifically reference Plaintiff or the specific instances in which she was abused. Defendants claim that they “have and will continue to search for and produce documents that relate to Plaintiff and her claims of battery and intentional infliction of emotional distress, regardless of whether they specifically reference Plaintiff.” ECF No. 34 at 3. As set forth above, however, Plaintiff is entitled to information concerning Epstein’s sex-trafficking conspiracy as a whole, including his abuse of others, his communications with his co-conspirators, and the various ways in which he operated his scheme throughout the years. Because the parties’ disagreement hinges on whether or not defined topics are discoverable under Rule 26, Defendants’ suggestion that the dispute can be resolved by exchanging “bilateral search-term proposals” is disingenuous at best.1 *Id.* at 3. Court intervention is required now so that Defendants can begin reviewing and producing documents concerning the sex-trafficking conspiracy they are trying to keep secret. + +***Third***, the Court should compel Defendants to answer Plaintiff’s interrogatories in full. In a desperate attempt to convince the Court that this issue is somehow “moot” or that Plaintiff’s premotion letter was “premature,” Defendants claim that Plaintiff’s request was merely “that Co- + +--- + +1 Plaintiff already offered to provide a list of search terms to Defendants, and their counsel responded by stating that Defendants would only consider any other names Plaintiff goes by as a search term. If that was not Defendants’ position, they never corrected it or otherwise indicated that they would change it. + +May 14, 2020 + +Page 3 + +Executors supplement their interrogatory responses." ECF No. 34 at 3. To be clear, Plaintiff's anticipated motion will be to compel Defendants to respond meaningfully to all of Plaintiff's interrogatories, which has still not happened despite Defendants' belated "supplementation." Defendants' "supplemental responses," attached hereto as Exhibit A, remain deficient, and only insert cosmetic changes based on information that should have been obvious to Defendants at the time they served their "initial" responses,2 or parrot back information taken from Plaintiff's complaint and Plaintiff's own production of documents. In any event, each of Defendants' "supplemental" responses "is limited to the Relevant Time Period," which means that Defendants still refuse to answer Plaintiff's interrogatories for more than a two-year period. Court intervention is required to compel Defendants to answer these interrogatories in full. + +Finally, although irrelevant to the pending motion concerning Defendants' discovery efforts, Plaintiff has fully complied with her discovery obligations to date, and will continue to do so. Defendants complain that Plaintiff included within her productions what they claim are "irrelevant documents from another case," ECF No. 34 at 4, but Plaintiff produced these documents because Defendants specifically asked for the documents identified in Plaintiff's initial disclosures, and Plaintiff correctly produced those documents. Plaintiff has and will continue to engage with opposing counsel in good faith to answer any questions they may have.3 + +For the foregoing reasons, Plaintiff respectfully requests that the Court grant her request for a conference. + +2 Together with their "supplemental responses," Defendants' served verifications for their "initial responses" on May 13, 2020. Ex. B. Whereas the initial responses were served on April 16, the signatures for the verifications for those responses are dated May 12, 2020, which is the same date as the verifications for the supplemental responses. + +In a footnote, Defendants mention a ruling in v. Dershowitz, which disqualified Boies Schiller Flexner LLP ("BSF") as counsel for another Epstein victim, in a defamation case brought by that victim against Alan Dershowitz. v. Dershowitz, 410 F. Supp. 3d 564, 578-79 (S.D.N.Y. 2019). Judge Preska's disqualification of the law firm was not a sanction. Instead, it was based on the advocate-witness rule because Dershowitz claimed that a BSF attorney (while representing the victim) said something to him during a settlement negotiation that would implicate the truth or falsity of one of Dershowitz's allegedly defamatory statements. Id. at 579. Indeed, BSF continues to represent before Judge Preska in the v. Maxwell matter. Defendants disingenuously state that "[t]he Court should be aware" of that ruling, despite the fact that it has nothing to do with whether or not Plaintiff herself was a victim of Epstein's sex-trafficking conspiracy. If Defendants and their counsel are actually seeking to prove Epstein innocent or otherwise insulated from accounting for his misconduct, they should drop their baseless objections to discovery, stop ad hominem attacks on counsel, cease their delay tactics, and welcome a trial on the merits. + +May 14, 2020 + +Page 4 + +Respectfully submitted, + +/s/ Sigrid S. McCawley + +Sigrid S. McCawley, Esq. + +cc: Counsel of Record (via ECF) + +# Exhibit A + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +Plaintiff, + +v. + +DARREN K. INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +Case No. 1:19-cv-10479-ALC-DCF + +#### DEFENDANTS' OBJECTIONS AND SUPPLEMENTAL RESPONSES TO PLAINTIFF FIRST SET OF INTERROGATORIES TO DEFENDANTS + +Defendants Darren K. Indyke and Richard D. Kahn, as co-executors of the estate of Jeffrey E. Epstein (the "Co-Executors"), by their attorneys, pursuant to Federal Rules of Civil Procedure 26 and 33, provide the following supplemental responses to Plaintiff ("Plaintiff") First Set of Interrogatories to Defendants (the "Interrogatories"). + +# RESERVATION OF RIGHTS + +These supplemental responses are made solely for the purpose of and in relation to discovery in the above-captioned action. The Co-Executors submit these supplemental responses subject to, and without intending to waive, and expressly preserving: (i) any objections as to relevancy, materiality, competency, privilege and admissibility of any documents and information produced in discovery, including without limitation herein; and (ii) the right to object to any other discovery requests. The Co-Executors have been placed in charge of a large and complex estate and are working to determine the existence of responsive information concerning the affairs of Jeffrey E. Epstein ("Decedent") and those efforts are continuing. Much of the requested information is outside of their knowledge, possession or control. To the extent non privileged + +responsive information would be available to them at all, access to such information has been severely hampered by the current pandemic. Accordingly, Co-Executors reserve their right to amend or further supplement these responses if and when appropriate. Further, these supplemental responses are neither an admission nor acceptance of any alleged facts, including without limitation those stated in the Interrogatories. + +# SPECIFIC OBJECTIONS TO DEFINITIONS AND INSTRUCTIONS + +The Co-Executors incorporate their initial objections to the definitions and instructions as if stated fully herein. + +#### SPECIFIC OBJECTIONS AND SUPPLEMENTAL RESPONSES TO INTERROGATORIES + +#### INTERROGATORY NO. I + +List the names and addresses of all persons who are believed or known by You, Your agents, or Your attorneys to have any knowledge concerning any of the issues in this lawsuit, and specify the subject matter about which the witness has knowledge. + +### SUPPLEMENTAL RESPONSE: + +The Co-Executors object to Interrogatory No. 1 on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors also object to Interrogatory No. I on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. + +Subject to and without waiving the foregoing objections, the Co-Executors identify the following individuals who have knowledge concerning the battery and intentional infliction of emotional distress allegedly committed by Decedent against Plaintiff: Plaintiff and Sven + +Stromnes. + +In addition, in her Complaint, Plaintiff identifies the following individuals with whom she alleges she interacted with or communicated with: M, "the former high U.S. Government official, the famous actor, and the well-known comedian" described in paragraph 39 of Plaintiff's Complaint, Lesley Groff, Plaintiff's mother, the "other young girl" described in paragraph 44 of Plaintiff's Complaint, and Ghislaine Maxwell. Co-Executors do not know whether these individuals ever spoke with or interacted with Plaintiff, or have knowledge concerning Plaintiff's claims. + +In addition, the Co-Executors identify the following individuals, believed to have worked at Decedent's homes in New York, Paris, New Mexico, Palm Beach, Florida and United States Virgin Islands, which where Plaintiff alleges she encountered Decedent, during the period from 2002 to 2004, which based upon the allegations of the Complaint, appears to cover the entire time period during which Plaintiff's claims accrued (the "Relevant Time Period"): Luciano Fontanilla, Rosalyn Fontanilla, Richard Barnett, Valdson Cotrin, Brice M , Floyd M, Miles Alexander, Catherine Alexander, Ghislaine Maxwell, Alvin M, Juan Alessi, Maria Alessi, Adam Lang, Michael and Alfredo Rodriguez. Co-Executors do not know whether these individuals ever spoke with or interacted with Plaintiff, or have knowledge concerning Plaintiff's allegations. + +To the extent additional individuals are identified in response to other interrogatories, those individuals may, but not necessarily, have such knowledge. The Co-Executors' search for relevant information remains ongoing; they will supplement this response if and when any additional responsive information is ascertained. + +#### INTERROGATORY NO. 2 + +Identify all email accounts used by Epstein or any of his employees or agents on his behalf. + +#### SUPPLEMENTAL RESPONSE: + +The Co-Executors object to Interrogatory No. 2 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it is unconstrained by time. Accordingly, Co-Executors' response is limited to the Relevant Time Period. + +Subject to and without waiving the foregoing objections, the Co-Executors state that it is their understanding that the email addresses listed below were created for or on behalf of Decedent, but only ieevacationlaernail.com and jeevroiectavahoo.com were actively used by Decedent himself. Moreover, Co-Executors currently do not believe that ieevacationAgmail.com existed or was in use during the Relevant Time Period and do not know whether jeeprojectOyahoo.com was in use during the Relevant Time Period: + +- columbiadental I ®yahoo.com +- jeevacation®me.com +- jeevacationl@me.com +- jeeproject®yahoo.com +- jeevacation@gmail.com +- jeffrey®jeffreyepstein.org +- jeffreyepsteinorg®gmail.com +- jeffreyepsteinorg®yahoo.com +- jeffreyepstein®live.com +- jeeitunes®gmail.com +- littlestjeff®yahoo.com + +The Co-Executors' search for relevant information remains ongoing; they will supplement this response if and when any additional responsive information is ascertained. + +#### INTERROGATORY NO. 3 + +Identify all telephone numbers used by Epstein or any of his employees or agents acting on his behalf, including beepers, Blackberry or PDA devices, cellular phones and land lines in any of his residences, by stating the users name, complete telephone number(s), type of device and name of the service provider. + +#### SUPPLEMENTAL RESPONSE: + +The Co-Executors object to Interrogatory No. 3 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it is unconstrained by time. Accordingly, Co-Executors' response is limited to the Relevant Time Period. + +Subject to and without waiving the foregoing objections, the Co-Executors state that it is their understanding that the following phone numbers were used by Decedent or registered to properties where Decedent stayed at different times, but are unaware of the specific time period that the numbers were in use: + +| 340-775-8111 | 340-775-8121 | 340-775-8143 | +|--------------|--------------|----------------| +| 340-775-8112 | 340-775-8122 | 340-775-8144 | +| 340-775-8113 | 340-775-8123 | 340-775-8145 | +| 340-775-8114 | 340-775-8124 | 340-775-8146 | +| 340-775-8100 | 340-775-8125 | 340-775-8147 | +| 340-775-8101 | 340-775-8126 | 340-775-8148 | +| 340-775-8102 | 340-775-8127 | 340-775-8149 | +| 340-775-8103 | 340-775-8128 | 561-655-7626 | +| 340-775-8104 | 340-775-8129 | 561-655-7629 | +| 340-775-8105 | 340-775-8130 | 561-832-2104 | +| 340-775-8106 | 340-775-8131 | 561-805-8663 | +| 340-775-8107 | 340-775-8132 | 561-655-3572 | +| 340-775-8108 | 340-775-8133 | 561-655-3704 | +| 340-775-8109 | 340-775-8134 | 561-655-2312 | +| 340-775-8110 | 340-775-8135 | 561-655-2779 | +| 340-775-8115 | 340-775-8136 | 505-938-2929 | +| 340-775-8116 | 340-775-8137 | 505-938-2930 | +| 340-775-8117 | 340-775-8138 | 505-938-2928 | +| 340-775-8118 | 340-775-8139 | 505-938-3065 | +| 340-775-8119 | 340-775-8140 | 505-938-3066 | +| 340-775-8120 | 340-775-8141 | 505-938-3069 | +| | 340-775-8142 | 505-938-3071 | +| 505-938-3072 | 212-472-1411 | 347-603-2935 | +| 505-988-3071 | 212-472-4883 | 505-377-3854 | +| 505-832-4900 | 212-535-5198 | 505-934-1256 | +| 505-832-4970 | 212-535-5297 | | +| 505-832-4983 | 212-717-4672 | (212) 533-3739 | +| 505-832-5369 | 212-249-1122 | | +| 505-832-5401 | 212-327-1608 | | +| 212-772-9416 | 212-879-3281 | | +| 212-249-1113 | 212-750-9895 | | +| 212-249-1166 | | | +| 212-249-9457 | | | + +The Co-Executors' search for relevant information remains ongoing; they will supplement this response if and when any additional responsive information is ascertained. + +# INTERROGATORY NO.4 + +Identify all employees, including each employee's position and dates and locations of employment, who performed work or services in or on any property owned, leased, occupied, or + +used by Epstein, including but not limited Epstein's homes in Palm Beach, Florida, New York City, the U.S. Virgin Islands, New Mexico, London and Paris, and provide the name and contact information of the individual who hired, trained and supervised each employee. + +# SUPPLEMENTAL RESPONSE: + +The Co-Executors object to Interrogatory No. 4 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it is unconstrained by time. Accordingly, Co-Executors' response is limited to those individuals who are believed to have worked during the Relevant Time Period at Decedent's homes in New York, the United States Virgin Islands, Paris, Palm Beach, Florida and New Mexico, where Plaintiff alleges she encountered Decedent. Co-Executors do not know whether these individuals ever spoke with or interacted with Plaintiff during the Relevant Time Period. + +Subject to and without waiving the foregoing objections, the Co-Executors identify the following individuals: + +- Luciano Fontanilla +- Rosalyn Fontanilla +- Richard Barnett +- Valdson Cotrin +- Brice I +- I 10> (I +- Miles Alexander +- Catherine Alexander +- Ghislaine Maxwell +- Alvin +- Juan Alessi, +- Maria Alessi, +- Adam Lan +- Michael + +- • +- Alfredo Rodriguez + +The Co-Executors' search for relevant information remains ongoing; they will supplement this response if and when any additional responsive information is ascertained. + +#### INTERROGATORY NO. 5 + +Identify all employees, including each employee's position and dates and locations of employment, who performed work as an assistant, scheduler, secretary, masseuse or traveling masseuse for Epstein and provide the name and contact information of the individual who hired, trained and supervised each employee. + +#### SUPPLEMENTAL RESPONSE: + +The Co-Executors object to Interrogatory No. 5 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the grounds that the terms "scheduler and "traveling masseuse" are vague and ambiguous. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it is unconstrained by time. Accordingly, Co-Executors' response is limited to the Relevant Time Period. + +Subject to and without waiving the foregoing objections, Co-Executors identify Lesley Groff and who were Decedent's assistants during the Relevant Time Period. Co-Executors do not know whether Ms. Groff or ever spoke with or interacted with Plaintiff. Co-Executors also refer Plaintiff to the documents produced by Plaintiff at Nos. JBRYANT 3736-3832, which purports to list contact information for masseuses. Co-Executors do not know whether any individuals identified therein are masseuses or if those individuals provided massages to Decedent during the Relevant Time Period. The Co-Executors' search for + +relevant information remains ongoing; they will supplement this response if and when any additional responsive information is ascertained. + +#### INTERROGATORY NO. 6 + +Identify all companies and/or persons who provided transportation services to Epstein, whether as an employee or independent contractor, including without limitation drivers, chauffeurs, boat captains, pilots, and aircraft crew, and provide the contact information for each listed person or company. + +#### SUPPLEMENTAL RESPONSE: + +The Co-Executors object to Interrogatory No. 6 on the grounds that it seeks information that is neither relevant to Plaintiff's claims; it is also overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the grounds that the phrase "transportation services" is vague and ambiguous. The Co-Executors further object to this Interrogatory on the grounds and to the extent that is unconstrained by time. Accordingly, Co-Executors' response is limited to the Relevant Time Period. + +Subject to and without waiving the foregoing objections, the Co-Executors state the following individuals provided transportation services to Decedent during the Relevant Time Period: + +- David Rodgers +- Larry Visoski +- Larry r +- Alvin + +Subject to and without waiving the foregoing objections, Co-Executors identify Shoppers Travel, Inc., which is a travel agency that provided travel-related services to Decedent during the Relevant Time Period. The Co-Executors' search for relevant information remains ongoing; they will supplement this response if and when any additional responsive information is ascertained. + +#### INTERROGATORY NO. 7 + +Identify all females by name and age for whom Epstein or his employees or agents provided accommodations at 301 East 66'h Street, New York, New York for any period of time. + +#### SUPPLEMENTAL RESPONSE: + +The Co-Executors object to Interrogatory No. 7 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the grounds that the phrase "provided accommodations" is vague and ambiguous. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it is unconstrained by time. Accordingly, Co-Executors' response is limited to the Relevant Time Period. + +Subject to and without waiving the foregoing objections, the Co-Executors state the following individuals stayed at 301 East 66th Street, New York, New York for some period of time, but it is unknown whether any of them stayed at 301 East 66th Street, New York, New York during the Relevant Time Period: + +- Rosl Fontanilla +- • +- • + +Co-Executors do not know whether the individuals listed have ever spoke with or interacted with Plaintiff during the Relevant Time Period. The Co-Executors' search for relevant information remains ongoing; they will supplement this response if and when any additional responsive information is ascertained. + +## INTERROGATORY NO. 8 + +Identify by name and age all persons who gave a massage or were asked to give a massage to Epstein, Maxwell or a guest, or to whom Epstein or Maxwell gave a massage, at any of Epstein's residences and provide the location of each massage. + +#### SUPPLEMENTAL RESPONSE: + +The Co-Executors object to Interrogatory No. 8 on the grounds and to the extent that it calls for the production of information protected by the attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors further object on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it is unconstrained by time. Accordingly, Co-Executors' response is limited to the Relevant Time Period. + +Subject to and without waiving the foregoing objections, Co-Executors refer Plaintiff to the documents produced by Plaintiff at Nos. JBRYANT 3736-3832, which purports to list contact information for masseuses. Co-Executors do not know whether any individuals identified therein are masseuses or if those individuals provided massages to Decedent during the Relevant Time Period. The Co-Executors' search for relevant information remains ongoing; they will supplement this response if and when any additional responsive information is ascertained. + +# INTERROGATORY NO. 12 + +Identify any telecommunications, information technology, or audio-visual technology company that Epstein hired for work in any of his residences or offices and provide the name and contact information for each individual or company listed, in addition to the residence or office serviced. + +# SUPPLEMENTAL RESPONSE: + +The Co-Executors object to Interrogatory No. 12 on the grounds that it seeks information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the grounds that the phrase "hired for work" is vague and ambiguous. The Co-Executors further object to this Interrogatory on the grounds and to the extent that it is unconstrained by time. Accordingly, Co-Executors' response is limited to the Relevant Time Period. + +Subject to and without waiving the foregoing objections, the Co-Executors believe that Jermaine Ruan performed information technology work at Decedent's home in the United States Virgin Islands during the Relevant Time Period. Subject to and without waiving the foregoing objections, the Co-Executors also believe that Mark Lundberg may have performed information technology work in some or all of Decedent's homes during the Relevant Time Period. + +The Co-Executors' search for relevant information remains ongoing; they will supplement this response if and when any additional responsive information is ascertained. + +Dated: New York, New York + +May 13, 2020 TROUTMAN SANDERS LLP + +By: /s/Bennet Moskowitz Bennet Moskowitz 875 Third Avenue New York, New York 10022 Tel: (212) 704-6087 bennet.moskowitz@troutman.com + +> Attorney for Darren K. Indyke and Richard D. Kahn. as co-executors of the estate ofJeffrey E. Epstein + +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +v. + +DARREN K. INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN. + +Defendants. + +Case No. l : I 9-cv-10479-ALC-DCF + +# VERIFICATION + +Darren K. Indyke and Richard D. Kahn, as Co-Executors of the estate of Jeffrey E. Epstein (the "Co-Executors"), have read the foregoing Co-Erecutors' Objections and Supplemental Responses to Plaintiff's First Set of Interrogatories and are familiar with its contents. The responses are subject to inadvertent and undiscovered errors and are based on information available at this stage of discovers. the Co-Executors reserve the right to amend the responses if it appears at any time that omissions or errors have been made therein or that more accurate or additional information is available. Subject to the limitations set forth herein and to the best of their knowledge and belief, Mr. Indyke and Mr. Kahn. solely in their capacities as Co-Executors. state that the answers contained therein are true and correct. + +I state under penalty of perjury that the foregoing is true and correct. Executed on May 12, 2020 + +![]()Darren K. Indyke +Co-Executor of the Estate of Jeffrey E. Epstein + +I state under penalty of perjury that the foregoing is true and correct. Executed on May 12, 2020 + +![]()Richard D. Kahn +Co-Executor of the Estate of Jeffrey E. Epstein + +# Exhibit B + +# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +![](_page_20_Picture_2.jpeg) + +Plaintiff + +v. + +DARREN K. INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +Case No. I :19-cv-10479-ALC-DCF + +# VERIFICATION + +Darren K. Indyke and Richard D. Kahn, as Co-Executors of the estate of Jeffrey E. Epstein (the "Co-Executors"). have read the Co-Eveciaors ' Objections and Responses to Plaintiffs First Set of Interrogatories, dated April 16. 