Epstein Secrets

status of discovery, Plaintiff respectfully requests that she be allowed to move forward. The sixteen cases currently pending against the Estate of Jeffrey Epstein in the Southern District of New York are all in very different stages of litigation. Two cases have already been stayed by agreement of the parties.

its participants from liability and accountability." (Id., at 18.) The New York Times reports that this lawsuit "seeks to head off an effort by Mr. Epstein's executor, Mr. Indyke, to turn Mr. Epstein's vast wealth into a victim's compensatory fund."' Particularly in light of these recent developments,

District of New York are all in very different stages of litigation. Two cases have already been stayed by agreement of the parties. Doe 1 et a! v. Jeffrey Epstein et at, 19-cv-07675-GBD-DCF (S.D.N.Y.); Doe 17 v. ',dyke et at, 19-cv-09610-PAE-DCF (S.D.N.Y.). One was filed recently, on December 27, 2019. Anasta

een cases currently pending against the Estate of Jeffrey Epstein in the Southern District of New York are

hat this lawsuit "seeks to head off an effort by Mr. Epstein's executor, Mr. Indyke, to turn Mr. Epstein's va

N HECKER & FINK LLP WWW.KAPLANHECKER.COM DIRECT DIAL 212.763.0884 DIRECT EMAIL rkaplan©kaplanhecker.com January 15, 2020 VIA ECF The Honorable Katherine Polk Failla United States District Court Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 The Ho

2014); Pace v. Quintanilla, No. 13-cv-91, 2013 WL 5405563, at *5 (S.D.N.Y. Sept. 23, 2013). Our client was understandably shocked by the suicide of Jeffrey Epstein in federal custody, and is eager to obtain a modicum of justice as soon as possible. All we have seen from Defendants, however, are efforts at delay

ent was understandably shocked by the suicide of Jeffrey Epstein in federal custody, and is eager to obtai

Case 1:19-cv-08673-KPF Document 21 Filed 11/06/19 Page 1 of 2 KAPLAN HECKER & FINK LLP VIA ECF The Honorable Katherine Polk Failla United States District Court Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 350 FI

cases should be marked as related since the risks of spoliation face plaintiffs in all cases. While we appreciate Defendants' explanation about Mr. Epstein's clothing (which was not previously provided to us), that was not the point of our prior letters and emails to Defendants. (See, e.g., ECF 14 Ex.

While we appreciate Defendants' explanation about Mr. Epstein's clothing (which was not previously provided to

yes died last month at his mother's apartment in the Bronx. He is the subject of public interest because he was the last person to share a cell with Jeffrey Epstein. As you are aware, there exists a presumption of access to court proceedings and judicial documents under both the common law and our Constitution.

was the last person to share a cell with Jeffrey Epstein. As you are aware, there exists a presumption of

cause he was the last person to share a cell with Jeffrey Epstein. As you are aware, there exists a presum

Case 1:18-cr-00454-KPF Document 306 Filed 12/29/20 Page 1 of 2 The Honorable Katherine Polk Failla United States District Judge Southern District of New York 40 Foley Square NY, NY 10007 December 29, 2020 Re: Unites States v. Efrain Reyes 18

yes died last month at his mother's apartment in the Bronx. He is the subject of public interest because he was the last person to share a cell with Jeffrey Epstein. As you are aware, there exists a presumption of access to court proceedings and judicial documents under both the common law and our Constitution.

was the last person to share a cell with Jeffrey Epstein. As you are aware, there exists a presumption of

cause he was the last person to share a cell with Jeffrey Epstein. As you are aware, there exists a presum

Case 1:18-cr-00454-KPF Document 306 Filed 12/29/20 Page 1 of 2 The Honorable Katherine Polk Failla United States District Judge Southern District of New York 40 Foley Square NY, NY 10007 December 29, 2020 Re: Unites States v. Efrain Reyes 18

Plaintiff, New York, N.Y. v. DARREN K. INDYKE, et al., Defendants. Before: 19 CV 8673 (KPF) x Conference December 11, 2019 11:30 a.m. HON. KATHERINE POLK FAILLA, District Judge APPEARANCES KAPLAN HECKER & FINK LLP Attorneys for Plaintiff BY: ROBERTA KAPLAN ALEXANDRA CONLON KATE L. DONIGER LOUIS FISHER

sher. THE COURT: Good morning. MR. MOSKOWITZ: Good morning. Bennet Moskowitz, Troutman Sanders LLP, counsel for the co-executors of the Estate of Jeffrey D. Epstein. MR. GLOVER: And Charles Glover of the same firm. THE COURT: First of all, I thank you very much for your indulgence. As you could see, we did not

P, counsel for the co-executors of the Estate of Jeffrey D. Epstein. MR. GLOVER: And Charles Glover of th

17 18 19 20 21 22 23 24 25 Maybe five. Our plaintiff, the two women who booked meetings -- that's not a right term. But massages with Mr. Epstein. I expect both of those women to take the Fifth, so that won't take very long, and maybe two experts. In terms of the documents that we are seeking

gs -- that's not a right term. But massages with Mr. Epstein. I expect both of those women to take the Fifth,