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in order to "pursue a civil remedy in the Epstein Claims Resolution Program." She argues that Plaintiff is "inexplicably the only of the numerous Epstein plaintiffs in this Court to not agree to such a stay" and that "a stay also would permit [Plaintiff] the opportunity to [participate in the Epstein
ng effects that abuse has had and continue to have on Plaintiff. Simply put, a stay would harm—not benefit—Plaintiff's interests. For too long 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 Est
—not benefit—Plaintiff's interests. For too long Jeffrey Epstein and Ghislaine Maxwell skirted the conseq
effrey 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,
onica Boulevard, Suite 700 • Los Angeles, California 90025 • 310.477.1700 phone • 310.477.1699 fax • www.psblaw.com August 27, 2020 VIA ECF Hon. Debra C. Freeman Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 Re: Doe v. Indyke, et al., 1:20-cv-000484-JGK-DCF P
n their capacities as executors of the Estate of Jefferey E. Epstein, and Ghislaine Maxwell, No. 1:20-cv-00
tiff’s counsel incorrectly maintains that, as Mr. Epstein is deceased, no protections should apply to his
laintiff’s counsel incorrectly maintains that, as Mr. Epstein is deceased, no protections should apply to his
tman.com August 26, 2020 VIA ECF The Honorable Debra C. Freeman United States District Court Southern District
he Defendant identified five individuals who require notice, but the Subpoena appears to seek personal and confidential information about all of the Epstein victims that BSF represents, which is more than five individuals. Thus, in an abundance of caution, BSF will notify each of the Epstein victims it
Defendant with two counts of jury for lying under oath during a civil deposition in a defamation action brought by when asked if she was aware of Jeffrey Epstein's sex trafficking scheme and whe er s e a ever iven Minor Victim-2 a massage. BSF represents Minor Victim-2 i and but does not represent and has ne
ction brought by when asked if she was aware of Jeffrey Epstein's sex trafficking scheme and whe er s e
ehow improper and that her accusers, several of whom BSF represents, are lying in order to obtain settlements. See Letter from L. Mennin er to Hon. Debra C. Freeman at 2-3, ECF No. 108 (accusing of "working during the pendency of this lawsuit with the Southern District of New York's U.S. Attorney's Office to t
ouse 500 Pearl Street New York, NY 10007 Re: Jane Doe v. Darren K. Indyke and Richard D. Kahn, in their capacities as executors of the Estate of Jefferey E. Epstein, and Ghislaine Maxwell, No. 1:20-cv-00484-JGK-DCF Dear Judge Freeman: We represent Defendants Darren K. Indyke and Richard D. Kahn, as
cities as executors of the Estate of Jefferey E. Epstein, and Ghislaine Maxwell, No. 1:20-cv
hird Avenue New York, New York 10022 troutman.com Mary Grace W. Metcalfe [email protected] August 20, 2020 VIA ECF The Honorable Debra C. Freeman United States District Court Southern District of New York Daniel Patrick Moynihan Courthouse 500 Pearl Street New York, NY 10007 Re: Jane Doe
Case 1:20-cv-00484-JGK-DCF Document 78 Filed 08/27/20 Page 1 of 6 PANISH SHEA & BOYLE, I, August 27, 2020 VIA ECF Hon. Debra C. Freeman Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 Re: Doe v. Indyke, et al., 1:20-cv-000484-JGK-DCF Plainti
Page: EFTA00016286 →e in order to "pursue a civil remedy in the Epstein Claims Resolution Program." She argues that Plaintiff is "inexplicably the only of the numerous Epstein plaintiffs in this Court to not agree to such a stay" and that "a stay also would permit [Plaintiff] the opportunity to [participate in the Epstein
Page: EFTA00016287 →damaging effects that abuse has had and continue to have on Plaintiff. Simply put, a stay would harm—not benefit—Plaintiffs interests. For too long 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 Esta
Page: EFTA00016289 →rm—not benefit—Plaintiffs interests. For too long Jeffrey Epstein and Ghislaine Maxwell skirted the conseq
Page: EFTA00016289 →Entities connected to both Jeffrey Epstein and Debra C. Freeman

Richard Kahn
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSONMaria Farmer
PERSONSecond Circuit
ORGANIZATION
New Hampshire
LOCATIONFreeman
PERSONKeating
PERSON
Daniel Patrick Moynihan
PERSONRobert Glassman
PERSONPepper Hamilton Sanders LLP
ORGANIZATIONOffice of Thrift Supervision
ORGANIZATION