2020. and are familiar with its contents. The responses are subject to inadvertent and undiscovered errors and are based on information available at this stage of discovery. The Co-Executors reserve the right to amend the responses if it appears at any time that omissions or errors have been made therein or that more accurate or additional information is available. Subject to the limitations set forth herein and to the best of their knowledge and belief, Mr. Indyke and Mr. Kahn. solely in their capacities as Co-Executors, state that the answers contained therein are true and correct. + +I state under penalty of perjury that the foregoing is true and correct. Executed on May 12, 2020 + +![]()Darren K. Indyke +Co-Executor of the Estate of Jeffrey E. Epstein + +I state under penalty of perjury that the foregoing is true and correct. Executed on May 12, 2020 + +![]()Richard D. Kahn +Co-Executor of the Estate of Jeffrey E. 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INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +# STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER + +WHEREAS, Plaintiff and Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, (collectively, the "Parties" and each individually, a "Party") request that this Court issue a protective order pursuant to Federal Rule of Civil Procedure 26(c) to protect the confidentiality of nonpublic and sensitive information that they may need to disclose in connection with discovery in this action; + +WHEREAS, the Parties, through counsel, agree to the following terms; and + +WHEREAS, this Court finds that good cause exists for issuance of an appropriately tailored confidentiality order governing the pretrial phase of this action: + +IT IS HEREBY ORDERED that the Parties to this action, their respective agents, employees, and attorneys, any other person in active concert or participation with any of the foregoing, and all other persons with actual notice of this Order will adhere to the following terms, upon pain of contempt: + +- 1. "Producing Party" shall mean the parties to this action and any third parties producing Confidential Information. +- 2. "Receiving Party" shall mean the party to this action and/or any non-party receiving Confidential Information. +- 3. With respect to "Discovery Material" (i.e., documents, information or tangible things of any kind produced or disclosed in the course of discovery in this action) that a Producing Party has designated as "Confidential" pursuant to this Order, no Receiving Party may disclose such Confidential Discovery Material to anyone else except as expressly permitted hereunder. +- 4. The Producing Party may designate as Confidential only the portion of such material that it reasonably and in good faith believes consists of: + - (a) medical, mental health and/or other health care records; + - (b) Social Security numbers, personal telephone numbers, tax returns, and credit and banking information of any person; + - (c) names of alleged minor victims of sexual abuse; + - (d) previously non-disclosed financial information; + - (e) non-public information that the producing person in good faith considers to be, reflect, or reveal business, marketing, financial, or regulatory information or data, or information of commercial value, including, without limitation, trade secrets, contracts with third parties, or other information required by law or agreement to be kept confidential; + +- (f) any other material the Parties agree in writing is Confidential; and +- (g) any other category of information given confidential status by this Court after the date of this Order. + +5. With respect to the Confidential portion of any Discovery Material other than deposition transcripts and exhibits, the Producing Party or its counsel may designate such portion as "Confidential" by: (a) stamping or otherwise clearly marking as "Confidential" the protected portion in a manner that will not interfere with legibility or audibility; and (b) producing for future public use another copy of said Discovery Material with the confidential information redacted. + +6. A Producing Party or its counsel may designate deposition exhibits or portions of deposition transcripts as Confidential Discovery Material either by: (a) indicating on the record during the deposition that a question calls for Confidential information, in which case the reporter will bind the transcript of the designated testimony in a separate volume and mark it as "Confidential Information Governed by Protective Order;" or (b) notifying the reporter and all counsel of record, in writing, within 30 days after a deposition has concluded, of the specific pages and lines of the transcript that are to be designated "Confidential," in which case all counsel receiving the transcript will be responsible for marking the copies of the designated transcript in their possession or under their control as directed by the Producing Party or that person's counsel. During the 30-day period following a deposition. all Parties will treat the entire deposition transcript as if it had been designated Confidential. + +7. If at any time before the termination of this action a Producing Party realizes that it should have designated as Confidential some portion(s) of Discovery Material that it previously produced without limitation, the Producing Party may so designate such material by + +notifying all Parties in writing. Thereafter, the Receiving Party will treat such designated portion(s) of the Discovery Material as Confidential. In addition, the Producing Party shall provide each Receiving Party with replacement versions of such Discovery Material that bears the "Confidential" designation within two business days of providing such notice. + +8. Nothing contained in this Order will be construed as: (a) a waiver by a Party or person of its right to object to any discovery request; (b) a waiver of any privilege or protection; or (c) a ruling regarding the admissibility at trial of any document, testimony, or other evidence. + +9. Where a Producing Party has designated Discovery Material as Confidential, the Receiving Party may disclose such information only to the following persons: + +- (a) the Parties to this action; +- (b) counsel retained specifically for this action, including any paralegal, clerical, or other assistant that such outside counsel employs and assigns to this matter; +- (c) outside vendors or service providers (such as copy-service providers and document-management consultants) that counsel hire and assign to this matter, provided such person has first executed a Non-Disclosure Agreement in the form annexed as Exhibit A hereto; +- (d) any mediator or arbitrator that the Parties engage in this matter or that this Court appoints, provided such person has first executed a Non-Disclosure Agreement in the form annexed as Exhibit A hereto; +- (e) as to any document, its author, its addressee, and any other person indicated on the face of the document as having received a copy; + +(f) any witness who counsel for a Party in good faith believes may be called to testify at trial or deposition in this action, provided such person has first executed a Non-Disclosure Agreement in the form annexed as Exhibit A hereto; + +(g) any person a Party retains to serve as an expert witness or otherwise provide specialized advice to counsel in connection with this action, provided such person has first executed a Non-Disclosure Agreement in the form annexed as Exhibit A hereto; + +(h) stenographers engaged to transcribe depositions the Parties conduct in this action; and + +(i) this Court, including any appellate court, its support personnel, and court reporters. + +10. Before disclosing any Confidential Discovery Material to any person referred to in subparagraphs 9(c), 9(d), 9(f), or 9(g) above, counsel must provide a copy of this Order to such person, who must sign a Non-Disclosure Agreement in the form annexed as Exhibit A hereto stating that he or she has read this Order and agrees to be bound by its terms. Said counsel must retain each signed Non-Disclosure Agreement, hold it in escrow, and produce it to opposing counsel either before such person is permitted to testify (at deposition or trial) or at the conclusion of the case including any and all appeals, whichever comes first. + +II. For the avoidance of doubt, nothing in Paragraph 9 shall impose any limitation on the ability of a Producing Party to disclose its own Confidential Discovery Material. A Producing Party shall not be required to obtain an executed Non-Disclosure Agreement from its own current or former employees with respect to disclosure of its own Confidential Discovery Material. + +12. This Order binds the Parties and certain others to treat as Confidential any Discovery Materials so classified. The Court has not, however, made any finding regarding the confidentiality of any Discovery Materials, and retains full discretion to determine whether to afford confidential treatment to any Discovery Material designated as Confidential hereunder. All persons are placed on notice that the Court is unlikely to seal or otherwise afford confidential treatment to any Discovery Material introduced into evidence at trial, even if such material has previously been sealed or designated as Confidential. + +13. In filing Confidential Discovery Material with this Court, or filing portions of any pleadings, motions, or other papers that disclose such Confidential Discovery Material ("Confidential Court Submission"), the Parties shall publicly file a redacted copy of the Confidential Court Submission via the Electronic Case Filing System. The Parties shall file an unredacted copy of the Confidential Court Submission under seal with the Clerk of this Court, and the Parties shall serve this Court and opposing counsel with unredacted courtesy copies of the Confidential Court Submission. Any Party that seeks to file Confidential Discovery Material under seal must file an application and supporting declaration justifying—on a particularized basis—the sealing of such documents. The parties should be aware that the Court will unseal documents if it is unable to make "specific, on the record findings ... demonstrating that closure is essential to preserve higher values and is narrowly tailored to serve that interest." Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 120 (2d Cir. 2006). Notwithstanding any other provision of this paragraph, if the parties stipulate that specific portions of a document are both confidential and immaterial to this lawsuit, a party may publicly file a version of the document with those confidential and immaterial portions redacted, and that party need not submit an unredacted version to the Court or file a motion to seal. + +14. Any Party who objects to any designation of confidentiality may at any time before the trial of this action serve upon counsel for the Producing Party a written notice stating with particularity the grounds of the objection. If the Parties cannot reach agreement promptly, counsel for all affected Parties will address their dispute to the Court by motion. The Party seeking confidentiality shall bear the burden of establishing that the material at issue was properly designated as confidential. The Parties shall treat the disputed materials as Confidential pending the Court's resolution of such motion. + +15. Any Party who requests additional limits on disclosure (such as "attorneys' eyes only" in extraordinary circumstances), may at any time before the trial of this action serve upon counsel for the recipient Parties a written notice stating with particularity the grounds of the request. If the Parties cannot reach agreement promptly, counsel for all affected Parties will address their dispute to the Court. + +16. Absent an Order from a court of competent jurisdiction, Recipients of Confidential Discovery Material under this Order may use such material solely for the prosecution and defense of this action, any appeals thereto, and any alternative dispute resolution proceeding intended to resolve this action with prior express permission of the producing party, and not for any other purpose or in any other litigation proceeding. Nothing contained in this Order, however, will affect or restrict the rights of any Party with respect to its own documents or information produced in this action. Nor shall anything contained in this Order prejudice a Party's ability to seek discovery in this and any other legal proceeding, without prejudice to any other Party's right to object to such discovery. + +17. Nothing in this Order will prevent any Party from producing any Confidential Discovery Material in its possession in response to a lawful subpoena or other compulsory + +process, or if required to produce by law or by any government agency having jurisdiction, provided that, unless precluded by applicable laws or rules, such Party gives written notice to the Producing Party as soon as reasonably possible, and if permitted by the time allowed under the request, at least 10 days before any disclosure. Upon receiving such notice, the Producing Party will bear the burden to oppose compliance with the subpoena, other compulsory process, or other legal notice if the Producing Party deems it appropriate to do so. + +18. Each person who has access to Discovery Material designated as Confidential pursuant to this Order must take all reasonable precautions to prevent the unauthorized or inadvertent disclosure of such material. + +19. If a Receiving Party receives documents or other materials that it has reason to believe are subject to a good faith claim of attorney-client privilege, work product protection, or other privilege or immunity from disclosure, the Receiving Party must refrain from examining the documents or other materials any more than is essential to ascertain whether the documents or other materials are reasonably subject to such a claim. The Receiving Party shall promptly notify the producing person in writing that the Receiving Party possesses documents or other material that appears to be privileged or otherwise protected from disclosure. + +20. If, in connection with this litigation, a producing person inadvertently discloses information that is subject to a claim of attorney-client privilege, attorney work product protection, or any other privilege or immunity from disclosure ("Inadvertently Disclosed Information"), such disclosure shall not constitute or be deemed a waiver or forfeiture of any claim of privilege, work product protection, or other privilege or immunity from discovery with respect to the Inadvertently Disclosed Information or its subject matter. In addition, a producing person may use its own document (e.g., as a deposition exhibit) containing material that is + +subject to a claim of privilege or immunity from disclosure for the purpose of establishing the basis of such claim without waiver of any applicable privilege or immunity from disclosure, unless the producing person affirmatively uses or relies upon the specific material contained in the document that is subject to the claim of privilege or immunity from disclosure for any purpose other than establishing the basis of such claim. + +21. If a producing person makes a claim of inadvertent disclosure, the Receiving Party shall, within five business days, return or destroy all copies of the Inadvertently Disclosed Information, and provide a certification of counsel that all such information has been returned or destroyed, unless the Receiving Party seeks to dispute that the information is privileged or otherwise protected as set forth below. Until the dispute is resolved or ruled upon, the Receiving Party shall undertake to keep such information restricted solely for use in connection with the dispute over the privilege or protection. + +22. Within five business days after the notification that such Inadvertently Disclosed Information has been returned or destroyed, the producing person shall produce a privilege log with respect to the Inadvertently Disclosed Information. + +23. The Receiving Party may move the Court for an Order compelling production of the Inadvertently Disclosed Information. Pursuant to the parties' obligations set forth herein, the motion shall not quote or paraphrase the substance of the document subject to the motion to compel beyond the description of the document contained in the privilege log entry for the document. The motion shall be filed under seal, and shall not assert as a ground for entering such an Order the fact or circumstances of the inadvertent production in this action. + +24. The Producing Party retains the burden of establishing the privileged or protected nature of any Inadvertently Disclosed Information. Nothing in this Order shall limit the right of + +any Producing Party or Receiving Party to request an in camera review of the Inadvertently Disclosed Information. + +25. Unless the parties otherwise agree or a court of competent jurisdiction otherwise orders, within 60 days of the final disposition of this action—including all appeals—all Receiving Parties must either return Confidential Discovery Material—including all copies thereof—to the Producing Party, or destroy such material—including all copies thereof. In either event, by the 60-day deadline, the Receiving Party must certify its return or destruction by submitting a written certification to the Producing Party that affirms that it has not retained any copies, abstracts, compilations, summaries, or other forms of reproducing or capturing any of the Confidential Discovery Material. Notwithstanding the foregoing: (i) Discovery Materials that have been received electronically and that cannot be returned or destroyed must be electronically deleted and deleted from "trash" files, and the Receiving Party must take reasonable measures to ensure that unauthorized persons do not have access to Confidential information residing on the Receiving Party's computer server and back-up media; and (ii) outside counsel for the parties are permitted to retain one archival copy of all pleadings, motion papers, court filings made under seal, transcripts, legal memoranda, correspondence, attorney work product, written discovery responses, deposition and trial exhibits, and expert reports, even if such materials contain Confidential Discovery Material, subject to a continuing obligation to protect information designated Confidential pursuant to this Order. + +26. This Order will survive the termination of the litigation and will continue to be binding upon each Receiving Party. + +27. This Court will retain jurisdiction over all persons subject to this Order to the extent necessary to enforce any obligations arising hereunder or to impose sanctions for any contempt thereof. + +SO STIPULATED AND AGREED. + +TROUTMAN SANDERS LLP + +/s/ Bennet .1. Moskowitz + +Bennet J. Moskowitz 875 Third Avenue New York, New York 10022 (212) 704-6000 bennet.moskowitz@troutman.com + +Counsel for Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E Epstein + +Dated: May 21, 2020 + +SO ORDERED. + +Dated: New York, New York BOLES SCHILLER FLEXNER LLP + +/s/ Sigrid McCawley + +Sigrid McCawley 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 smccawley@bsfllp.com + +Counsel for Plaintiff + +Dated: May 21, 2020 + +## Exhibit A to Stipulated Confidentiality Agreement and Protective Order + +#### UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK + +Plaintiff, CASE NO: 19-cv-10479-ALC-DCF + +v. + +DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +## NON-DISCLOSURE AGREEMENT + +acknowledge that I have read and understand the Protective Order in this action governing the non-disclosure of those portions of Discovery Material that have been designated as Confidential. I agree that I will not disclose such Confidential Discovery Material to anyone other than for purposes of this litigation and that at the conclusion of the litigation I will return all discovery information to the Party or attorney from whom I received it. 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INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +# STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER + +WHEREAS, Plaintiff and Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, (collectively, the "Parties" and each individually, a "Party") request that this Court issue a protective order pursuant to Federal Rule of Civil Procedure 26(c) to protect the confidentiality of nonpublic and sensitive information that they may need to disclose in connection with discovery in this action; + +WHEREAS, the Parties, through counsel, agree to the following terms; and + +WHEREAS, this Court finds that good cause exists for issuance of an appropriately tailored confidentiality order governing the pretrial phase of this action: + +IT IS HEREBY ORDERED that the Parties to this action, their respective agents, employees, and attorneys, any other person in active concert or participation with any of the foregoing, and all other persons with actual notice of this Order will adhere to the following terms, upon pain of contempt: + +- 1. "Producing Party" shall mean the parties to this action and any third parties producing Confidential Information. +- 2. "Receiving Party" shall mean the party to this action and/or any non-party receiving Confidential Information. +- 3. With respect to "Discovery Material" (i.e., documents, information or tangible things of any kind produced or disclosed in the course of discovery in this action) that a Producing Party has designated as "Confidential" pursuant to this Order, no Receiving Party may disclose such Confidential Discovery Material to anyone else except as expressly permitted hereunder. +- 4. The Producing Party may designate as Confidential only the portion of such material that it reasonably and in good faith believes consists of: + - (a) medical, mental health and/or other health care records; + - (b) Social Security numbers, personal telephone numbers, tax returns, and credit and banking information of any person; + - (c) names of alleged minor victims of sexual abuse; + - (d) previously non-disclosed financial information; + - (e) non-public information that the producing person in good faith considers to be, reflect, or reveal business, marketing, financial, or regulatory information or data, or information of commercial value, including, without limitation, trade secrets, contracts with third parties, or other information required by law or agreement to be kept confidential; + +(f) any %.