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hip with Plaintiff while she was a minor and even acted on Jeffrey Epstein's behalf to communicate with Plaintiff on several occasions," the lawyer Robert Glassman wrote to U.S. District Judge Debra Freeman, responding to the estate's push to delay the under-oath grilling. Doe also plans to depose Kahn. In an
e the federal judge overseeing the case and indicated Indyke would be deposed "in both his personal capacity and as a co- EFTA00163123 executor of the Epstein Estate," and would "offer extremely relevant testimony" relating to her claims. "Indeed, we have reason to believe he has firsthand knowledge of Jeffrey
hip with Plaintiff while she was a minor and even acted on Jeffrey Epstein's behalf to communicate with Plaintiff on several occasions," the lawyer Robert Glassman wrote to U.S. District Judge Debra Freeman, responding to the estate's push to delay the under-oath grilling. Doe also plans to depose Kahn. In an
e the federal judge overseeing the case and indicated Indyke would be deposed "in both his personal capacity and as a co- EFTA01654941 executor of the Epstein Estate," and would "offer extremely relevant testimony" relating to her claims. "Indeed, we have reason to believe he has firsthand knowledge of Jeffrey
Jeffrey Epstein and Ghislaine Maxwell skirted the consequences of their vile acts. Now, Plaintiff brings this suit, as is her right by law, to hold the Epstein Estate and defendant Maxwell to answer. Plaintiff is best served by pressing forward with her claims—not waiting even longer for justice. Sadly, defendant
Page: EFTA00016289 →laintiff respectfully requests that the Court deny defendant Maxwell's request to stay this case. Respectfully submitted, PANISH SHEA & BOYLE /s/ Robert Glassman Robert Glassman cc: All counsel of record EFTA00016291
Page: EFTA00016291 →Entities connected to both Robert Glassman and the Epstein Estate

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONDarren Indyke
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
New York
LOCATIONGlassman
PERSONSigrid McCawley
PERSON
U.S. Virgin Islands
LOCATIONSouthern District
LOCATION
Richard Kahn
PERSONthe Southern District
LOCATION
United States
LOCATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Virginia Giuffre
PERSON
Les Wexner
PERSONthe C.O.U.Q. Foundation
ORGANIZATIONGratitude America
ORGANIZATIONSecond Circuit
ORGANIZATION