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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
kaplan©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 Honorable Debra Freeman United States District Court Southern District of New York Daniel Pat
rk. New York 10007 Re: Steven Jude Hoffenberg v. Jeffrey E. Epstein, et al. (Index No. 1:I6-ev-03989) Dear
rk. New York 10007 Re: Steven Jude Hoffenberg v. Jeffrey E. Epstein, et al. (Index No. 1:I6-ev-03989) Dear
nzi Fraud"). It is Mr. Hoffenberg's position that Mr. Epstein's fraudulent actions and engagement in the TFC P
District of New York Thurgood Marshall United States Courthouse 40 Foley Square, Room 2104 New York. New York 10007 Re: Steven Jude Hoffenberg v. Jeffrey E. Epstein, et al. (Index No. 1:I6-ev-03989) Dear Judge Sullivan: Reference is made to the Defendants' letter to the Court (the "Defendants' Letter") which w
ge 1 of 3 EFTA00592314 Case 1:16-cv-03989-RJS Document 20 Filed 06/29/16 Page 2 of 3 "TFC Ponzi Fraud"). It is Mr. Hoffenberg's position that Mr. Epstein's fraudulent actions and engagement in the TFC Ponzi Fraud with Mr. Hoffenberg and TFC resulted in over 200,000 victims and damages of over one bil
ECOPIER JOSEPI I J. TOMASEK June 29, 2016 Via E-mail Hon. Richard J. Sullivan, D.J. United States District Court Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square, Room 2104 New York. New York 10007 Re: Steven Jude Hoffenberg v. Jeffrey E. Epstein, et al. (Index No. 1:I6-ev-03989)
ited States Courthouse 40 Foley Square, Room 2104 New York, New York 10007 ([email protected]) Re: Steven Jude Hoffenberg v. Jeffrey E. Epstein, et al. (Index No. 1:16-cv-039891 Dear Judge Sullivan: Our firm represents Mr. Steven Jude Hoffenberg, the Plaintiff in the above-referenced matte
e of such "co-conspirators" was Mr. Jeffrey E. Epstein, the Defendant in the above-referenced matter. Accordingly, the Complaint sets forth how Mr. Epstein was integrally involved in the fraudulent securities activities for which Mr. Hoffenberg was convicted. Mr. Hoffenberg was ordered by Judge Sweet t
nysd.uscourts.gov) Re: Steven Jude Hoffenberg v. Jeffrey E. Epstein, et al. (Index No. 1:16-cv-039891 Dear
nysd.uscourts.gov) Re: Steven Jude Hoffenberg v. Jeffrey E. Epstein, et al. (Index No. 1:16-cv-039891 Dear
atter. Accordingly, the Complaint sets forth how Mr. Epstein was integrally involved in the fraudulent securit
PH J. TOMASEK (212) 486-0701 June 7, 2016 Via E-mail Hon. Richard J. Sullivan, D.J. United States District Court Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square, Room 2104 New York, New York 10007 ([email protected]) Re: Steven Jude Hoffenberg v. Jeffrey E.
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
Page: EFTA00028472 →ent was understandably shocked by the suicide of Jeffrey Epstein in federal custody, and is eager to obtai
Page: EFTA00028472 →/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 FIFTH AVENUE I SUITE 7110 NEW YORK, NEW YORK 10118 TEL I FAX WWW.KAPLANHECKER,COM November
Page: EFTA00028472 →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.
Page: EFTA00028473 →While we appreciate Defendants' explanation about Mr. Epstein's clothing (which was not previously provided to
Page: EFTA00028473 →Entities connected to both Jeffrey Epstein and Thurgood Marshall United States
Darren Indyke
PERSON
Alan Dershowitz
PERSONSouthern District
LOCATIONJane Doe
PERSON
Steven Hoffenberg
PERSONSullivan
PERSON
Foley Square
LOCATIONFailla
PERSON
Gary H. Baise
PERSONKatherine Polk Failla
PERSONRichard J. Sullivan
PERSONThe Mintz Fraade Law Firm
ORGANIZATION