• Ma %AM tla. 01 WO as,,,, in WI. MS la /ell I ulIal, and Pic + +(g) any other category of information given confidential status by this Court after the date of this Order. + +5. With respect to the Confidential portion of any Discovery Material other than deposition transcripts and exhibits, the Producing Party or its counsel may designate such portion as "Confidential" by: (a) stamping or otherwise clearly marking as "Confidential" the protected portion in a manner that will not interfere with legibility or audibility; and (b) producing for future public use another copy of said Discovery Material with the confidential information redacted. + +6. A Producing Party or its counsel may designate deposition exhibits or portions of deposition transcripts as Confidential Discovery Material either by: (a) indicating on the record during the deposition that a question calls for Confidential information, in which case the reporter will bind the transcript of the designated testimony in a separate volume and mark it as "Confidential Information Governed by Protective Order;" or (b) notifying the reporter and all counsel of record, in writing, within 30 days after a deposition has concluded, of the specific pages and lines of the transcript that are to be designated "Confidential," in which case all counsel receiving the transcript will be responsible for marking the copies of the designated transcript in their possession or under their control as directed by the Producing Party or that person's counsel. During the 30-day period following a deposition. all Parties will treat the entire deposition transcript as if it had been designated Confidential. + +7. If at any time before the termination of this action a Producing Party realizes that it should have designated as Confidential some portion(s) of Discovery Material that it previously produced without limitation, the Producing Party may so designate such material by + +notifying all Parties in writing. Thereafter, the Receiving Party will treat such designated portion(s) of the Discovery Material as Confidential. In addition, the Producing Party shall provide each Receiving Party with replacement versions of such Discovery Material that bears the "Confidential" designation within two business days of providing such notice. + +8. Nothing contained in this Order will be construed as: (a) a waiver by a Party or person of its right to object to any discovery request; (b) a waiver of any privilege or protection; or (c) a ruling regarding the admissibility at trial of any document, testimony, or other evidence. + +9. Where a Producing Party has designated Discovery Material as Confidential, the Receiving Party may disclose such information only to the following persons: + +- (a) the Parties to this action; +- (b) counsel retained specifically for this action, including any paralegal, clerical, or other assistant that such outside counsel employs and assigns to this matter; +- (c) outside vendors or service providers (such as copy-service providers and document-management consultants) that counsel hire and assign to this matter, provided such person has first executed a Non-Disclosure Agreement in the form annexed as Exhibit A hereto; +- (d) any mediator or arbitrator that the Parties engage in this matter or that this Court appoints, provided such person has first executed a Non-Disclosure Agreement in the form annexed as Exhibit A hereto; +- (e) as to any document, its author, its addressee, and any other person indicated on the face of the document as having received a copy; + +(f) any witness who counsel for a Party in good faith believes may be called to testify at trial or deposition in this action, provided such person has first executed a Non-Disclosure Agreement in the form annexed as Exhibit A hereto; + +(g) any person a Party retains to serve as an expert witness or otherwise provide specialized advice to counsel in connection with this action, provided such person has first executed a Non-Disclosure Agreement in the form annexed as Exhibit A hereto; + +(h) stenographers engaged to transcribe depositions the Parties conduct in this action; and + +(i) this Court, including any appellate court, its support personnel, and court reporters. + +10. Before disclosing any Confidential Discovery Material to any person referred to in subparagraphs 9(c), 9(d), 9(f), or 9(g) above, counsel must provide a copy of this Order to such person, who must sign a Non-Disclosure Agreement in the form annexed as Exhibit A hereto stating that he or she has read this Order and agrees to be bound by its terms. Said counsel must retain each signed Non-Disclosure Agreement, hold it in escrow, and produce it to opposing counsel either before such person is permitted to testify (at deposition or trial) or at the conclusion of the case including any and all appeals, whichever comes first. + +II. For the avoidance of doubt, nothing in Paragraph 9 shall impose any limitation on the ability of a Producing Party to disclose its own Confidential Discovery Material. A Producing Party shall not be required to obtain an executed Non-Disclosure Agreement from its own current or former employees with respect to disclosure of its own Confidential Discovery Material. + +12. This Order binds the Parties and certain others to treat as Confidential any Discovery Materials so classified. The Court has not, however, made any finding regarding the confidentiality of any Discovery Materials, and retains full discretion to determine whether to afford confidential treatment to any Discovery Material designated as Confidential hereunder. All persons are placed on notice that the Court is unlikely to seal or otherwise afford confidential treatment to any Discovery Material introduced into evidence at trial, even if such material has previously been sealed or designated as Confidential. + +13. In filing Confidential Discovery Material with this Court, or filing portions of any pleadings, motions, or other papers that disclose such Confidential Discovery Material ("Confidential Court Submission"), the Parties shall publicly file a redacted copy of the Confidential Court Submission via the Electronic Case Filing System. The Parties shall file an unredacted copy of the Confidential Court Submission under seal with the Clerk of this Court, and the Parties shall serve this Court and opposing counsel with unredacted courtesy copies of the Confidential Court Submission. Any Party that seeks to file Confidential Discovery Material under seal must file an application and supporting declaration justifying—on a particularized basis—the sealing of such documents. The parties should be aware that the Court will unseal documents if it is unable to make "specific, on the record findings ... demonstrating that closure is essential to preserve higher values and is narrowly tailored to serve that interest." Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 120 (2d Cir. 2006). Notwithstanding any other provision of this paragraph, if the parties stipulate that specific portions of a document are both confidential and immaterial to this lawsuit, a party may publicly file a version of the document with those confidential and immaterial portions redacted, and that party need not submit an unredacted version to the Court or file a motion to seal. + +14. Any Party who objects to any designation of confidentiality may at any time before the trial of this action serve upon counsel for the Producing Party a written notice stating with particularity the grounds of the objection. If the Parties cannot reach agreement promptly, counsel for all affected Parties will address their dispute to the Court by motion. The Party seeking confidentiality shall bear the burden of establishing that the material at issue was properly designated as confidential. The Parties shall treat the disputed materials as Confidential pending the Court's resolution of such motion. + +15. Any Party who requests additional limits on disclosure (such as "attorneys' eyes only" in extraordinary circumstances), may at any time before the trial of this action serve upon counsel for the recipient Parties a written notice stating with particularity the grounds of the request. If the Parties cannot reach agreement promptly, counsel for all affected Parties will address their dispute to the Court. + +16. Absent an Order from a court of competent jurisdiction, Recipients of Confidential Discovery Material under this Order may use such material solely for the prosecution and defense of this action, any appeals thereto, and any alternative dispute resolution proceeding intended to resolve this action with prior express permission of the producing party, and not for any other purpose or in any other litigation proceeding. Nothing contained in this Order, however, will affect or restrict the rights of any Party with respect to its own documents or information produced in this action. Nor shall anything contained in this Order prejudice a Party's ability to seek discovery in this and any other legal proceeding, without prejudice to any other Party's right to object to such discovery. + +17. Nothing in this Order will prevent any Party from producing any Confidential Discovery Material in its possession in response to a lawful subpoena or other compulsory + +process, or if required to produce by law or by any government agency having jurisdiction, provided that, unless precluded by applicable laws or rules, such Party gives written notice to the Producing Party as soon as reasonably possible, and if permitted by the time allowed under the request, at least 10 days before any disclosure. Upon receiving such notice, the Producing Party will bear the burden to oppose compliance with the subpoena, other compulsory process, or other legal notice if the Producing Party deems it appropriate to do so. + +18. Each person who has access to Discovery Material designated as Confidential pursuant to this Order must take all reasonable precautions to prevent the unauthorized or inadvertent disclosure of such material. + +19. If a Receiving Party receives documents or other materials that it has reason to believe are subject to a good faith claim of attorney-client privilege, work product protection, or other privilege or immunity from disclosure, the Receiving Party must refrain from examining the documents or other materials any more than is essential to ascertain whether the documents or other materials are reasonably subject to such a claim. The Receiving Party shall promptly notify the producing person in writing that the Receiving Party possesses documents or other material that appears to be privileged or otherwise protected from disclosure. + +20. If, in connection with this litigation, a producing person inadvertently discloses information that is subject to a claim of attorney-client privilege, attorney work product protection, or any other privilege or immunity from disclosure ("Inadvertently Disclosed Information"), such disclosure shall not constitute or be deemed a waiver or forfeiture of any claim of privilege, work product protection, or other privilege or immunity from discovery with respect to the Inadvertently Disclosed Information or its subject matter. In addition, a producing person may use its own document (e.g., as a deposition exhibit) containing material that is + +subject to a claim of privilege or immunity from disclosure for the purpose of establishing the basis of such claim without waiver of any applicable privilege or immunity from disclosure, unless the producing person affirmatively uses or relies upon the specific material contained in the document that is subject to the claim of privilege or immunity from disclosure for any purpose other than establishing the basis of such claim. + +21. If a producing person makes a claim of inadvertent disclosure, the Receiving Party shall, within five business days, return or destroy all copies of the Inadvertently Disclosed Information, and provide a certification of counsel that all such information has been returned or destroyed, unless the Receiving Party seeks to dispute that the information is privileged or otherwise protected as set forth below. Until the dispute is resolved or ruled upon, the Receiving Party shall undertake to keep such information restricted solely for use in connection with the dispute over the privilege or protection. + +22. Within five business days after the notification that such Inadvertently Disclosed Information has been returned or destroyed, the producing person shall produce a privilege log with respect to the Inadvertently Disclosed Information. + +23. The Receiving Party may move the Court for an Order compelling production of the Inadvertently Disclosed Information. Pursuant to the parties' obligations set forth herein, the motion shall not quote or paraphrase the substance of the document subject to the motion to compel beyond the description of the document contained in the privilege log entry for the document. The motion shall be filed under seal, and shall not assert as a ground for entering such an Order the fact or circumstances of the inadvertent production in this action. + +24. The Producing Party retains the burden of establishing the privileged or protected nature of any Inadvertently Disclosed Information. Nothing in this Order shall limit the right of + +any Producing Party or Receiving Party to request an in camera review of the Inadvertently Disclosed Information. + +25. Unless the parties otherwise agree or a court of competent jurisdiction otherwise orders, within 60 days of the final disposition of this action—including all appeals—all Receiving Parties must either return Confidential Discovery Material—including all copies thereof—to the Producing Party, or destroy such material—including all copies thereof. In either event, by the 60-day deadline, the Receiving Party must certify its return or destruction by submitting a written certification to the Producing Party that affirms that it has not retained any copies, abstracts, compilations, summaries, or other forms of reproducing or capturing any of the Confidential Discovery Material. Notwithstanding the foregoing: (i) Discovery Materials that have been received electronically and that cannot be returned or destroyed must be electronically deleted and deleted from "trash" files, and the Receiving Party must take reasonable measures to ensure that unauthorized persons do not have access to Confidential information residing on the Receiving Party's computer server and back-up media; and (ii) outside counsel for the parties are permitted to retain one archival copy of all pleadings, motion papers, court filings made under seal, transcripts, legal memoranda, correspondence, attorney work product, written discovery responses, deposition and trial exhibits, and expert reports, even if such materials contain Confidential Discovery Material, subject to a continuing obligation to protect information designated Confidential pursuant to this Order. + +26. This Order will survive the termination of the litigation and will continue to be binding upon each Receiving Party. + +27. This Court will retain jurisdiction over all persons subject to this Order to the extent necessary to enforce any obligations arising hereunder or to impose sanctions for any contempt thereof. + +SO STIPULATED AND AGREED. + +TROUTMAN SANDERS LLP + +/s/ Bennet .1. Moskowitz + +Bennet J. Moskowitz 875 Third Avenue New York, New York 10022 (212) 704-6000 bennet.moskowitz@troutman.com + +Counsel for Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey £ Epstein + +Dated: May 21, 2020 + +SO ORDERED. + +Dated: 5/22/2020 New York, New York BOLES SCHILLER FLEXNER LLP + +/s/ Sigrid McCawley + +Sigrid McCawley 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 smccawley@bsfllp.com + +Counsel for Plaint(g + +Dated: May 21, 2020 + +Adopted, as modified in paragraph 4. In addition, any application to maintain the confidentiality of documents or information presented at trial shall be made to the trial judge, in advance of trial. + +Agar gortire---\_\_ + +DEBRA FREEMAN United States Magistrate Judge or + +## Exhibit A to Stipulated Confidentiality Agreement and Protective Order + +#### UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK + +Plaintiff, CASE NO: 19-cv-10479-ALC-DCF + +v. + +DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +## NON-DISCLOSURE AGREEMENT + +acknowledge that I have read and understand the Protective Order in this action governing the non-disclosure of those portions of Discovery Material that have been designated as Confidential. I agree that I will not disclose such Confidential Discovery Material to anyone other than for purposes of this litigation and that at the conclusion of the litigation I will return all discovery information to the Party or attorney from whom I received it. 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INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +Case No. 1:19-cv-10479 (ALC) (DCF) + +## DEFENDANTS' REPLY MEMORANDUM OF LAW IN SUPPORT OF THEIR MOTION TO DISMISS PLAINTIFF'S COMPLAINT + +TROUTMAN SANDERS LLP + +875 Third Avenue + +New York, New York 10022 + +Tel: 212-704-6000 + +Fax: 212-704-6288 + +Attorneys for Defendants + +# TABLE OF CONTENTS + +| | Page | +|---------------------------------------------------------------------------|------------------------------------------------------------------------------| +| PRELIMINARY STATEMENT | 1 | +| ARGUMENT | 1 | +| I. New York's borrowing statute applies to Plaintiff's claims because her | | +| resident | 1 | +| I1. The 20-year limitations period in CPLR § 213-c does not apply | | +| retroactively or to torts allegedly committed outside New York | 3 | +| III. | Plaintiff is unable to invoke CPLR § 215(8)(a) because she fails to assert a | +| her. | 4 | +| IV. | Plaintiff fails to meet her burden to allege "extraordinary" circumstances | +| sufficient to invoke equitable estoppel or tolling | 6 | +| V. Judge Engelmayer recently dismissed two other plaintiffs' punitive | | +| raises here | 7 | +| CONCLUSION | 10 | + +# TABLE OF AUTHORITIES + +| Cases Bache Halsey Stuart Inc. v. Namm, 446 F. Supp. 692 (S.D.N.Y. 1978) Banks v. Intl Rental & Leasing Corp., | Page(s) 2 | +|--------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------| +| 55 V.I. 967 (2011) Blisset v. Eisensmidt, 940 F. Supp. 499 (N.D.N.Y. 1996) v. Parkchester S. Condos., 287 F.3d 58 (2d Cu.r 2002) Carson Optical Inc. v. eBay Inc., | 10 | +| 202 F. Supp. 3d 247 (E.D.N.Y. 2016) Corcoran v. New York Power Auth., | 3 | +| No. 95 CIV. 5357 (DLC), 1997 WL 603739 (S.D.N.Y. Sept. 29, 1997) Crabtree ex rel. Kemp v. Estate of Crabtree, | 4 | +| 837 N.E.2d 135 (Ind. 2005) | 10 | +| No. 15-CV-5359 (KMK), 2016 WL 5720811 (S.D.N.Y. Sept. 30, 2016) Doe 15 v. Indyke, | 7 | +| No. 19-cv-10653 (PAE), 2020 WL 2086194 (S.D.N.Y. Apr. 30, 2020) Doe v. Indyke, | 8, 9, 10 | +| No. 19-cv-10758 (PAE), 2020 WL 2036707 (S.D.N.Y. Apr. 28, 2020) Funk v. Belneftekhim, Gen. Stencils, Inc. v. Chiappa, | 7, 8, 9, 10 | +| 219 N.E.2d 169 (N.Y. 1966) Gold v. Katz, | 7 | +| No. 90 CIV. 7726 (RLC), 1991 WL 237807 (S.D.N.Y. Nov. 4, I991).. Godin v. Lederman, | .2 | +| No. 05-CV-1899 (ILO), 2006 WL 1154817 (E.D.N.Y. Apr. 28, 2006). | .7 | + +| Guobadia v. Irowa, | | +|------------------------------------------------------------------------------------------|---------| +| 103 F. Supp. 3d 325 (E.D.N.Y. 2015) Kashef v. BNP Paribas S.A., | 7 | +| 925 F.3d 53 (2d Cir. 2019) Lettis v. U.S. Postal Serv., | 6 | +| 39 F. Supp. 2d 181 (E.D.N.Y. 1998) | 4 | +| In re Merrill Auction Rate Sec. Litig., | | +| 851 F. Supp. 2d at 544 (S.D.N.Y. 2012) Nash v. Coram Healthcare Corp., | 8 | +| 1996) Nat'l Jewish Democratic Council v. Adelson, | 8 | +| 2019) People v. McLaughlin, | 9 | +| 80 N.Y.2d 466 (1992) Texas v. Florida, | 4 | +| 306 U.S. 398 (1939) Whitley v. Bowden, | 2 | +| No. 17-cv-3564 (KMK), 2018 WL 2170313 (S.D.N.Y. May 9, 2018) Willis v. Westin Hotel Co., | 3 | +| 651 F. Supp. 598 (S.D.N.Y. 1986) Wilson v. Erra, | 2 | +| 94 A.D.3d 756, 942 N.Y.S.2d 127 (2012) Statutes | 4 | +| 97 NY Jur Statutes § 185 | 6 | +| CPLR § 213-c | I, 3, 4 | +| CPLR § 215(8Xa) | I, 4, 5 | +| E.P.T.L. § I 1-3.2(a)(1) | 9 | +| New York Child Victims Act | 8 | +| Rule 12(bX6) and Rule 12(f) | 8 | + +# Other Authorities + +The Co-Executors' submit this reply memorandum of law in support of their motion to dismiss Plaintiff's Complaint (ECF No. 1). + +# PRELIMINARY STATEMENT + +In her opposition brief, Plaintiff asks the Court to depart from well-established law to resuscitate her claims that expired over a decade ago. First Plaintiff attempts to create a nonexistent issue of fact — which does not alter the result of the proper legal analysis in any event regarding her residence, which she unequivocally alleges was not in New York. Second, Plaintiff asks the Court to disregard basic principles of statutory interpretation and numerous cases applying CPLR §§ 213-c and 215(8)(a) to support her erroneous application of those rules. Third, Plaintiff asks the Court to disregard Second Circuit authority holding that it is Plaintiff's burden to allege "extraordinary circumstances" to toll the applicable statutes of limitations, which she fails to do here. Fourth, Plaintiff urges this Court to permit her to seek punitive damages notwithstanding that, in two other actions against the Co-Executors involving similar claims, Judge Engelmayer dismissed claims for punitive damages in the face of the very arguments Plaintiff raises here. The Court should reject Plaintiff's arguments. + +## ARGUMENT + +## I. New York's borrowing statute applies to Piaintiff's claims because her own allegations firmly establish she was not, and is not, a New York resident. + +As laid out in the Co-Executors' moving papers, the New York borrowing statute requires dismissal of Plaintiff's claims to the extent that they are based on torts that allegedly occurred in France, New Mexico, and the USVI, as such claims are time-barred by the applicable laws of those + +I Capitalized terms not defined herein have the meanings ascribed to them in the Co-Executors' moving brief (ECF No. 24). + +jurisdictions. (Mov. Br. pp. 4-6.) In a failed attempt to avoid this result, Plaintiff now attempts to manufacture a fact issue regarding her residency.2 (Op. Br. p. 15.) + +Not only is this argument unsupported by case law, it is directly contradicted by Plaintiff's own allegations in her Complaint. Plaintiff argues that her "Complaint alleges that Plaintiff was a New York resident at all relevant times." (Op. Br. p. 15.) However, nowhere in her Complaint does Plaintiff claim New York domicile or residency. Rather, in addition to expressly alleging that "Plaintiff is a citizen and resident of South Africa," all other supporting facts alleged in Plaintiff's Complaint -- including that she met Decedent when he was visiting Cape Town, that she repeatedly would "travel to the United States" "for one to two weeks at a time," and that she "flew home to South Africa" (Comp1.11 16, 38, 46, & 50) -- confirm her claimed South African residency. + +Plaintiff further argues that there is a factual question regarding her New York residency because "she had always wanted to live in New York, Epstein's co-conspirators got Plaintiff a visa so that she could travel to New York often, and when she visited she stayed at Epstein's New York home for one to two weeks at a time." (Op. Br. p. 15). None of these allegations, even if true, would suffice to establish Plaintiff's residency in New York under the New York borrowing statute. See Gold v. Katz, No. 90 CIV. 7726 (RLC), 1991 WL 237807, at •2 (S.D.N.Y. Nov. 4, 1991) ("The test for domicile has two elements: '(r]esidence in fact, coupled with the purpose to make the place of residence one's home.'" (quoting Texas v. Florida, 306 U.S. 398, 424 (1939)); Bache Halsey Stuart Inc. v. Namm, 446 F. Supp. 692, 695 (S.D.N.Y. 1978Xin determining + +2 "An individual can have only one state of residence for purposes of the borrowing statute, and that is the state of his domicile." Bache Halsey Swan Inc. v. Namm, 446 F. Supp. 692, 694 (S.D.N.Y. 1978). Furthermore, lain individual's residence at the time a lawsuit is commenced provides prima facie evidence of his domicile." Willis v. Westin Hotel Co., 651 F. Supp. 598, 601 (S.D.N.Y. 1986). Plaintiff's Complaint expressly states that "Plaintiff is a citizen and resident of South Africa." (Compl. r 16). Therefore, New York's borrowing statute applies. + +residency under the borrowing statute, "[w]hat is vital is whether the Namms' Connecticut or New York residence is where they intended to maintain their home"). On their face, allegations that Plaintiff needed a visa to visit New York reveal her current claims of residency are nothing more than an after-the-fact concoction. + +Furthermore, even if Plaintiff had also alleged in her Complaint that she was a New York resident -- which she did not do -- such an allegation would not preclude dismissal of her claims in the face of her numerous allegations establishing she was not a New York resident during the relevant time period. "'Where [the] plaintiff's own pleadings are internally inconsistent, a court is neither obligated to reconcile nor accept the contradictory allegations in the pleadings as true in deciding a motion to dismiss."' Whitley v. Bowden, No. 17-cv-3564 (KMK), 2018 WL 2170313, at \*11 (S.D.N.Y. May 9, 2018) (quoting Carson Optical Inc. v. eBay Inc., 202 F. Supp. 3d 247, 255 (E.D.N.Y. 2016)). + +Finally, even if New York's borrowing statute does not apply, for the reasons set forth in the Co-Executors' moving brief and herein, Plaintiff's claims are still untimely under New York law. + +## II. The 20-year limitations period in CPLR § 213-c does not apply retroactively or to torts allegedly committed outside New York. + +In her opposition brief, Plaintiff argues that CPLR § 213-c, which provides a 20-year limitations period for certain civil claims based on sexual offenses that constitute specific New York penal law violations, revives her claims. Plaintiff's argument fails for at least two reasons. + +First, the 20-year limitations period in CPLR § 213-c does not apply to Plaintiff's claims because they were already time-barred by 2007 at the latest, which was long before the nonretroactive 20-year limitations period in CPLR § 213-c became effective. The 20-year limitations period in CPLR § 213-c became effective as of September 18, 2019; the previous limitation period therein was 5 years as of 2006 and 1 year before then. L. 2006, ch. 3, § 5(b). The law enacting the 20-year limitations period unequivocally states that it does not apply retroactively except "where the applicable statute of limitations in effect on the date of such act or omission has not yet expired." L. 2019, ch. 315, § 4. Here, Plaintiff's claims expired over a decade before the 20-year statute of limitations became effective—so it is inapplicable. + +Second Plaintiffs allegations of torts occurring outside New York cannot constitute violations of New York penal law that serve as necessary predicates to the application of CPLR § 213-c. See People v. McLaughlin, 80 N.Y.2d 466, 471 (1992) ("Because the State only has power to enact and enforce criminal laws within its territorial borders, there can be no criminal offense unless it has territorial jurisdiction"). In an attempt to avoid this well-established principle, Plaintiff argues that her claims based on torts that occurred outside New York still somehow accrued under New York law. This argument is both nonsensical and contrary to other black-letter law. See Corcoran v. New York Power Auth., No. 95 CIV. 5357 (DLC), 1997 WL 603739, at •5 (S.D.N.Y. Sept. 29, 1997) ("An action for battery accrues when the nonconsensual offensive contact occurs."); Lettis v. U.S. Postal Serv., 39 F. Supp. 2d 181, 204 (E.D.N.Y. 1998) ("Causes of action for assault and battery accrue immediately upon the occurrence of the- tortious act"); Wilson v. Erra, 94 A.D.3d 756, 756, 942 N.Y.S.2d 127, 129 (2012) ("A cause of action alleging intentional infliction of emotional distress accrues on the date of injury"). + +#### III. Plaintiff is unable to invoke CPLR § 215(8Xa) because she fails to assert a criminal i nd let ment that arises from Decedent's alleged conduct towards her. + +In her opposition brief, Plaintiff confirms her allegation is that she did not even meet Decedent until she was already an adult. Nonetheless, Plaintiff continues to urge the application of CPLR § 215(8)(a) to this action based on an Indictment charging Decedent with sex trafficking of minors. However, to invoke CPLR § 215(8)(a), Plaintiff is required to assert allegations + +establishing the Indictment and this lawsuit arise from the same "event or occurrence." Plaintiff fails to do this. + +Instead, Plaintiff attempts to recast the Indictment as broader in scope than its contents allow. Specifically, Plaintiff takes two allegations concerning Decedent's purported actual knowledge of the age of some of the "minor victims" out of context to imply adult women were the subject of the Indictment. (Op. Br. p. 6).3 This is disingenuous. The Indictment does not reference any adult victims. Rather, all the facts alleged in the indictment refer to Decedent's alleged conduct towards "minor girls" or "minor victims" (Indictment at ¶¶ 1-4, 6, 8, 11-15 18- 19, et seq.); and the two counts of the indictment, for Sex Trafficking Conspiracy and Sex Trafficking, charge crimes involving minors (id at ¶¶ 20 & 24). + +Plaintiff next tries to expand the scope of CPLR § 215(8Xa)'s "event or occurrence" requirement. However, the cases cited in the Co-Executors' moving brief confirm that, even where it is undisputed that the subject criminal indictment concerns the civil plaintiff and the same kind of conduct alleged in the plaintiff's civil complaint, CPLR § 215(8Xa) still does not apply where the indictment and civil action arise from different events or occurrences. (See Mov. Br. pp. 7-10.) Plaintiff's attempt to distinguish these cases on the ground that they "focused on events that occurred on specified dates" (Op. Br., p. 8) is based on Plaintiff's dubious assertion that, because the Indictment at issue here "was not limited to a specific day or discrete event" (id., p. 10), anyone alleging she suffered the same type of misconduct described in the Indictment is free to invoke CPLR § 215(8Xa). Such a reading is s contrary to basic + +3 The full sentences in the Indictment which Plaintiff references are as follows: "JEFFREY EPSTEIN, the defendant, knew that many of his New York victims were underage, including because certain victims told him their age;" and "JEFFREY EPSTEIN, the defendant, knew that certain of his victims were underage, including because certain victims told him their age." (Indictment at ¶¶ I I & 17.) + +principles of statutory interpretation prohibiting a reading of a statute that would render its words meaningless (see 97 NY Jur Statutes § 185), the case law cited in the Co-Executors' moving brief, a plain reading of the Indictment and common sense.4 + +#### IV. Plaintiff fails to meet her burden to allege "extraordinary" circumstances sufficient to invoke equitable estoppel or tolling. + +Plaintiff misstates the pleading burden with respect to equitable estoppel and tolling, asserting that "Defendants have failed to meet their burden of showing that [she] will be unable to invoke equitable estoppel and equitable tolling." (Op. Br. p. I.) Plaintiff has it backwards. As explained in the Co-Executors' moving brief, the burden is on Plaintiff to sufficiently allege "extraordinary circumstances" to invoke these doctrines. (Mov. Br. pp. I, 12-15.) + +In her opposition brief, Plaintiff does not address many of the cases that the Co-Executors cite on this point, but rather attempts to buttress her Complaint by painting a slightly more detailed (but still insufficient) picture of why she waited 15 years to bring this action. However, Plaintiff's Complaint is controlling. In her Complaint, Plaintiff does not allege: any particularized acts by Decedent that prevented her from exercising her rights; that Decedent made a misrepresentation to her and had reason to believe she would rely on it; or that she reasonably relied on any misrepresentation by Decedent to her detriment. + +Excluding vague allegations concerning Decedent's alleged misconduct directed at some unidentified set of alleged victims that does not include Plaintiff (see, e.g., Comp!. y 26 ("[Decedentj utilized his seemingly unlimited power, wealth, and resources... intimidate and manipulate his victims"),5 Plaintiff primarily alleges her impressions and emotions between + +Plaintiff also once again relies on Kashef v. BNP Paribas S.A., 925 F.3d 53 (2d Cir. 2019), notwithstanding that the Co-Executors already demonstrated that it is distinguishable from this action. (Mov. Br. p. 10.) + +s Many of Plaintiff's allegations are cut-and-pasted from the complaints of other plaintiffs represented by the same counsel and lack any ascribed basis other than Plaintiff's impression of Decedent's wealth. + +2002 and 2004, rather than Decedent's conduct. (Id. ¶ 44, 45, 48.) Not a single case Plaintiff cites supports a finding that such allegations satisfy the "extraordinary circumstances" pleading burden required to invoke estoppel or tolling. To the contrary, the cases Plaintiff cites are either inapplicable6 or confirm her allegations fall short of that threshold.7 + +While Plaintiff claims that "Epstein attempted to keep in contact with Juliette through email over the years" following Plaintiff's cutting tics with him in 2004, she cites to two emails that neither contain threats nor misrepresentations—hardly "extraordinary circumstances." In any event, the cited emails, which are dated to 2016 and 2019, cannot serve as justification for Plaintiff's failure to pursue her claims for the more-than-ten-year gap between when she "cut ties" with Decedent and when she corresponded with him. + +## V. Judge Engelmayer recently dismissed two other plaintiffs' punitive damages claims as a matter of law, rejecting the very arguments Plaintiff raises here. + +The Hon. Paul A. Engelmayer recently dismissed punitive damages claims on the pleadings in two other actions against the Co-Executors involving claims similar to those Plaintiff raises in this action. See e.g., Doe v. Indyke, No. 19-cv-10758 (PAE), 2020 WL 2036707, at \*1 (S.D.N.Y. + +Plaintiffs reliance on v. No. 15-CV-5359 (KMK), 2016 WL 5720811, at \*11 (S.D.N.Y. Sept. 30, 2016)—to support her assertion that reasonable fear of retaliation "may be sufficient" to warrant equitable tolling (Op. Br. p. 17)—is misleading. In that action, the court granted a pro se prisoner leave to allege facts sufficient to show he pursued his claims with reasonable diligence. Id. at \*39. However, the Court was clear that its findings were based on plaintiff's incarceration and pro se status. See id. at \*35, 39 ("in the prison context, reasonable fear of retaliation may be sufficient"; "given Plaintiff's pro se status ... the Court is hesitant to dismiss [his] claims"). As Plaintiff is neither a prisoner nor proceeding pro se, is inapplicable. + +7 In Funk v. Belnefiekhim, No. 14-CV-0376 (BMC), 2019 WL 3035124 (E.D.N.Y. July II, 2019), which Plaintiff also cites, the court found the plaintiffs "alleged extraordinary circumstances that could warrant the application of equitable tolling: they were drugged, kidnapped, flown to Belarus, held captive, and tortured for 383 and 483 days, respectively." Id. at \*2. There are no such allegations here. The other cases Plaintiff cites likewise support the conclusion she has not met her burden to allege extraordinary circumstances. See Gatlin v. Lederman, No. 05-CV-1899 (ILG), 2006 WL 1154817, at \*30 (E.D.N.Y. Apr. 28, 2006) (plaintiffs in medical malpractice action alleged defendants failed to provide them with, and intentionally and fraudulently attempted to discourage and prevent them from obtaining, their medical records); Gen. Stencils, Inc. v. Chiappa, 219 N.E.2d 169, 171 (N.Y. 1966) (plaintiff was allowed to invoke NM estoppel against a bookkeeper who had used his position to carefully conceal his theft of the plaintiff's money); v. Parkchester S. Condos., 287 F.3d 58, 59 (2d Cir. 2002) (employee argued his medical condition prevented him from timely filing his complaint); Guobadia v. Irowa, 103 F. Supp. 3d 325, 341 (E.D.N.Y. 2015) (plaintiff filed her lawsuit less than a year after leaving a home where she was allegedly forced to work without pay as a servant). + +Apr. 28, 2020) (granting motion to dismiss punitive damages against the Co-Executors); Doe 15 v. Indyke, No. 19-cv-10653 (PAE), 2020 WL 2086194, at \*1 (S.D.N.Y. Apr. 30, 2020) (same). In doing so, Judge Engelmayer correctly rejected each of the arguments Plaintiff asserts here in support of her request to continue to pursue her legally deficient claim for punitive damages. + +First, Judge Engelmayer rejected the argument that a motion to dismiss a legally deficient claim for punitive damages on the pleadings is procedurally improper: "where punitive damages have been unavailable as a matter of law, courts have not hesitated to dismiss prayers for such damages at the threshold." Doe, 2020 WL 2036707, at \*3; see also Doe 15, 2020 WL 2086194, at \*1. "[A]mple authority permits striking prayers for punitive damages where such relief is unavailable as a matter of law." Id. at \*4 (citing In re Merrill Auction Rate Sec. Litig., 851 F. Supp. 2d at 544).8 + +Discarding the "conceptual debate" between motions filed under Rule 12(bX6) and Rule 12(9, Judge Engelmayer further concluded that the Court could in any event dismiss claims for punitive damages sua sponte under Rule 12(f) because: "With numerous personal injury actions pending against the Epstein estate as a result of the recent enactment of the New York Child Victims Act, there is value in clarifying—for the parties and settlors—the damages available in actions where the law permits a sure answer on this point." Doe, 2020 WL 2036707, at \*5. The same practical wisdom applies here. + +Second, Judge Engelmayer rejected Mary Doe's and Jane Doe 15's attempts to apply United States Virgin Islands law to the issue of punitive damages, finding that the law of the place + +8 See also C. & A. M, 5C Fed. Prac. & Proc. Civ. § 1380 (3d ed.) ("the technical name given to a motion challenging a pleading is of little importance inasmuch as prejudice to the nonmoving party can hardly result from treating a motion that has been inaccurately denominated as a motion to strike as a motion to dismiss the complaint"); In re Merrill Auction Rate Sec. Litig., 851 F. Supp. 2d 512, 544 (S.D.N.Y. 2012) (granting defendant's motion to strike sections of first amended complaint asserting punitive damages); Nash v. Coram Healthcare Corp., No. 96 Civ. 0298 (LMM), 19% U.S. Dist. LEXIS 9101, at •I5 (S.D.N.Y. June 27, 1996) ("The motion to strike the punitive damages prayer from the Complaint is granted."). + +of the torts governs. Doe, 2020 WL 2036707, at \*5-6; Doe 15,2020 WL 2086194, at \*2 (S.D.N.Y. Apr. 30, 2020). As established in the Co-Executors' moving brief, none of the jurisdictions where Plaintiff alleges the torts occurred permits punitive damages against a deceased tortfeasor's estate. (ECF No. 24 pp. 16-18.) + +Moreover, Plaintiff here, like Mary Doe and Jane Doe 15, ignores Blisset v. Eisensmidt, 940 F. Supp. 499, 457 (N.D.N.Y. 1996). That well-reasoned decision establishes that Plaintiff may not have the Court simultaneously apply the first sentence of E.P.T.L. § 11-3.2(a)(1)—the portion of the statute permitting her to bring this action against the Co-Executors—but disregard the very next sentence precluding punitive damages. See Blisset, 940 F. Supp. at 457. To quote Judge Engelmayer, it would be "problematic for [Plaintiff] to cherrypick within that provision, invoking the part that authorizes a personal injury suit against an executor while disclaiming the balance, which delimits the recovery available in such a suit." Doe, 2020 WL 2036707, at \*6 (S.D.N.Y. Apr. 28, 2020) (citing Blisset, 940 F. Supp. at 457).9 + +Third Judge Engelmayer ruled that the choice-of-law debate (Le., New York law vs. USVI law) is "academic." Id. at \*7. "That is because, while the USVI does not have a statute on point and USVI courts have not squarely resolved the issue, it is likely that USVI common law would not permit an award of punitive damages against an estate." Id. See also Doe 15, 2020 WL 2086194.2 (S.D.N.Y. Apr. 30, 2020) ("Doe does not have any stronger argument than did Mary Doe that USVI law applies ... or, if it did, that it would permit such damages"). + +9 Like the plaintiffs in Mary Doe and Doe 15, Plaintiff also erroneously relies on Nat? Jewish Democratic Council v. Adelson, No. 18 Civ. 8787 (JPO), 2019 U.S. Dist. LEXIS 168675, (S.D.N.Y. Sept. 30, 2019). Even under the framework of Adelson, the place where a tort occurs has the greater interest in applying its laws and policies on punitive damages. Further, and as Judge Engelmayer found, Adelson is inapposite where, as here, the current lawsuit "does not build on a prior litigation in, or (is not) based on the law of, the USVI." See Mary Doe, 2020 WL 2036707, at •7. + +Plaintiff in this action misapplies the Banks analysis factors, which USVI courts use to determine common law. See Banks v. Intl Rental & Leasing Corp., 55 V.I. 967, 979 (2011). As Judge Engelmayer found, a proper Banks analysis demonstrates: (Factor 1) "USVI courts have repeatedly cited the Restatement (Second) of Torts § 908 favorably"; (Factor 2) consistent with the Restatement, most U.S. jurisdictions do not permit an award of punitive damages against a tortfeasor's estate; and (Factor 3) USVI courts appear comfortable with the majority rule. Doe, 2020 WL 2036707, at \*8. + +Plaintiff's remaining arguments fail for the same reasons applied by Judge Engelmayer in Mary Doe and Jane Doe 15. Plaintiff argues that, because the USVI Attorney General seeks punitive damages against the Estate in an unrelated civil racketeering lawsuit, punitive damages are allowed under USVI law. (Opp. at 22, n.9.) "But the decision by a government lawyer to attempt to obtain such damages in a high-profile case involving allegations of extreme conduct .. . do not speak to the question that the third Banks factor assays: which rule of law best durably servers the USVI's interests." Doe v. Indyke, 2020 WL 2036707, at \*8. + +Separately, Plaintiff's reliance on Crabtree a ref Kemp v. Estate of Crabtree, 837 N.E.2d 135, 139 (Ind. 2005), is misplaced. The court in that action held "Indiana law does not permit recovery of punitive damages from the estate of a deceased tortfeasor." + +# CONCLUSION + +For the reasons stated above and in their moving brief (ECF No. 24), the Co-Executors respectfully request that the Court grant their motion to dismiss, together with such other and further relief as the Court deems just and proper. + +Dated: New York, New York Respectfully submitted, May 26, 2020 + +TROUTMAN SANDERS LLP 875 Third Avenue New York, NY 10022 212.704.6000 + +By:/s/Bennet J. 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+ +21 + +22 + +23 + +24 + +25 + +, + +Plaintiff, New York, N.Y. + +v. 19 CV 10475 (LGS) + +DARREN K. INDYKE, in his Teleconference capacity as executor of the Estate of Jeffrey Edward May 22, 2020 Epstein; RICHARD D. KAHN, in 11:00 a.m. his capacity as executor of the Estate of Jeffrey Edward Epstein; and GHISLAINE MAXWELL, + +Defendants. + +x + +. 19 CV 10476 (PGG) + +v. + +Plaintiff, + +DARREN K. INDYKE, in his capacity as executor of the Estate of Jeffrey Edward Epstein and RICHARD D. KAHN, in his capacity as executor of the Estate of Jeffrey Edward Epstein, + +Defendants. + +v. + +x + +' + +19 CV 10479 (ALC) + +Plaintiff, + +DARREN K. INDYKE, in his capacity as executor of the Estate of Jeffrey Edward Epstein and RICHARD D. KAHN, in his capacity as executor of the Estate of Jeffrey Edward Epstein, + +Defendants. + +x + +x JANE DOE 1000, 19 CV 10577(LJL) + +Plaintiffs, + +v. + +4 5 6 7 DARREN K. INDYKE, in his capacity as executor of the Estate of Jeffrey Edward Epstein and RICHARD D. KAHN, in his capacity as executor of the Estate of Jeffrey Edward Epstein, + +8 Defendants. x + +9 + +10 11 Before: + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +HON. DEBRA C. FREEMAN, + +Magistrate Judge + +APPEARANCES + +BOIES, SCHILLER & FLEXNER, LLP + +Attorneys for Plaintiff + +BY: SIGRID S. McCAWLEY + +SABINA MARIELLA + +ANDREW VILLACASTIN + +TROUTMAN SANDERS, LLP + +Attorneys for Defendants Indyke and Kahn + +BY: BENNET J. MOSKOWITZ + +MATTHEW J. AARONSON + +VALERIE SIROTA + +HADDON, & , P.C. + +Attorneys for Defendant Maxwell + +BY: LAURA A. MENNINGER + +4 5 6 7 8 All right. So this is Judge Freeman, and this is a conference in four of the cases against the Jeffrey Epstein estate: v. Indyke, 19 Civ. 10475; v. Indyke, 19 Civ. 10476; v. Indyke, 19 Civ. 10479; and Doe 1000 v. Indyke, 19 Civ. 10577. + +9 10 If you are here for some other case or you think I got those numbers wrong, please make sure I know about it. + +11 12 13 But I'm going to ask for your appearances. We have quite a number of people on the line. Let me have the appearance first by plaintiff's counsel in these cases. + +14 15 16 17 18 19 MS. McCAWLEY: Yes, your Honor. Good morning. This is Sigrid McCawley from the law firm of Boies, Schiller & Flexner, and I'm representing the plaintiffs in the actions that you listed. Along with me, I have my colleague Sabina Mariella and Andrew Villacastin. We also have a few of our summer associates who have joined the line as well. + +20 THE COURT: All right. + +21 Do I have a court reporter on the line? + +22 23 THE COURT REPORTER: Yes. Good morning, Judge. This is Kristen Carannante. + +24 25 THE COURT: I'm going to ask anyone who is giving appearances for the record to please spell your name. So, + +THE COURT: This is Judge Freeman. We might have a court reporter, but I'm going to record this call anyway, so hold on while I set that up. + +4 5 6 7 MS. McCAWLEY: Of course. Sigrid McCawley, which is spelled S-I-G-R-I-D, and the last name is McCawley, M-c-C-A-W-L-E-Y. I also have with me Sabina Mariella, which is S-A-B-I-N-A M-A-R-I-E-L-L-A and Andrew Villacastin, and that's A-N-D-R-E-W and Villacastin is V-I-L-L-A-C-A-S-T-I-N. + +8 9 THE COURT: You are counsel in all of the cases that are on for today? + +10 MS. McCAWLEY: Correct. Correct, your Honor. + +11 THE COURT: Can I have defendants' counsel, please? + +12 13 14 MR. MOSKOWITZ: Hi, your Honor. Again, this is Bennet Moskowitz, B-E-N-N-E-T, last name M-O-S-K-O-W-I-T-Z, at Troutman Sanders, for the co-executors in each of these cases. + +15 16 17 18 19 My colleagues who handle the day-to-day discovery, Matthew Aaronson and Valerie Sirota, are on. That's Matthew is M-A-T-T-H-E-W, last name is Aaronson, A-A-R-O-N-S-O-N; and Valerie, V-A-L-E-R-I-E, last name Sirota, S-I-R-O-T-A, and we are counsel for the co-executors in each of these cases. + +20 THE COURT: All right. + +21 22 23 Do I have any other attorneys who are on or representing plaintiffs in any of the other cases that are pending before the court? No. All right. + +24 MS. MENNINGER: Your Honor -- + +25 THE COURT: Yes. + +Ms. McCawley, if you could please spell your name and the names of your colleagues. + +4 II. MENNINGER: I am in the 10475 case. + +5 THE COURT: Can you spell your name, please? + +6 MS. MENNINGER: Yes. It is L-A-U-R-A + +7 M-E-N-N-I-N-G-E-R. + +8 9 THE COURT: Okay. And, again, are there any other attorneys on the line in any of the cases? + +10 11 12 All right. I'm going to assume, then, that anyone else on the phone is public or press and just ask you to please keep your lines muted. + +13 14 15 16 17 18 19 20 21 22 Sometimes on these calls we hear beeps which suggest that someone else may have joined in the call. It can also suggest that someone may have dropped off the call. And because of that, I will probably interrupt anyone who is speaking just to try to make sure that we didn't lose anybody or we didn't gain anyone we should know about. It is not a courtroom where I can see people coming and going, so I just like to make sure we didn't accidentally lose one of the counsel who is supposed to be present. And I apologize in advance for the interruptions. + +23 Do I have + +24 : Yes, Judge, I'm here. + +25 THE COURT: Okay. That's one of my law clerks, just + +MS. MENNINGER: Sorry. This is a defendant's counsel for Ms. Maxwell, Laura Menninger. + +THE COURT: + +4 5 All right. So I have letters in these cases. They have come in clusters of letter and response and reply in the three cases where Ms. Maxwell is not a party, and then there are letters relating to her in the case where she is a party. + +6 7 Let me start with the other cases where she is not the party and deal with those letters first. + +8 9 10 Can I have, from Ms. McCawley, just a status update from you where things stand with your current request, with your understanding about potential settlements? + +11 MS. McCAWLEY: Yes, your Honor. + +12 13 14 15 16 So with respect to the requests, we have presented to the court a main threshold issue which has been unresolved at this point by the parties, and that is the issue of the time period within which the defendants, the estate, will produce documents. That issue remains unresolved. + +17 18 19 20 21 22 23 24 25 It is the plaintiffs' position that documents for the entire relevant time period for each plaintiff, which runs from the date of their abuse, that year, to the present, are responsive and relevant to discovery in the case. That goes to the evidence with respect to any of the conduct that Epstein was engaging in over those years that would prove the abuse, not simply, as in a car crash case, you don't just get the evidence of the date of the car crash, you get all evidence relating to anything that's relevant and could be used + +so you know. + +potentially at trial. Similarly, here, the defendants have 4 5 6 7 8 attempted to limit the production to simply the year of the abuse or years of the abuse, if it happened in more than one year. It is our position that all evidence relating to the over 20-year span of Epstein's abuse of not only our clients but other clients that are similarly situated, other women that are similarly situated, is highly relevant to the discovery in this matter. + +9 10 11 12 13 And of course, as your Honor knows, the plaintiff has the burden of proving her case in each of these instances, and the estate has taken the position of attempting to prove Epstein's innocence, therefore making all of this information highly relevant for the entire time period. + +14 15 16 17 18 19 20 This is similar to other cases that have come before in the Southern District of New York. For example, Judge Sweet, in his case with one of the victims, allowed discovery for the entire time period from 2000 to the present; and that is, again, because, under 415, evidence of other abuse can be admissible at trial. So we believe that the entire time period is highly relevant, and those documents need to be produced. + +21 22 23 24 25 The status of this, as of the date of filing our letters, no documents have been produced. In the last couple of days, in case and in the Jane Doe 1000 case, there has been one document produced by the defendants. in the case of there have been three documents produced, + +4 5 6 7 8 9 10 11 So we are still in a position where we have not received any substantial document production in this case. The court will remember that, back on January 28 -- the cases were filed in November. Back on January 28 we sent -- after your hearing that you had in December asking them to preserve documents, we sent a document preservation letter that outlined in very specific detail the e-mail accounts for which we were aware of that Mr. Epstein had utilized. + +12 13 14 15 16 17 18 19 You are going to hear today, and you saw in the filings from the defendant about their claims of burdens, they have not justified burden at this point. They have thrown around a number of 700,000 documents. I will tell you that we have already gone through 600,000 documents in just Annie's case alone for our production. They have not produced a hit list to show burden or otherwise establish why our request would be so burdensome. + +20 21 22 23 24 25 So with respect to -- and that is only -- now, they are only still responding to the time period that is the oneor two-year window, depending on the particular plaintiff. So at this stage we do not have -- that is still the threshold issue that we are asking this court to resolve. We need that issue resolved before we can undertake depositions or get this + +one of which was clawed back. And in the case of there have been 90 documents produced, and that is on their side. + +4 5 6 7 They have produced supplemental interrogatory responses. Again, those are still limited to the time period that they have set forth. They have not agreed to produce information for the entire time period at this point. + +8 9 10 So that is the key issue that we put before the court that we need resolution on it in order to be able to move these cases forward at this point. + +11 12 13 THE COURT: All right. Before I ask some questions about that, let me just ask about potential for settlement of these cases. What is plaintiffs' understanding? + +14 15 16 17 18 19 20 21 22 23 24 25 MS. McCAWLEY: Potential for settlement in these cases, as your Honor knows, there was the proposal of a potential claims administration program that came about in the fall of this past year. That program has been through a series of back-and-forth between the U.S. Virgin Islands' A.G. and the estate, with input from the various plaintiffs' attorneys, as well. The program has not yet been approved. It has made headway, but it has not yet been approved to move forward. There are still issues with respect to a release and other matters, so that has not gotten off the ground at all. So there have been no substantive settlement discussions of any kind in these cases. + +case moving, because we at this point have no documents of any substance from the other side. So that is the key issue that we have put before the court for resolution. + +And, again, if -- + +4 5 6 THE COURT: If the program gets off the ground, the program as you understand it to be fashioned, would these plaintiffs be likely to participate in it? + +7 8 9 10 MS. McCAWLEY: We would still have to have those final conversations with the clients pending what the final outcome of the program is, but they have all been interested in trying to participate in a program if it does go forward. + +11 12 13 14 15 16 17 18 19 20 21 Our concern, of course, is that that program has been delayed and has not moved forward, so we have had the need to press forward with our case. Of course, in that program, too, any offer that could be made could be very substandard, where our clients would want to proceed with the merits of their action, which is why we are here before the court trying to seek resolution of our clients' claims, because there is no guarantee with respect to that program whatsoever. So we are in a position where we need to and want to move forward with discovery without further delay to be able to get to the merits of our clients' claims. + +22 23 24 25 Any discovery they would receive in these matters would be relevant anyway to those discussions with our presenting claims to the claims administrator. So we see that as coinciding and being relevant and responsive to Epstein + +THE COURT: If the program -- + +MS. McCAWLEY: Sorry. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +being able to establish our claim, again, before the claims administrator. + +THE COURT: All right. And going back to your request to compel discovery from defendant, you say that the time frame is the issue. I believe the letter was presented, it appeared to say in general you hadn't gotten discovery responses to document requests or interrogatories, and then you highlighted this issue. Is this really the key issue or the only issue or are there other issues with respect to just not getting responses? + +MS. McCAWLEY: Well, you are correct, your Honor. At the time we wrote the initial letter, the responses were there were not responses, there were just objections. They have since supplemented their responses but, again, limiting it only to the time frame. So we still may have issues with those responses, because at this point we only can see them as to the time period within which they are saying the abuse victims - that time period where they were abused, so we don't believe that they are fulsome at this point. But if the court could resolve the threshold issue of whether or not they have to produce for the entire time period, they would then supplement, or our assumption is that they would supplement their responses both to interrogatories and to the requests for production, and then we could evaluate at that point if it appears there is anything missing. + +THE COURT: And why would it not be the case that, document request by document request or interrogatory by interrogatory, the inquiry might be different as to what time frame would be appropriate to look at? There might be some, depending upon how the request is framed, where it would be appropriate to look at a longer time frame; and there may be some, based on the nature of the request, where that would not make sense to look at a longer time frame. Why should I be doing this on a global basis? + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +MS. McCAWLEY: Well, that's a very fair question, your Honor. So the requests, for example, seek information related -- like the request number one is information related to the plaintiff including diary, diaries, journals, calendars, any information, travel itineraries that relate to that plaintiff, and that could be in any time period. For example, if Epstein's last year was talking about one of our client's and had information that he had recorded in an e-mail about one of our clients, that would be responsive. + +So the time period does pertain, in my view, to all of the requests. We have not -- they have not come to us and said a particular request only applies for these reasons to one particular year. In my view, the request, for example, for flight logs, if there are not flight logs in a certain year, they would only produce what they have, obviously. But if they have flight logs for the entire time period, we would want + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +those. So it is -- your Honor is correct that there can be some request-specific issues, but they haven't agreed to produce anything outside of the year of the abuse at this point. + +THE COURT: Are there some requests that relate to people other than your clients? + +MS. McCAWLEY: Yes. + +THE COURT: Other than -- + +MS. McCAWLEY: For example -- yes. + +So as I said before, it is our position that, with respect to our clients' claims in each of the cases, information relating to Epstein's abuse of other victims is highly relevant under 415, particularly to establish that this pattern of luring in young girls in the same way, for example, with saying they are interviewing for a modeling job or saying they are coming for an assistant's interview, the pattern of how he lured girls in, then abused them is relevant to our clients presenting their claims to the jury to prove the truth of the fact that they have before, as well, abused in a similar manner. So we firmly believe that that information is highly relevant to the case. + +Again, the estate has taken the position, and you have seen it in our filings, that Epstein is innocent, and we have to prove the truth of that, as well as with respect to all of these cases. So we are in a position where we are having to + +4 5 6 fight to get discovery from the estate. I would was certainly hoping it would not be this kind of a battle. I was hoping that now that he is no longer taking his Fifth Amendment privileges, no longer with us, that we would be able to get substantive discovery in a more streamlined manner, but that is not the case. + +7 8 9 10 11 12 13 14 15 16 And any threshold issue is very important because it implicates our clients' ability to be able to present their case and to be able to substantively be able to depose witness. As your Honor knows our discovery deadline is looming in early July. We need to be able to take the depositions of various people who either interacted with our clients or who were witnesses to the abuses that occurred in Epstein's various homes, and we need the information and the documents from his files that establish and relate to the abuse, and those are the requests that we have put forward. + +17 18 THE COURT: All right. I have some thoughts on this, but let me hear from defendants first. + +19 MR. MOSKOWITZ: Hi, your Honor. Bennet Moskowitz. + +20 21 22 23 If I may, I would like to address the program issue first, which I think is much quicker than the discovery. My colleague, Matt Aaronson, will discuss the discovery issues, if that's okay. + +24 THE COURT: Okay. + +25 MS. McCAWLEY: So I am very, very surprised to hear + +4 5 6 7 8 9 10 11 Ms. McCawley give a presentation that seems like her clients are lukewarm on the program. She is on the e-mails from this week where Brad , who represents five plaintiffs and we understand the vast majority of claimants all of whom want to participate in the program according to him, announced to us on the estate side that he was able to get the Attorney General to finally step aside and let the program move forward. So my first surprise is hearing that Ms. McCawley thinks that the program is still in some vast limbo. It is not for all of the reasons that I discussed this morning, which Ms. McCawley is aware of. + +12 13 14 15 16 THE COURT: Hold on a second. We have two separate conferences. One was at 10:00 and this one is 11:00. So when you say that we discussed this morning, Ms. McCawley, unless she didn't announce herself, was not on that call and doesn't know what you said at that conference. + +17 MR. MOSKOWITZ: Sure. + +18 MS. McCAWLEY: (Inaudible). + +19 THE COURT: I'm sorry? + +20 MS. McCAWLEY: I'm sorry. This is Sigrid McCawley. + +21 22 I was unaware of the 10:00 conference call. I'm sorry. + +23 24 25 THE COURT: We had a conference call in certain of the other cases with different plaintiffs' counsel where there were somewhat different issues raised. + +4 5 6 7 MR. MOSKOWITZ: I am happy to concisely, as best I can, go through the same points, and I will say now that I know Ms. McCawley knows all of the following with perhaps one exception, which I will explain. + +8 9 10 11 12 13 14 15 Ms. McCawley knows that around 69 individual claimants, including her clients, have publicly come forward to voice overwhelming support for the program, including to the USVI probate court. We know that is the vast majority of known claimants. We are aware of only one claimant who is a state court plaintiff who has publicly said that she is not participating, and that was through her counsel, and I don't even know if that's that person's current position. + +16 17 18 19 20 21 Ms. McCawley also knows that seven plaintiffs in the SDNY action, including one of her clients, , most recently stayed their actions in favor of the program. It bears mentioning that -- you know, the stipulation in that regard goes contrary to everything Ms. McCawley just said. + +22 23 24 25 Your Honor entered that order, so I don't think I need to repeat it verbatim. But mentioned in there was the notion of conserving resources, and in that regard, as a side note, it bears mentioning that Boies Schiller has been the biggest + +MR. MOSKOWITZ: Sure. And I am trying -- + +THE COURT: I'm trying to cluster these so we don't have to have a marathon session with all cases at once. + +4 5 6 7 8 9 10 11 culprit in driving up the estate's litigation cost, money that will never be available for their clients or other alleged victims in the program. We don't understand that. We were staffed very leanly until recently, just me and an associate. Five attorneys on their side, including three partners. I have lawyers, my colleagues are on now for the team more recently, because Boies Schiller takes the most unreasonable positions on discovery, grossly overbroad view -- again, Mr. Aaronson will get to that -- and they make the most constant threat to motion practice notwithstanding their clients participating in the program. + +12 13 14 15 16 Ms. McCawley also knows that the protocol for the program, which was done in close consultation between the administrator and designers and claimants' counsel, including hers, her firm, and with -- in between co-executors is nearly finalized. + +17 18 19 20 21 22 23 24 And Ms. McCawley also knows the only reason this hasn't gone forward until now was because of the USVI Attorney General. But again, Mr. announced a couple of days ago in an email that Ms. McCawley is on that that last, quote, lingering issue, as Mr. put it, is now resolved. And, again, there are a few less contentious matters to iron out, but it is our firm expectation that by sometime next week that resolution in principle will be formalized. + +25 The sole thing that not be aware of + +is that if something unexpected happens and that resolution in 4 5 6 7 8 9 10 principle is not finalized, then by June 15, our current intent on the estate side is to move forward with the program absent the probate court entering an order directing us not to or otherwise impeding that, and I don't think that's going to happen because another person who has voiced support for the program is the probate judge who, on February 4, at a hearing that Ms. McCawley attended, as did David Boies, the probate judge said the following: "I think we agreed that everybody believes this program is a great program." + +11 12 13 14 15 16 17 18 19 20 So I will say that I don't understand why we get one display of overwhelming support from Boies Schiller and others when we are not before your Honor, and then we come before your Honor and I hear a different story. The program is going to go forward very soon. I am confident of that. And I'm confident that, per Ms. McCawley's own statements, all of her clients, not just the one who stayed her action already, are going to participate. So, again, every dollar we are spending in the meantime is money that will never be available for that program. + +21 22 23 That's all I have to say on the program aspect. Unless your Honor has questions, I will refer to my colleague, Mr. Aaronson, to address the discovery issues. + +24 THE COURT: Let me hear the discovery issues. + +25 MR. AARONSON: Good morning, your Honor. Matthew + +Aaronson. + +4 5 6 7 8 It is not the estate's position that documents that relate to the claims asserted by the plaintiffs will not be produced. In fact, all of our discovery responses have identified that to the extent the request seeks information about plaintiffs, they will be produced. + +9 10 We also identified to your Honor in the letter that we sent to you -- + +11 12 THE COURT: Hold on. Let me interrupt you. Without regard to time frame or only within a specific time frame? + +13 14 15 16 17 18 19 20 21 22 23 24 MR. AARONSON: I was about to clarify that. We said in our letter to your Honor without regard to time frame with respect to the plaintiffs. And in fact, that is something that, your Honor, the problem we have here is, we were still under the impression we were meeting and conferring with plaintiffs' counsel on these issues, and we put that in our letter. And before we could even -- you know, we told them we would consider their positions, and before we could even conclude that, they filed a letter with the court. I think you are aware, our initial letter to the court said that we were sort of surprised by that and we are saying it is premature. We still think these issues are premature. + +25 But the simple fact is, your Honor, our position is we + +I want to correct a couple of misstatements that Ms. McCawley made. + +are producing any documents that reference orally to the plaintiffs. And in fact we have searched documents for that. So there is no dispute there, there is no issue there. + +4 5 6 7 8 9 10 11 12 13 We are not saying that the time period for documents relating to plaintiff is limited in that way, shape, or form. What we did say was, these are events in some situations, , incidents that happened on one day in 2002, and we are saying it is not proportional to ask for our client, the estate, to search for documents relating to a 20 -- I guess it would be a 19-year period, your Honor, relating to people who may have worked at a property that Mr. Epstein owned and in fact property that Mr. Epstein -- doesn't allege she ever visited. You know, it's a scope issue. + +14 15 16 17 But, again, to the extent there is an allegation that -- I'm sorry, there is a document that references we have agreed to produce it. We searched for those documents. And the same applies for all of the plaintiffs. + +18 19 So I want to make it very clear that that is a misstatement of what our position is. + +20 21 22 23 24 25 You know, again, the scope here is just so overbroad, beyond plaintiff, that we think it is not proportional to the case. We disagree completely with Ms. McCawley's statement that any of that discovery is necessary for her to prove her claims. Her claims in this case are a simple claim of battery. That's the claim in this case. That's her burden to prove and + +4 that is it. And we have agreed to provide documents that relate to her claims. If she says she was at a property on a certain date, we have identified to the best of our ability people who may have been at that property that date. + +5 6 7 8 9 10 11 12 13 You know, I'm not sure what more we are obligated to do, your Honor. And this is a part of the problem. If they have complaints about search terms, then meet with us to talk about search terms. Before we could finish the process, they ran into court. We are open to a dialogue. We have always been open to a dialogue to try to resolve these issues. But, as we told you, they prematurely went to court to try to -- you know, to try to get in front of your Honor before we could even finish that. + +14 15 16 17 18 19 We have a lot of requests, your Honor, that are just completely unrelated to these cases. I don't think it's appropriate now to go through each one right now. But I just wanted to clarify that this concept that it is a -- we are not agreeing to produce documents about the plaintiffs is wholly untrue, and I just wanted to make that very clear. + +20 21 22 23 24 25 THE COURT: Okay. So let me go back on plaintiffs' side. I'm not going to make any blanket ruling, and I'm not persuaded that you have conferred fully in good faith before bringing the motion, in part, because you have already said that some of it is moot because in fact when you got responses, you no longer had a complete absence of information, and now + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +you are really just focused on the time frame issue. That tells me that when you wrote the initial letter you hadn't conferred fully in good faith to see what really had to be put before the court. + +With respect to the time frame issue, it sounds like defendant is prepared to and planning to produce documents without regard to time frame that refer to your clients or relate to your clients, and it also sounds like defendants are willing to confer with respect to other requests. + +As far as those other requests go, the test for relevance is not whether something is relevant to a general subject matter of a case, it's whether it is relevant to a claim or defense asserted in the case. It may be with respect to some of the requests where time frame is at issue that the documents sought are in fact highly relevant to a defense that's been asserted in the case, for example. It may be that they are tangentially relevant. It may be the burden is great. It may be the burden is modest. It may be that -- let me just make sure I didn't lose counsel. + +Do I still have plaintiffs' counsel? + +MS. McCAWLEY: Yes, your Honor. + +THE COURT: Do I still have defendants' counsel? + +MR. MOSKOWITZ: Yes, your Honor. + +THE COURT: Okay. If anyone joined from the public or press, I will please ask you to mute your phone. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Did anyone join who is an attorney in one of the cases in front of me? No. All right. + +I lost the thread a little bit of what I was saying, but the point is that if this is in front of me with particularized disputes, I'm going to have to look at each document request at issue or each interrogatory at issue, hear from the parties about the particular relevance to a claim or a defense, hear from the defendant about the particular arguable lack of relevance or burden, and make item-by-item determinations. I'm not going to do it in a blanket fashion, and you are going to have to confer on that kind of level to get it focused for me, if it comes back to me, so that I understand just what the documents are that are being sought, just what the claim of relevance is, just what the purported burden is, just what the proportionality is so that I can make that assessment balancing relevant factors. + +Now, the other issue that we have is resources and settlement and whether the dollars that are spent by defendants in litigating the case and responding to discovery requests might be better spent by being put into a fund if plaintiffs are planning to participate in that and whether it is a consideration that I should take into account, whether we should have any kind of extended period of time for the responses so that you can see if you are going to participate in the program if the kinks are worked out. + +4 5 6 In the earlier conference we had today, what I did was allow the parties to have a bit of a hiatus in their cases, to conserve resources, asking for a status letter by June 19 with the understanding that the estate was planning to move forward with the program no later than June 15 absent something they thought would be extraordinary to stop it from doing so. + +7 8 9 10 So on plaintiffs' side, let me hear whether you think it makes sense to give it a window of time before there is increased attorney's fees spent to see if in fact that program is moving forward and you might be participating in it. + +11 12 13 14 And in any event, let me hear what you have to say about my view that perhaps you should be conferring further in good faith about these time frame issues on a request-by-request basis. + +15 16 MS. McCAWLEY: Of course, your Honor. This is Sigrid McCawley for the plaintiff. + +17 18 19 20 21 22 23 24 With respect to the issue of a hiatus, my concern there would be that we, as you know, back in November, talked about this program, and while Mr. Moskowitz has made representations on this call, you will understand that those were the same representations that he was making back in December and January and, for a number of reasons, that program has just not moved forward. Now I'm hearing for the first time this June 15 date that I have not heard before. + +25 The problem I see with any kind of hiatus and, to + +4 5 6 7 be clear, we don't want to, of course, expend unnecessary estate resources. The issue that I have with that is it is the continued delay and the part of the disadvantage to my clients in that they don't have information, all of the information they need relevant to their claims because they haven't received even though we have tried diligently, they have not received substantial production in the case of any kind. + +8 9 10 11 12 13 14 15 16 17 So with respect to a hiatus, my concern would be that right now our discovery deadline is set for early July. We were hoping to get documents in order to be able to start taking some of the necessary depositions to get information for our case to be able to move it forward, and I believe that is something that we would be entitled to. I think that my concern is that, again, it would be a July 15 date, then it would be -- I'm sorry, a June 15 date, then a July 15 date, and it would continue without us being able to move the case forward. + +18 19 20 21 22 23 24 25 Also, as you know, the claims program is voluntary So to the extent that a client does participate in that and gets paused, we don't know what that claims administration program is going to ultimately prove to be. So to the extent that a client participates and is offered something or not offered anything, their case should be moving forward so that they are able to go to trial on the merits of their claims, if they need to, against the estate. So that would be my concern + +4 5 Again, we are not -- the discovery, in my view, has moved very, very slowly. So just to pull back and not have them continue to engage with us on discovery, in my view, would be problematic, because it would just further delay the case. + +6 7 So those are my concerns generally with respect to that. + +8 9 10 11 12 13 And, again, I'm hearing from the other side this June 15 date that I have no confidence that that is something that will necessarily move forward because we don't have anything in writing with respect to that or any statement from the court in the USVI that they have approved that or anything of that nature. So that was my concern there. + +14 15 16 17 18 19 With respect to the issue before the court, we are in a position where the time frame issue is significantly problematic to us for the reasons that I have outlined. While they are representing to the court today that they will produce documents related to the plaintiff, you will remember that we have -- + +20 21 22 23 THE COURT: What did they say in their responses that you got in? Did they say these documents will be produced or is it just they are saying this for the first time to the court today? + +24 25 MS. McCAWLEY: With respect to the plaintiff, they represented they would run the name of the plaintiff in their + +with making any change at this point. + +4 MS.McCAWLEY: But the problem -- + +5 6 7 THE COURT: Why did you tell me earlier on in the call that they were refusing to produce any documents for the later time frame even with regard to the plaintiff? + +8 9 10 11 MS.McCAWLEY: That is my understanding of their position, your Honor. I am hearing now that they are saying well, first of all, they have only produced one document for case, one document for Jane Doe's case. + +12 13 14 15 16 17 18 19 20 21 THE COURT: Wait a minute, wait a minute. This is complete lack of meaningful dialogue between the parties, because I'm hearing opposite things from the parties about what defendants' position is. Defendant, as I understand it from this call, has said that they will, and have told you that they will, produce documents regardless of time frame if they refer or relate to the plaintiff, and that they are doing that in fact in all cases and have not taken a position that they would not. And you are saying that is your understanding of their position, that they will not. + +22 23 How can that be if you have had a good conference between you? + +24 25 MS. McCAWLEY: Your Honor, as we set forth in our letter, we did have a two-hour conference where we asked them + +discovery searches and produce with respect to the plaintiff, yes, that they did. + +THE COURT: Why -- + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +about the time frame issues and made sure to get the full position on that because that was our biggest concern. And that is what we discretely presented to the court because that was the concern we have, that they were not going to be producing anything beyond the time period of the abuse. + +(Indiscernible crosstalk) + +THE COURT: -- discretely presented to the court. You presented to the court in your opening letter that there was a complete failure to respond to any of the requests, and now you tell me on the call that since then there has been a response, and so what is now being discretely presented on this telephone call is what you say is a remaining issue, which seems like it is only a remaining issue in part because it seemed like if there are documents specifically relating or referring to the plaintiff, defendants have agreed to produce it and according to defendants have told you they have agreed to produce it in their responses that you have since gotten. Now, I haven't seen those responses. If they have been put before me, I'm sorry, I have not reviewed them. I don't think I have them. For that matter, I'm not sure I have all of the requests, I'm not sure I have an item-by-item explanation of relevance, and I'm not sure that your discussion has been adequate between the lawyers. + +MS. McCAWLEY: Your Honor, this is Sigrid McCawley for the plaintiff. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +I appreciate that. I am hearing your Honor. We will go back and address these issues again with the defendants in the hopes of being able to resolve them and not hopefully have to come before the court with respect to them. We are, again, hopeful to be able to get discovery in this case. We do not believe that has been the situation that we are in presently, and that's why we have presented it to the court. But I understand your point, your Honor, and we will make sure to engage further in the hopes of being able to resolve this. + +THE COURT: All right. Let me ask, on defendants' side, by when do you plan to produce -- assuming we have no stay of discovery here and no hiatus, by when do you plan to produce the documents referring or relating to plaintiff? + +MR. MOSKOWITZ: We have already started that, your Honor. Bennet Moskowitz, excuse me. And in fact, I apologize. Let me let Mr. Aaronson address that question. And then, if I can, I would like to just very quickly respond to something Ms. McCawley said about the program. + +THE COURT: Let me hear first about the documents -- + +MR. AARONSON: Yes -- + +THE COURT: -- regarding the production. + +MR. AARONSON: Yes, your Honor. Matthew Aaronson. + +We have already started the production. We made a production I believe on Wednesday of documents, and I think in particular it was over 100 documents. + +4 5 6 7 8 9 10 So with the process underway -- and, again, I think, your Honor, you have gotten this correct, is that we have told them that we will produce and search for -- search for and produce documents that relate to their clients. To the extent that they think we need to add additional search terms, we searched the individual plaintiffs' names. If there are additional search terms, we are open to a dialogue to discuss that. If there are additional terms, as in every case, whether or not we can reach agreements on those terms. You know, the thing -- + +11 12 13 14 15 16 17 THE COURT: I would like to put a deadline on getting the production complete with respect to any documents that in any way refer or relate to the plaintiffs after you have had some further discussion perhaps on search terms, if necessary. But I would like to have a firm date when you are not just producing a few documents and a few documents and say it is underway, that that actually gets produced. Once -- + +18 19 20 21 MR. AARONSON: That's fair, your Honor. Part of that goes back to the same issue you raised earlier about the expenditure of time and money on discovery issues versus putting it towards the program. + +22 23 24 25 So to the extent the court is not inclined to issue a pause or some sort of temporary issue on that, it's hard to say. The problem we have is that, you know, it is difficult to search all of our files, given the pandemic. Some files have + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +not been able to be collected yet. So I can tell you that, of the electronic documents that we have collected, I think we can keep that probably within 30 days of what we have collected already. + +But I will tell you, we have done the initial pass of that, and we have made those productions. As I said, there was a significant number of documents. Presumably other plaintiffs there were not. So, again, we do believe that it would be appropriate (unintelligible) some of this, but to the extent the court is not inclined to do that, you know, I think 30 days for what we have. But to be clear, your Honor, I don't know that we have collected every, you know, source at this point in time, given our inability to collect documents dues to the pandemic. + +THE COURT: How has the pandemic affected your ability to collect documents specifically? + +MR. AARONSON: I will let Mr. Moskowitz speak to that, but my understanding is, you know, that we have not been able to access and people are not traveling to different locations. So we have collected electronic documents. I'm not -- again, I'm deferring to Mr. Moskowitz on that, whether or not the additional documents are still out there. + +MR. MOSKOWITZ: Yes. Bennet Moskowitz. Happy to clarify that point, your Honor. + +There are two -- let me take a step back. Yes. It is + +4 5 6 7 8 9 10 11 true that we have collected over 700 and I think 40,000 documents, and we did search them for the plaintiffs' names. And we did produce what we found that wasn't privileged, and we will go back and make sure that that is complete. But the fact that we located many documents for , which were dated to as late as I believe last year and have already been produced, so I don't understand Ms. McCawley's confusion about the time frame issue. But in any event, the fact that we found those but didn't find such documents for the other cases just evidences a lack of documents, not something wrong with the search process. + +12 13 14 15 16 17 18 19 20 In terms of the pandemic difficulties, my problem with making a 30-day blanket representation is that there are at least some hard copy files that I would like certain people to look through, and while I have no reason one way or the other to expect their responsive materials are there, I would like that to happen before such deadline, and I'm not 100 percent certain that it can, because at least some of the documents are in places that are still under lockdown or there are still health concerns. + +21 22 23 24 25 In addition to that, this is somewhat subject to the disputes about the scope of the discovery. If Ms. McCawley is, let's say, correct and these cases -- everything related to any allegedly bad thing Mr. Epstein ever did is relevant in each action, well, then, it could take me, you know, six months or a + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +year to finish looking for every piece of paper and every property Mr. Epstein owned. So, again, it's with the context of just searching for names. Mr. Aaronson is correct, that can be done in the next 30 days, with the exception of anything that we can't actually access to look through. + +And again I have -- + +THE COURT: You have already -- + +MR. MOSKOWITZ: Yes. + +THE COURT: You already have the documents electronically, at least certain of the documents, most of the documents. + +MR. MOSKOWITZ: Yes. + +THE COURT: And you have already gone through them and you have already made some production. Why would you need another 30 days before you can get to the end of that particular road? + +MR. MOSKOWITZ: We may not. It really depends on the rest of the meet-and-confer process which never completed. It depends on the search terms that are proposed, whether there are any additional search terms proposed. For example, what we wanted to happen during a full meet-and-confer process, which is what we strive to do in every case, and what we are actually doing in other actions against the estate, that Boies Schiller is not involved with, is suggest search terms to us that you think would satisfy your view of what a particular request + +entails, let us run the report. If the report comes back and 4 says 500 documents or even a thousand, we may deem that reasonable for that request. If it comes back at 10,000, we may not deem that reasonable. + +5 6 7 8 9 10 11 So this is part of what an ongoing discussion, I hope, would have entailed, which gives me pause to, again, say a blanket yes, we will get it all done in 30 days. As to searching for things, I mentioned the plaintiffs in what we have already collected, to the extent we didn't complete that, you know, we don't need 30 days. But I don't know that that will satisfy Ms. McCawley. + +12 THE COURT: Okay. + +13 14 15 16 17 18 19 20 If this case goes all the way forward in litigation and goes to trial, you are going to try this case. You are not going to try ever case that is before this court or any other court at the same trial. That doesn't mean that evidence regarding others who are claiming to have been victims of Mr. Epstein might not have relevance to some claim or defenses being raised, and I understand that it may, in some documents, may have relevance. + +21 22 23 24 25 But you are going to have to get, on plaintiffs' side, a lot more focused with what you want and why you want it. And if you are going to come back and make a renewed application to me, that application is going to have to be more focused on what kind of documents you are talking about, what claim or + +4 5 6 7 8 9 10 11 12 13 14 defense they are relevant to, why they are relevant to that claim or defense, giving me an example of some case law that shows how it could be relevant, and I will make a decision on a request-by-request basis about what appropriate time frames should be used. And with respect to search terms, in the first instance you need to talk to each other about that because you don't want the court coming up with search terms or trying to make judgment calls on that if it's not necessary. You know, you are much better off trying to figure it out between you, getting an agreed protocol, an agreed list of custodians, an agreed list of search terms, and then go from there, as generally happens in cases where there might be a lot of documents that are kept electronically. So I expect you to go through that process as you would in any other case. + +15 16 17 18 19 20 21 22 23 24 25 I am open to kicking out your deadlines a bit to give you time to talk this through and to see if we can get some progress. I'm going to ask defendants, to the extent you already have a known universe of documents, if there are any you have not yet produced, get them produced within two weeks. If there are additional search terms, you will talk with each other in good faith about time frame for running any additional searches and getting any additional documents produced. And if plaintiff wanted to come back to me on a renewed motion that's more specifically laid out on particular categories of documents or responses to interrogatories, you will do that + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +after you have tried to work these things through with an eye toward what is what is reasonable. Plaintiff may reasonably need more than defendants want to give. Defendants may have a reasonable point about conserving resources for the sake of a settlement program which should be taken seriously because it seems that very serious efforts are underway to try to get that program off the ground. + +I'm going to ask for a status letter by June 19, which is the date that I gave in other cases. It is geared to Mr. Moskowitz's representation that this program should launch, he thinks, by June 15. So it seems to me by June 19 you will have a better idea and you will also have a better idea of where you are with respect to these discovery issues. + +I'm going to caution plaintiffs' counsel in the future, please do not send me something without being sure you are at the end of the road in talking to your adversary. I don't want to get a response that says it is premature, we haven't really talked. Make sure you are clear on a point-by-point basis that you have talked about specific relevance, that you have talked about specific burden issues, that you have talked about specific search terms, at least you have try to engage in that kind of dialogue. If you are stymied, you are stymied, and I will hear from you. But I don't think you are at that point. + +And I think that's it with respect to those disputes, + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +and I should probably turn to the dispute regarding + +Ms. Maxwell. What I am going to do is I am going to -- I don't know if the letters were framed as a motion for a conference or a motion to compel. If they were framed as a motion for a conference, I will say granted. We had a conference. As to the underlying issue about compelling, go talk or in if actually framed as a motion, I will say denied without prejudice to renew, and I'm going to ask for a status letter by June 19. + +Anybody want to say anything else on that before I turn to Ms. Maxwell's issue? + +No? Okay. I'm hearing no, or I am hearing nothing. Hopefully I haven't lost everybody on the entire call. I'm hearing laughs, so hopefully that means not. + +Let me turn to Ms. Menninger's issue. One thing I want to understand, because there was a reference to a potential criminal prosecution which of course could impact whether there should be a stay as to a defendant who is being criminally correctly, or you may prosecuted. Currently, if I'm understanding be the target of an investigation, be concerned she is the target of an investigation but there are no actual criminal charges pending, is that right? + +MS. MENNINGER: Yes, that's correct, your Honor. We do not have any criminal charges pending anywhere, but we have + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +a number of public statements by the U.S. Attorney's office in the Southern District, as well as statements made by plaintiffs' counsel to the press that suggest that those - that that investigation is underway and that it would encompass Ms. Maxwell, and so that is our concern. But it is correct to say that there is no active criminal charges that I am aware of. + +THE COURT: All right. So if there were active criminal charges filed or if that should happen, that might influence the thinking about whether or not there should be a stay, because of course if a defendant ends up taking the Fifth, that could have consequences in a civil case and defendant may feel there is little choice but to do that if the person is under a criminal indictment or if plaintiffs have filed. + +So I just want to just note that if that circumstance change -- if that circumstance changes, let me know. If it affects any ruling I make, let me know, because I may need to revisit a ruling. + +Let me hear what -- given the last conference, the last subject, where there seem to be some changed landscapes since the application was initially made, let me make sure that I am aware of the current circumstance. + +Let me just hear from Ms. Maxwell's counsel first on this. + +MS. MENNINGER: Thank you, your Honor, Ms. Menninger here on behalf of Ms. Maxwell. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +The landscape has not changed since our letters. We have filed a motion to dismiss the claims which we believe are distinct and different from any sort of example that the estate may have, and we believe that they are strong grounds for dismissal. The case -- the allegations against Ms. Maxwell in this case involve an allegation of battery that occurred one time in 1996 in New Mexico, and the statute of limitations and venue issues, you know, in New York versus New Mexico are very different for Maxwell than perhaps for the estate and we think provide the grounds for dismissal. + +The other two bases that we raise for a stay are the claims program that your Honor has already spent some time discussing on this call and the earlier call today. We believe -- we don't have any independent information. We were not party to the calls in the Virgin Islands, as were counsel for plaintiffs and for the estate. But I have heard on the call today the representations made by the estate that they believe that the program will be getting off the ground in a matter of a few weeks, June 15, or three weeks or so from today. + +Given that plaintiff has indicated an intent to participate in that program, at least in filings in the Virgin Islands, and the fact that that program would -- if she + +participates and it is successful, would render this entire lawsuit moot, we think we believe balancing that fact against the extremely broad discovery demands that something about, although not with respect would counsel in favor of at least a short your Honor has heard to Ms. Maxwell yet, stay similar to the ones that other plaintiffs' counsel have agreed to, promoted, or even stipulated to in other cases pending before your Honor. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +We have received extensive discovery demands. been advised that plaintiffs' counsel intends to take a of depositions, including around the country, including We have number for people that plaintiff in our case never met and had no dealings with. And, your Honor, I can speak from personal experience with that same type of discovery happening with the same plaintiffs' counsel in the v. Maxwell action that I was counsel for significant depositions in front of Judge Sweet. We had a number of discovery disputes in that case and we had that occurred not only across the country, from California to New York and Florida and many places in between, but also abroad in that case, and the litigation costs were in the hundreds of thousands easily in that case. And so looking at the pattern of discovery that I believe plaintiff intends to pursue here, balancing the costs of those to someone like my client, who is claims program resolving this not a multimillionaire, and then viewing the as something that could be successful in case in a short period of time, we would ask + +Your Honor to consider putting a stay on discovery in the case that I am party to, or I am counsel for a party to. + +4 5 6 7 8 9 10 I think I can second or third some of the things that have already been said earlier, so I don't want to waste the court's time with those. But we have concerns that any money spent on this litigation is going to reduce the amount of money that would be available to any of the accusers in the Virgin Islands, and we don't think it makes sense to spend the money on these broad discovery requests if we can get the case resolved shortly. + +11 12 13 14 15 16 17 18 19 20 21 22 23 I think the only objection that I heard from plaintiffs' counsel to something like a hiatus was that there's a pending discovery cutoff of early July, and it seems to me reasonable that of course if the claims program gets off the ground in a few weeks, that discovery cutoff could be set out to see if it is successful or not. And so it is sort of a false premise to say that the discovery cutoff in July is the reason we should be forging ahead full steam with this expensive discovery, rather than just taking the more logical approach, to me, which would be to at least put it on hold to see if the claims program is successful in the first instance; and, if not, then the cases can proceed with the court's blessing, pick back up where we left off. + +24 25 In this particular case, I think it also bears noting that the claim allegedly occurred in 1996, so it has been some + +24 years since the allegations supposedly happened, and so I 4 5 6 don't see that waiting one or two or three months balanced against 24 years is -- it's not as though we think documents will go missing in those three months that weren't already somehow lost to the winds of time over the last 24 years, your Honor. + +7 8 9 10 11 12 13 14 15 THE COURT: So you are -- I will just note, by the way, that in your initial letter you ask for an opportunity to do full briefing, but it is all laid out in the letters. So let me just get some clarification on that. What more briefing would you be looking to do beyond what's in these letters? You have case citations in these letters and you lay out the bases for a stay. What would you be looking to do when you are trying to conserve resources? Do you really need full briefing. + +16 17 18 19 20 21 22 23 24 MS. MENNINGER: I think it could be abbreviated briefing; but, yes, there are more cases in support of the request that we are making. There are more cases in terms of the criminal investigation versus active prosecution, and then there is certainly a fair amount of exhibits that I could tender to your Honor to display the breadth of discovery that is part of the traditional balancing test when looking at a motion to stay -- or good cause -- of grounds for good cause as balanced against the breadth of discovery. + +25 THE COURT: I don't remember if at the beginning of + +this call I asked if my law clerk was on. are you there? + +4 5 THE COURT: Okay. Well, for the court reporter, it is , H-A-N-N-A. + +6 7 8 9 10 11 And and I were conferring before this conference about some case law about some criminal prosecution as opposed to criminal investigation, and we weren't finding, at least on an initial look, cases where the courts tended to stay civil proceedings when there was an investigation proceeding. You have cases that say the opposite? + +12 13 MS. MENNINGER: Your Honor, I have some. They are not in the Southern District, so there are -- + +14 THE COURT: Okay. + +15 16 MS. MENNINGER: -- cases that have occurred in various federal and state cases across the country. + +17 18 THE COURT: And you are looking for a stay of the entire case, not just as to proceedings against your client? + +19 20 21 22 23 24 25 MS. MENNINGER: Your Honor, it seems to me best to stay the case, but I would be amenable just in regards to my client or, as I said towards the end of my letter, there are other alternatives that, you know, I think I would view as intermediate steps, for example, bifurcation of discovery on the statute of limitations issue, for example, if that were something the court thought were appropriate or a stay on party + +: Yes, I'm here, Judge. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +depositions until later in the discovery process to see where the claims program and the criminal investigation end up, and certainly with regard to the motion to dismiss, that should be, I would think, decided at some point. + +THE COURT: I might consider, because there is a lot to do in this case, I might consider putting a hold on Ms. Maxwell having to make statements, so either responding to substantive interrogatories or being deposed because of Fifth Amendment issues, because it may be that she ends up the subject of prosecution even if she is not yet and because there are other things that can meanwhile be going forward. If we put her deposition further down the pike, maybe we will have greater clarity on that before that issue actually comes to the fore. + +I'm also thinking that there are other interests besides hers in this case. There are plaintiffs' interests and I'm sure that although your point is well taken that it's not that likely that documents will now not be preserved within these few months as opposed to not being preserved over the years, I'm sure plaintiff does not want to hear that after all of these years she must wait more time in order to have what she considers to be serious wrongs redressed. So the factors can cut in more than one direction. + +So right now I'm not inclined to stay the whole case, but I am inclined to keep one eye on settlement, to keep one + +4 5 6 7 8 9 10 11 12 13 eye -- I'm not sure how many eyes I have -- to keep an eye on the -- any criminal investigation and ask to have updates if there are charges filed, and maybe put some things more at the front end of the discovery period, some things more at the back end of the discovery period. And I am willing to move the dates out some to accommodate the parties if the parties are engaged in good-faith discussions, if there is a desire to conserve resources because it looks like the claims program is in fact going forward. I am willing to do that. I have done that another cases. I have stayed other cases. I have extended deadlines in other cases. I don't really want to see resources going to litigation if it's not necessary. But right now I'm not inclined to have a complete stay of everything. + +14 15 16 17 Ms. Menninger, what would be your reaction to saying hold off on anything that could be in the category of affirmative statements made by Ms. Maxwell for now and having other discovery going forward? + +18 19 MS. MENNINGER: It does address -- this is Ms. Menninger, again, Laura Menninger. + +20 21 22 23 24 25 It does address many of my concerns. I would say, you know, the costs related to the broad discovery demands that were propounded, written discovery requests and the like, are still of concern to me. As I mentioned, we have been asked for every calendar she has had for the last 24 years and every Amazon account she has ever used for the last 24 years. So + +4 5 6 7 8 THE COURT: That sounds to me, again, like you need to have a discussion with plaintiffs' counsel and, plaintiffs' counsel, it sounds like you need to have a discussion with Ms. Menninger about what you really need, why you really need it, how it can be done in a way that's manageable with no absolute yeses and no absolute nos with respect to those sorts of requests. + +9 10 11 12 13 14 15 16 17 18 19 20 It may be that there is something about Amazon accounts that's really critical, and you can explain that. And maybe there is something else that's not really critical, and you can, you know, bend a bit on it. So you need to have that kind of discussion to keep, you know -- you know, to keep discovery tailored to the case and proportionate to the needs of the case. That has to do with time frame, that has to do with the scope of what's being claimed in a particular case, and to some extent it has to do with Mr. Epstein's accused conduct over time. So you are going to have to try to have that conversation and try to balance it. And if you can't, then I will. + +21 MS. MENNINGER: I appreciate that, your Honor. + +22 MS. McCAWLEY: Your Honor, this is + +23 THE COURT: Yes. + +24 25 MS. McCAWLEY: I'm sorry. This is Ms. McCawley. Can I address -- + +THE COURT: Absolutely. + +MS. McCAWLEY: Thank you. + +4 5 6 7 MS. McCAWLEY: With respect to the motion to stay that Ms. Maxwell is proposing, one of the bases that she has filed motion to dismiss, Judge Schofield held a premotion conference with respect to that -- + +8 9 10 THE COURT: Hold on a moment, please. Do I still have -- do I still have -- I know I still have Ms. McCawley. Do I still have Ms. Menninger? + +11 MS. MENNINGER: Yes, your Honor. + +12 THE COURT: Do I still have Mr. Moskowitz? + +13 MR. MOSKOWITZ: Yes, your Honor. + +14 15 16 17 THE COURT: Did anyone join us who is another attorney? Okay. Hopefully we didn't lose anybody. If anyone joined from the public or press, welcome. Please keep your phone on mute. + +18 Okay. Go ahead. You were saying, Ms. McCawley? + +19 20 21 22 23 24 25 MS. McCAWLEY: Yes. So we did hold in front of Judge Schofield a premotion conference on Ms. Maxwell's motion to dismiss. As Judge Schofield did with the estate, she discouraged Ms. Maxwell from filing a motion to dismiss, giving her preliminary views that they -- the arguments that she was putting forth were not meritorious. Ms. Maxwell insisted on filing a motion to dismiss and has done that now, just this + +THE COURT: Please go ahead. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +week. So in my view, that is -- bodes against any sort of stay based on the motion to dismiss because the district judge has set forth her views with respect to that at least as an initial matter. + +With respect to the case law, your Honor is correct, the case law in New York is clear that unless there is an indictment put forward, which there has not been, it doesn't allow somebody in a civil case to stay the case on the basis of a possible investigation. + +With respect to your Honor's statements about the investigation and potentially allowing Ms. Maxwell to not have to make statements in this civil action, the concern I have there is that we have no indication of any time frame with respect to the Southern District of New York, how long that investigation could go on or will go on or anything of that nature. So the concern, for me, is Ms. Maxwell, as we have alleged, worked in concert with Mr. Epstein to abuse my client. We brought those claims under the Child Victims Act, as we are allowed to do, because she was a minor, and to not be able to get a discovery and ask Ms. Maxwell questions and get responses and keep the case moving forward puts us in handcuffs with respect to being able to establish our claims because, as your Honor has seen from the complaint, the allegations are that they worked together hand in hand with respect to the abuse of . So I would have concerns about some form of that + +kind of a path for defendant Maxwell in the case at this time until there is a criminal indictment that's put forward. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +THE COURT: All right. Let me just say a few things about that. + +First of all, if the investigation is going on here in New York, or for that matter wherever it may be going on, because what we have in New York is not only in New York with respect to COVID-19, the grand jury process is understandably delayed because it is very difficult to have jurors convene. So there may be additional time before any case that is being investigated is indicted, and so we just have to recognize that we are in somewhat unusual circumstances. + +The second thing is that any stay that I might put in place with respect to any aspect of the claims against Ms. Maxwell would be temporary and would be revisited. I would not allow it to drag on indefinitely. But in a case where some things can be done to move the case forward and the case is not completely stalled, I don't see any harm in putting some things a little bit further down the road. + +The third thing I will say is this is also an unusual circumstance because of the potential of this claims process in which plaintiff may well participate and which may well get off the ground soon; and, if it does, I'm not sure whether it would moot claims against Ms. Maxwell or not, but it might. And as you balance those factors, you have this situation where we may + +4 5 know in the relatively near future whether plaintiff is actively participating in the claims process, whether it looks like it is going to resolve her claims, and we may never have to get to the point where we jeopardize, potentially jeopardize somebody's Fifth Amendment rights. + +6 7 8 9 10 11 12 13 14 15 So I might be inclined to do this, to say, look, you can carry on with discovery in the case after a conference on all kinds of things, to try to keep costs under control and try to focus on what's most important. I will extend deadlines out if you would like if you are feeling pressure from that. We will hold off on -- not on production of documents from Ms. Maxwell but on the statements that she makes, whether sworn statements or interrogatories or deposition, we will put that a little bit further down. You will give me status report regarding the process of settlement, and we will take + +16 17 18 19 20 21 22 23 And with respect to holding off on interrogatory responses or deposition by Ms. Maxwell, that will not be a permanent situation, that will be revisited. And if time is stretching out too far and if there is no indictment, then I may take further briefing on the subject and I will make a decision as to whether in fact that part of the case should also go forward. But I will not let it drag out indefinitely. That is my current thinking. + +24 What say both of you on that? + +25 MS. MENNINGER: Your Honor, this is Laura Menninger. + +4 5 6 7 8 9 10 11 MS. McCAWLEY: Your Honor, obviously we disagree with that because we believe that it's important to have Ms. Maxwell's participation in this case. We have noticed her for a deposition already and that got moved because she -- you know, the issue of just being able to be in person, things of that nature. We were trying to accommodate. So we are concerned about there being extended delay and are concerned about not being able to get information from her through her testimony. + +12 13 14 15 16 17 18 19 We respect the court's concerns about a Fifth Amendment privilege but, again, we would ask that if you are going to be inclined to do something like this, you tie it to a date like the June 15 date, or something along those lines, so that we are not in a position where she is able to take depositions of all of our people and we are, you know, handcuffed with respect to any discovery with respect to Ms. Maxwell. + +20 21 22 23 24 25 THE COURT: Like I said, I have no desire to have this drag out. If all things -- if we didn't have this potential claim process out there with a fairly soon, seemingly likely, start date, according to defendants, then I think the balance would be different. Because I don't think the case law in this circuit would generally support the stay when there is no + +That would be -- we would welcome that ruling, your Honor. + +THE COURT: Plaintiff? + +4 5 6 7 8 9 10 11 12 13 14 15 But nonetheless, there are a number of factors one might look at on that, and whether or not an indictment is pending is only one of the factors. There are several factors that could be relevant, including, and I'm going to refer you to the Louis Vuitton MalIetier case. For the court reporter, L-O-U-I-S V-U-I-T-T-O-N M-A-L-L-E-T-I-E-R v. Ly, L-Y, U.S.A., Inc., and the case number is 676 F.3d 83 from 2011. So the Second Circuit noted that courts often take a look at a number of factors in deciding whether there should be a stay, including the extent to which the issues in the criminal case overlap with those presented in the civil case. Here, there would be, I assume, a very strong overlap to the status of the case, including whether the defendants have been indicted. So that's a factor. + +16 17 18 19 20 21 22 23 Three, the private interests of the plaintiff in proceeding expeditiously weighed against the prejudice to plaintiffs caused by the delay. Here I'm looking at the potential settlement process and that, to me, is an unusual factor that suggests that the plaintiffs' interests may be divided here in proceeding fast with this case when there is a potential settlement within the next few months potentially available to plaintiffs and plaintiff may go for that. + +24 25 Another factor is the private interest of and burden on the defendants. We do have an individual here. We are not + +prosecution pending yet. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +talking about the estate, and there is somewhat more burden for discovery. + +There are the interests of the courts. The interest of the court is not to have unnecessary litigation if the matters can be resolved amicably, and not to have it stretch out forever. That's also an interest of the court. + +We also have this strange overlay of COVID-19 which affects the ability for criminal prosecutors to take matters to a grand jury. + +The public interest, I think the public interest is would be well served by a claims process. If you look at this case in terms of there being a number of claim victims, and that is something that I definitely am looking at and is weighing into my consideration as to how any and all of these cases should be litigated. And in several of the cases, which claims that are no more recent than the claims here, a lot of plaintiffs' counsel have agreed to stays or partial stays or are holding off on certain things to conserve resources and allow that process to play out a bit, and I think that those are factors that are unusual in this case. This is a case-by-case, specific analysis that has to be made as to whether there should be a stay. + +So in this particular case, at this particular time, with these particular circumstances, it seems to me to make sense not to stay the case in its entirety, to send counsel + +4 5 6 7 8 9 10 11 off to have the kind of good-faith conference you should have had before contacting me in the first place and that you should always have about anything and everything as you try to work through discovery issues, but to hold off on the most serious of the issues with respect to Ms. Maxwell, which are her constitutional rights, and not forever, but at least long enough to let us know whether the claims process is likely to go forward. And I will revisit it, and I will revisit it at intervals that are reasonable and that does not put you in limbo where you will never be able to get discovery from Ms. Maxwell if this case proceeds. All right? + +12 13 14 15 16 17 So let me ask straight out, are you, under the circumstances I have described and the way in which I would envision this, which is some discovery going forward, good-faith conference, report to me by June 19 about the status, are you looking to have me move out the discovery schedules at all and, if so, by how long? + +18 MS. McCAWLEY: Your Honor, this is Sigrid McCawley. + +19 20 21 22 23 24 25 Would it be possible to have some time to consider that? Right now the discovery deadline is set for July 10, I believe, and I of course have anticipated taking depositions throughout June and into early July. So if I could have some time to consider what that would look like and confer with the other side, then if we can't agree, then maybe present something to the court with the timing of that? + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +THE COURT: Yeah. I mean, I'm not usually in the habit of suggesting extensions, but I think here, rather than be crunched with depositions and panicking at the end of June and beginning of July, putting another 30 days on it to give you time to talk through your issues and for me to have fuller briefing on the issue of a stay, should it come to that, it might make sense to at least give you another 30. + +MS. McCAWLEY: That would be fine, your Honor. + +THE COURT: Mr. Moskowitz, do you want to say anything? + +MS. McCAWLEY: Just very quickly, your Honor. + +That 30-day initial extension for the further discussion makes perfect sense to us. I would say you laid out -- your Honor laid out very compelling reasons, one of which is unique to this action, but the others equally apply to the other actions that we are here now before you on, so I would hope that we could also discuss with Ms. McCawley keeping the extensions in line for each case with those other considerations in mind. It's something we will discuss. + +The only other thing I wanted to mention is -- which I didn't get a chance to mention earlier is that Ms. McCawley mentioned various concerns about the program. That could be more convincing from someone but for the fact that they already stayed one of their clients' actions in favor of the program. So I just don't -- it doesn't square with us that those + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +concerns are such that they can't take the same reasoned approach in the other actions when they found it reasonable for one of them already. + +But other than that, I have nothing to add, your Honor. + +THE COURT: Okay. So I'm going to ask for a status report by June 19. In that status report, I not only want to hear about how discovery is going and how settlement prospects are looking. I also want to hear about further discussions with counsel for Ms. Maxwell and mapping out of how the parties would anticipate things moving further from that point, and, you know, Ms. Maxwell permitting not to respond to interrogatories and not to have her deposition until the parties have had a chance to confer, until I have had that status report June 19, until I hear again from counsel as to the next logical way to proceed with that, and I will kick out discovery deadlines 30 days, which is modest. Others, I think, are going to be kicked out longer. You can do whatever planning you do for depositions to be happening a little further down the road in July, and you will get back to me. As need be, we will have another conference and we will take in the next piece. Okay? + +MS. McCAWLEY: Thank you, your Honor. + +THE COURT: All right. Anything else + +MS. MENNINGER: Thank you, your Honor. + +4 5 6 7 a 9 All right. Let me just say one last thing, which is, I did record this call into the conferencing system, but you also have a court reporter on the call. You don't need to have a transcript made from the telephone recording. And just be aware that if there are two transcripts made -- one from AT&T and one from the court reporter -- and there is any discrepancy, the court reporter's transcript will be the official transcript and will control. Okay? + +10 MS. McCAWLEY: Thank you, your Honor. + +11 MR. MOSKOWITZ: Thank you, your Honor. + +THE COURT: -- before we end this call? + +12 THE COURT: All right. Thank you all. 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I NDYKE + +Defendant(s) + +## NOTICE OF FILING OF OFFICIAL TRANSCRIPT + +Notice is hereby given that an official transcript of aconferenceheld on 5/22/2020 has been filed by the court reporter/transcriber in the above-captioned matter. + +Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting the transcript is a judge or a member of the public or media. + +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically available to the public without redaction after ninety (90) calendar days. + +This process may only be used to redact the following personal data identifiers: Social Security numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information may proceed by motion. + +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. + +/S Kristen Carrar + +('cult Reporter/Transcriber Date \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732300/EFTA02732300.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02732300/EFTA02732300.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..074d4c4135c5428160c9fd18a86f246fdac9b407 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732300/EFTA02732300.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02732300.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1434, + "elapsed_seconds": 0.87, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "IN THE UNITED STATES DISTRICT COURT \nFOR THE SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 154.224, + 66.42 + ], + [ + 418.669189453125, + 66.42 + ], + [ + 418.669189453125, + 96.363037109375 + ], + [ + 154.224, + 96.363037109375 + ] + ] + }, + { + "title": "NOTICE OF FILING OF OFFICIAL TRANSCRIPT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 168.3, + 307.79999999999995 + ], + [ + 448.5048828125, + 307.79999999999995 + ], + [ + 448.5048828125, + 322.4830627441406 + ], + [ + 168.3, + 322.4830627441406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 54 + ], + [ + "Line", + 26 + ], + [ + "Text", + 15 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02732300" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732301/EFTA02732301.md b/marker2/court-redacted-v-indyke-10479/EFTA02732301/EFTA02732301.md new file mode 100644 index 0000000000000000000000000000000000000000..65fd368a52d0292045a4aa2c74afb1316ca601a7 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732301/EFTA02732301.md @@ -0,0 +1,89 @@ +Troutman Sanders LLP 875 Third Avenue New York, New York 10022 + +troutman.com + +Bennet J. Moskowitz + +bennet.moskowitz@troutman.com + +June 3, 2020 + +### VIA ECF + +Hon. Debra Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007 + +![](_page_0_Picture_3.jpeg) + +Re: Katlyn Doe, 1:19-cv-07771-PKC-DCF; Priscilla Doe, 1:19-cv-07772-ALC-DCF; Lisa Doe. 1:19-cv-07773 ER-DCF; VE. 1:19-cv-07625-AJN-DCF; ithzt Doe. 1:19-cv-08673-KPF-D . 1:19-cv-10475-LGS-DCF; 1:19-cv-10476-PGG-DCF: 1:19-cv-10479-ALC-DCF; Jane Doe 1000, 1:19-cv-10577-LGS-D F- Jane Doe 15, 1:19-cv-10653-PAE-DCF; Mary Doe, 1:19-cv-10758-PAE-DCF; 1:19-cv-10788-GHW-DCF: Anastasia Doe, 1:19-cv-11869-AJN-DCF; Jane Doe, 1:20-cv-00484-JGK-DCF + +Dear Judge Freeman: + +We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the to -Executors"), in the above-referenced actions. We are pleased to inform the Court that, today, the Superior Court of the United States Virgin Islands entered an order granting the Co-Executors' Motion to establish the Epstein Victims' Compensation Program. A copy of the Order is attached hereto. + +Respectfully submitted, + +/s/ Bennet J. Moskowitz + +Bennet J. Moskowitz + +cc: Counsel of Record (via ECF) + +# EXHIBIT + +## IN THE SUPERIOR COURT TH VIRGIN ISLANDS District of St. St. John + +In the Matter of the Estate of JEFFREY E. Case Number: ST-2019-PB-00080 + +EPSTEIN, deceased. Action: Administration of Testamentary Estates + +## NOTICE of ENTRY of ORDER + +To: '= Kroblin, Esq. + +John H. Benham, Esq. Douglas B. Chanco, Esq. Richard P. Bourne-Vanneck, Esq. John K. Dema Esq. Denise N. E l Esq. Melody D. West all, Esq. Sean E MK Esq. Gaylin Vogel, Esq. A. Jeffrey Weiss, Esq. + +Ariel M. Esq. Kevin F. D'amour, Esq. Kevin Boyle, Esq. Robert Glassman, Esq. + +Please take notice that on June 3, 2020 a(n) ORDER dated June 2, 2020 was entered by the Clerk in the above-titled matter. + +Dated: June 03, 2020 Tamara Charles + +By: + +Clerk of the Court + +44114 + +Edotcia Hodge Court erk + +## IN THE SUPERIOR COURT THE VIRGIN ISLANDS DIVISION OF ST. MM AND ST. JOHN + +IN THE MATTER OF THE ESTATE OF: + +JEFFREY E. EPSTEIN, + +PROBATE NO. ST-19-PB-80 + +ACTION FOR TESTATE deceased. ) ADMINISTRATION + +### ORDER + +THIS MATTER is before the Court on the Co-Executors' Status Report on Voluntary Compensation Program and Presentation of Program Protocol filed on June 1, 2020, wherein, in pertinent part, the Co-Executor notify that all interested parties have finalized and are in support of the protocol for the Epstein Victims' Compensation Program (hereinafter "the Program")) The Court having received testimony concerning the Program at the hearing held on February 4, 2020, and having reviewed said Status Report, it is hereby + +ORDERED that the Expedited Motion for Establishment of a Voluntary Claims Resolution Program filed on November 14, 2019, is GRANTED; and it is further + +ORDERED that the Co-Executors are AUTHORIZED to commence the Epstein Victims' Compensation Program on or about June 15, 2020. + +Dated: June , 2020 + +Magistrate ROLVN P. HER ON- ERCELL dge off e Superior/Court of the Virgin Islands + +## ATTEST: + +TAMARA CHARLES CERTIFIE T + +0 E COPY Clerk of the Court DATE 14A0 BY TAMARA CLERK CHARLES =Flc + +By: kin 0 A EDOTCIA T MAS-HODGE Court Clerk Supervisor 6, / 3 gt zlk, COURT CLERK + +&#x27;At the hearing held on February 4. 2020, while the Court did not allow the Attorney General of the U.S. Virgin Islands to intervene, the Court did request the Co-Executors and the Attorney General to resolve their differences concerning the proposed compensation program. which has garnered the support of all interested parties, including claimants' counsel. The Co-Executors now inform that Itaecause the need for the Program has grown increasingly urgent, and with the support of claimants' counsel and the USVI Attorney General - and because the remaining impediments have been resolved and the interested parties have consented to the Protocol.- they and the Attorney General have reached an agreement in which the latter will promptly lift previously imposed liens to pay amounts owed for the Program and to begin funding the Program's active operations. including payment of compensation determinations to eligible claimants. Co-Executors' Status Report on Voluntary Compensation Program and Presentation of Program Protocol, at 6. 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INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +Case No. I:19-cv-10479-ALC-DCF + +## JOINT STIPULATION AND IPROPOSED1 ORDER STAYING ACTION + +WHEREAS independent claims administration experts have designed and are implementing the Epstein Victims' Compensation Program (the "Program") to resolve sexual abuse claims against decedent Jeffrey E. Epstein ("Decedent") in a non-adversarial alternative to litigation; and + +WHEREAS Plaintiff ("Plaintiff " and together with Defendants, Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein, the "Parties"), seeks to participate in the Program; and + +WHEREAS the Parties seek to preserve their resources and judicial economy by staying this action for sixty (60) days while Plaintiff participates in the Program; and + +WHEREAS should Plaintiff resolve her claims against Decedent via the Program, Plaintiff will promptly discontinue this action with prejudice. + +IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel for the Parties, that: + +- I. The captioned action is hereby stayed, both as to discovery and to the resolution of any pending motions, for sixty (60) days from the date of entry of this Order. + +- 2. After the expiration of the stay, if any, the Parties will confer on a schedule for the remaining discovery in this action. + +Dated: June 12, 2020 Respectfully submitted, New York, New York + +BOLES, SCHILLER & FLEXNER LLP + +By: /s/ Sigrid McCawley + +Sigrid McCawley 401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL, 33301 (954) 377 4223 smccawley@bsifip.com + +Attorneys for Plaintiff + +TROUTMAN SANDERS LLP + +By: /s/ Bennet J. Moskowitz + +Bennet J. Moskowitz 875 Third Avenue New York, NY 10022 (212) 704-6000 bennet.moskowitz@troutman.com + +Attorneys for Defendants + +Date: 2020 + +New York, New York HON. DEBRA C. 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DARREN K. INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, Defendants. + +Case No. 1:19-cv-10479-ALC-DCF + +## JOINT STIPULATION AND FPROPOSED1 ORDER STAYING ACTION Pic + +WHEREAS independent claims administration experts have designed and are implementing the Epstein Victims' Compensation Program (the "Program") to resolve sexual abuse claims against decedent Jeffrey E. Epstein ("Decedent") in a non-adversarial alternative to litigation; and + +WHEREAS Plaintiff ("Plaintiff " and together with Defendants, Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein, the "Parties"), seeks to participate in the Program; and + +WHEREAS the Parties seek to preserve their resources and judicial economy by staying this action for sixty (60) days while Plaintiff participates in the Program; and + +WHEREAS should Plaintiff resolve her claims against Decedent via the Program, Plaintiff will promptly discontinue this action with prejudice. + +IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel for the Parties, that: + +- 1. The captioned action is hereby stayed, both as to discovery and to the resolution of any pending motions, for sixty (60) days from the date of entry of this Order. + +- 2. After the expiration of the stay, if any, the Parties will confer on a schedule for the remaining discovery in this action. + +Dated: June 12, 2020 Respectfully submitted, New York, New York + +BOWS, SCHILLER & FLEXNER LLP + +By: /s/ Sigrid McCawley Sigrid McCawley 401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL, 33301 (954) 377 4223 smccawley@bsfIlp.com + +Attorneys for Plaintiff TROUTMAN SANDERS LLP + +By: Is/ Bennet J. Moskowitz Bennet J. Moskowitz 875 Third Avenue New York, NY 10022 (212) 704-6000 bennet.moskowitz@troutman.com + +Attorneys for Defendants The parties are directed to submit a joint status report by 8/14/2020. + +Date: Iune 15 2020 New York, New York + +HON. DEBRA C-. 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KAHN, et al., Defendant. + +## NOTICE OF CHANGE OF ADDRESS + +TO. ATTORNEY SERVICES CLERK AND ALL OTHER PARTIES + +I have cases pending I have no cases pending + +Pursuant to Local Rule 1.3 of this Court, please take notice of the following attorney information change (s) for: + +Bennet J. Moskowitz + +FILL IN ATTORNEY NAME + +My SDNY Bar Number is: 8M1024 My State Bar Number is 4693842 + +I am, + +An attorney + +A Government Agency attorney + +A Pro Hac Vicc attorney + +FIRM INFORMATION (Include full name of firm (OLD AND NEW), address, telephone number and fax number): + +OLD FIRM: FIRM NAME: Troutman Sanders LLP FIRM ADDRESS: 875 Third Avenue. New York, NY 10022 FIRM TELEPHONE NUMBER: (212) 704-6000 FIRM FAX NUMBER: (212)704-6288 + +NEW FIRM: FIRM NAME: Troutman Pepper Sanders LLP FIRM ADDRESS: 875 Third Avenue. New York. NY 10022 FIRM TELEPHONE NUMBER: 1212) 704.6000 FIRM FAX NUMBER: (212) 704-6288 + +I will continue to be counsel of record on the above-entitled case at my new firm/agency. + +I am no longer counsel of record on the above-entitled case. An order withdrawing my appearance was entered on by Judge + +Dated: July 9.2020 s/Elennet J. 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KAHN, et al., Defendant. + +## NOTICE OF CHANGE OF ADDRESS + +TO. ATTORNEY SERVICES CLERK AND ALL OTHER PARTIES + +I have cases pending I have no cases pending + +Pursuant to Local Rule 1.3 of this Court, please take notice of the following attorney information change (s) for: + +Mary "Molly" S. Dirago + +FILL IN ATTORNEY NAME + +My SDNY Bar Number is: My State Bar Number is + +I am, + +An attorney + +A Government Agency attorney + +A Pro Hac Vice attorney + +FIRM INFORMATION (Include full name of firm (OLD AND NEW), address, telephone number and fax number): + +OLD FIRM: FIRM NAME: Troutman Sanders LLP FIRM ADDRESS: 227 W. Monroe Street. Suite 3900. Chicago. IL 60606 FIRM TELEPHONE NUMBER: (312) 759-1920 FIRM FAX NUMBER: (312) 759-1939 + +NEW FIRM: FIRM NAME: Troutman Pepper Sanders LLP FIRM ADDRESS: 227 W. Monroe Street. Suite 3900. Chicago, IL 60606 FIRM TELEPHONE NUMBER: 1312) 759.1920 FIRM FAX NUMBER: (312) 759-1939 + +0 + +I will continue to be counsel of record on the above-entitled case at my new firm/agency. + +I am no longer counsel of record on the above-entitled case. An order withdrawing my appearance was entered on by Judge + +Dated: July 9.2020 s/Mary •Molly" S. 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KAHN, et al., Defendant. + +## NOTICE OF CHANGE OF ADDRESS + +TO. ATTORNEY SERVICES CLERK AND ALL OTHER PARTIES + +I have cases pending I have no cases pending + +Pursuant to Local Rule 1.3 of this Court, please take notice of the following attorney information change (s) for: + +## Charles L. Glover + +## FILL IN ATTORNEY NAME + +My SDNY Bar Number is: CG0117 My State Bar Number is 5329909 + +I am, + +An attorney + +A Government Agency attorney + +A Pro Hac Vice attorney + +FIRM INFORMATION (Include full name of finn (OLD AND NEW), address, telephone number and fax number): + +OLD FIRM: FIRM NAME: Troutman Sanders LLP + +NEW FIRM: + +FIRM ADDRESS: 875 Third Avenue. New York, NY 10022 + +FIRM TELEPHONE NUMBER: (212) 704-6000 + +FIRM FAX NUMBER: (212) 704.6288 + +FIRM NAME: Troutman Pepper a Sanders LLP + +FIRM ADDRESS: 875 Third Avenue. New Veit. 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KAHN, et al., Defendant. + +## NOTICE OF CHANGE OF ADDRESS + +TO. ATTORNEY SERVICES CLERK AND ALL OTHER PARTIES + +I have cases pending I have no cases pending + +Pursuant to Local Rule 1.3 of this Court, please take notice of the following attorney information change (s) for: + +## Valerie Sirota + +My SDNY Bar Number is: V56041 My State Bar Number is 4916599 + +I am, + +## FILL IN ATTORNEY NAME + +An attorney + +A Government Agency attorney + +A Pro Hac Vice attorney + +FIRM INFORMATION (Include full name of firm (OLD AND NEW), address, telephone number and fax number): + +OLD FIRM: FIRM NAME: Troutman Sanders LLP + +FIRM ADDRESS: 875 Third Avenue, New York. NY 10022 + +FIRM TELEPHONE NUMBER: (212) 704-6000 + +FIRM FAX NUMBER: (212) 704.6288 + +NEW FIRM: FIRM NAME: Troutman Pepper Sanders LLP + +FIRM ADDRESS: 875 Third Avenue. New Yodr. 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KAHN, et al., Defendant. + +## NOTICE OF CHANGE OF ADDRESS + +TO. ATTORNEY SERVICES CLERK AND ALL OTHER PARTIES + +I have cases pending I have no cases pending + +Pursuant to Local Rule 1.3 of this Court, please take notice of the following attorney information change (s) for: + +Matthew J. Aaronson + +FILL IN ATTORNEY NAME + +My SDNY Bar Number is: MA2092 My State Bar Number is 3951100 + +I am, + +An attorney + +A Government Agency attorney + +A Pro Hac Vice attorney + +FIRM INFORMATION (Include full name of firm (OLD AND NEW), address, telephone number and fax number): + +OLD FIRM: FIRM NAME: Troutman Sanders LLP + +NEW FIRM: + +FIRM ADDRESS: 875 Third Avenue, New York. NY 10022 + +FIRM TELEPHONE NUMBER: (212) 704-6000 + +FIRM FAX NUMBER: (212) 704.6288 + +FIRM NAME: Troutman Pepper Sanders LLP + +FIRM ADDRESS: 875 Third Avenue. New York. NY 10022 + +FIRM TELEPHONE NUMBER: 1212) 704.6000 + +FIRM FAX NUMBER: (212) 704-6288 + +I will continue to be counsel of record on the above-entitled case at my new firm/agency. + +I am no longer counsel of record on the above-entitled case. An order withdrawing my appearance was entered on by Judge\_ + +Dated: July 10, 2020 s/Matthew J. 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Darren. Indyke and Richard D. Kahn, in their capacities as executors of the Estate of Jeffrey Edward Epstein, 19-10479-ALC-DCF + +August 14, 2020 + +Dear Judge Freeman: + +Pursuant to the Court's June 15, 2020, Order (ECF No. 44) Plaintiff and Defendants Darren Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, jointly submit this status report. + +Plaintiff submitted her claim to the Epstein Victims' Compensation Program on June 26, 2020, and has actively participated in the program since. Based on communications with the program's Administrator, Plaintiff expects to receive an eligibility and/or compensation determination in the coming weeks. + +To preserve the parties' resources and in the interests of judicial economy, the parties respectfully request an extension of forty-five (45) additional days to the current stay of discovery (and the resolution of any pending motions) in this case. + +Respectfully submitted, + +/s/Sigrid S. McCawley + +Sigrid S. McCawley, Esq. Boies Schiller Flexner LLP + +Is/Bennet J. Moskowitz + +Bennet J. Moskowitz, Esq. 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Nine East 71st Street et at, No. 1:19-cv-07625 (MN) (DF) Doe I et at v. Indyke et at, No. 1:19-cv-7675 (GBD) (DF) Katlyn Doe v. Indyke et at, No. 1:19-cv-0777 I (PKC) (DF) Priscilla Doe v. Indyke et at, No. 1:19-cv-07772 (ALC) (DF) Lisa Doe v. Indyke et al., No. 1:19-cv-07773 (ER) (DF) Jane Doe v. Indyke a at, No. 1:19-cv-08673 (KPF) (DF) Doe 17 v. Indyke et at, No. 1:19-cv-09610 (PAE) (DF) v. Indyke a at, No. 1:19-cv-10475 (LOS) (DF) v. Indyke a at, No. 1:19-cv- 10476 (PGG) (DF) v. Indyke et at, No. 1:19-cv-10479 (ALC) (DF) Jane Doe 1000 v. Indyke et at, No. 1:19-cv-10577 (LOS) (DF) Jane Doe IS v. Indyke et at, No. 1:19-cv-10653 (PAE) (DF) Mae v. Indyke a at, No. 1:19-cv-10758 (PAE) (DF) v. Indyke et at, No. 1:19-cv-10788 (GFIW) (DF) Anastasia Doe v. Indyke a at, No. 1:19-cv-11869 (MN) (DF) Doe v. !ndvke a al., No. 1:20-cv-02365 (LIL) (DF) Doe v. Indyke a at, No. 1:20-cv-2365 (LJL) (DF) + +## DEBRA FREEMAN, United States Magistrate Judge: + +This Court, at the joint request of the parties in each of the above-referenced cases, having issued stays of the proceedings in those cases so that the plaintiffs may pursue the potential settlement of their claims through the Epstein Victims' Compensation Program, it is hereby ORDERED that the parties to each of the referenced cases shall provide this Court with a status report by October 1, 2020, and then, if the matter remains unresolved, by the first day of each month thereafter (or, if the first of the month falls on a weekend or Court holiday, then by the next business day). + +Dated: New York, New York September 4, 2020 + +SO ORDERED + +dad< eyrir-i-r-- DEBRA FREEMAN United States Magistrate Judge + +Copies to: All counsel in the above-referenced cases (via ECF) \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732315/EFTA02732315.metadata.json b/marker2/court-redacted-v-indyke-10479/EFTA02732315/EFTA02732315.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..72d9c80590cab727de444c4d8f39b67aaa9a7dd5 --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732315/EFTA02732315.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-indyke-10479/EFTA02732315.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1863, + "elapsed_seconds": 0.53, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "DEBRA FREEMAN, United States Magistrate Judge:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 69.156, + 353.15999999999997 + ], + [ + 351.7024841308594, + 353.15999999999997 + ], + [ + 351.7024841308594, + 367.1835632324219 + ], + [ + 69.156, + 367.1835632324219 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "Line", + 37 + ], + [ + "Text", + 7 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02732315" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-indyke-10479/EFTA02732316/EFTA02732316.md b/marker2/court-redacted-v-indyke-10479/EFTA02732316/EFTA02732316.md new file mode 100644 index 0000000000000000000000000000000000000000..d064fa993d56bc67730abaf813a3a7006ef2439f --- /dev/null +++ b/marker2/court-redacted-v-indyke-10479/EFTA02732316/EFTA02732316.md @@ -0,0 +1,29 @@ +![](_page_0_Picture_1.jpeg) + +## VIA ECF + +The Honorable Debra Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 + +> Re: v. Darren. Indyke and Richard D. Kahn, in their capacities as executors of the Estate of Jeffrey Edward Epstein, 19-10479-ALC-DCF + +August 14, 2020 + +Dear Judge Freeman: + +Pursuant to the Court's June 15, 2020, Order (ECF No. 44) Plaintiff and Defendants Darren Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, jointly submit this status report. + +Plaintiff submitted her claim to the Epstein Victims' Compensation Program on June 26, 2020, and has actively participated in the program since. Based on communications with the program's Administrator, Plaintiff expects to receive an eligibility and/or compensation determination in the coming weeks. + +To preserve the parties' resources and in the interests of judicial economy, the parties respectfully request an extension of forty-five (45) additional days to the current stay of discovery (and the resolution of any pending motions) in this case. + +The requested extension of the stay is granted. Dated: 09/11/2020 SO ORDERED + +DEBRA FREEMAN United States Magistrate Judge + +cc: Counsel of Record (via ECF) + +Respectfully submitted, + +/s/Sigrid S. McCawley Sigrid S. McCawley, Esq. Boies Schiller Flexner LLP + +Is/BennetI Moskowitz Bennet J. Moskowitz, Esq. 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Darren. Indyke and Richard D. Kahn, in their capacities as executors of the Estate of Jeffrey Edward Epstein, 19-10479-ALC-DCF + +October 1, 2020 + +Dear Judge Freeman: + +Pursuant to the Court's September 4, 2020, order (ECF No. 51) Plaintiff and Defendants Darren,. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, jointly submit this status report. Plaintiff submitted her claim to the Epstein Victims' Compensation Program on June 26, 2020, and has since been actively participating in the Program. Plaintiff expects that her participation in the Program will conclude in the coming weeks. + +Respectfully submitted, + +/s/ Sigrid S. McCawley + +Sigrid S. McCawley, Esq. Boies Schiller Flexner LLP + +/s/ Bennet J. Moskowitz + +Bennet J. Moskowitz, Esq. 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INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, + +Defendants. + +## JOINT STIPULATION FOR DISMISSAL + +Plaintiff and Defendants Darren K. Indyke and Richard D. Kahn, executors of the Estate of Jeffrey E. Epstein, by and through their undersigned counsel, hereby stipulate and agree that pursuant to Plaintiff's acceptance of an offer of compensation from the Epstein Victims' Compensation Program and Fed. R. Civ. P. 41(aX1)(AXii), this action shall be dismissed with prejudice, with each party to bear its own attorneys' fees and costs. + +SO STIPULATED AND AGREED. + +TROUTMAN PEPPER + +SANDERS LLP + +Bennet J. Mos owl 875 Third Avenue New York, New York 10022 (212) 704-6000 bennet.moskowitz®troutman.com + +Counsel for Defendants Darren K Indyke and Richard D. Kahn, Co-Executors of the Estate of eflkey E. Epstein + +Dated: October 15, 2020 + +BOIES SCHILLER FLEXNER LLP + +/s/ + +401 E. Las Olas Blvd., Suite 1200 Ft. 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