Epstein Secrets

morning, Your Honor. Bennet Moskowitz; Troutman Sanders, here with my colleague Charles Glover, and we represent the co-executors of the Estate of Jeffrey E. Epstein as well as with certain exceptions various other defendants in the actions for which we're here today. To explain that a little further -- THE COUR

minally abused, sexually abused by Mr. EFTA00078908 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 15 Epstein. There was radio silence, complete radio silence on their end for week after week despite repeated entreaties from myself and others for us to have

d we represent the co-executors of the Estate of Jeffrey E. Epstein as well as with certain exceptions vario

d we represent the co-executors of the Estate of Jeffrey E. Epstein as well as with certain exceptions variou

settle claims and what assets are going to go to Mr. Epstein's brother. We've had zero disclosure about that.

hance that I will not be. All right? And in particular right now I know that Judge Buchwald does not wish me to supervise hers. In addition, Judge Schofield has two cases right now. They are 19-CV-10475 and 19-CV-10577. I believe she scheduled her own conference a little farther down the road. I think

Claims Resolution Program in the U.S. Virgin Islands (the "Program"), under which the Estate will make compensatory payments to alleged victims of Jeffrey Epstein. Plaintiffs who participate in the Program and accept payment will be required to release all former employees or potential indemnitees of the Esta

or potential indemnitees of the Estate, including Ms. Maxwell, from any and all claims or causes of action that concern acts of sexual abuse by Mr. Epstein. We understand that, if the Program is approved, it may begin making payments as early as August 2020. Hence, Plaintiff's participation in the Prog

make compensatory payments to alleged victims of Jeffrey Epstein. Plaintiffs who participate in the Progr

s of action that concern acts of sexual abuse by Mr. Epstein. We understand that, if the Program is approved,

64 rx 303.832.2628 www.hmflaw.corn Imenningerathmflaw.com v. Darren K Indyke, et aL On behalf of defendant Ghislaine Maxwell, I write under Judge Schofield's Individual Rules and Procedures for Civil Cases III(A)(1) and this Court's Practices II(A) to request a pre-motion conference concerning our anti

ble Debra C. Freeman May 18, 2020 Page 2 Further, Maxwell has provided no information about the subject matter of the criminal investigation into Epstein's co-conspirators, the status of the investigation, or even disclosed whether she herself is a target of the Southern District's investigation. When

gh her criminal conduct would be directly at issue in that case, and the case would require discovery concerning such conduct. Maxwell v. Estate of Jeffrey E. Epstein, et at, ST-20-CV-155 (V.I. Super. Ct.); Willie v. Amerada Hess Corp., 66 V.I. 23, 92 (Super. Ct. 2017) (common law indemnification is only available

ry concerning such conduct. Maxwell v. Estate of Jeffrey E. Epstein, et at, ST-20-CV-155 (V.I. Super. Ct.);

ry concerning such conduct. Maxwell v. Estate of Jeffrey E. Epstein, et at, ST-20-CV-155 (V.I. Super. Ct.); W

the merits of Maxwell's motion to dismiss in her response to Maxwell's letter requesting a pre-motion conference on that motion. ECF No. 48. Judge Schofield's words at the pre-motion conference—in which she suggested that Maxwell's counsel not file a motion to dismiss—speak for themselves, and demonstrat

ir capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL, Defen

RICT COURT SOUTHERN DISTRICT OF NEW YORK Plainta v. DARREN K. INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL, Defendants. Case No. 1:19-cv-10475-LGS-DCF PLAINTIFF RESPONSES AND OBJECTIONS TO DEFENDANTS DARREN K. INDYKE AND RICHA

the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL, Defendants. Case No.

addition to or different from those imposed by the Federal Rules of Civil Procedure, the Local Rules of the Southern District of New York, or Judge Schofield's or Judge Freeman's Individual Rules and Practices. 3. Any objection to any of the Interrogatories is not an admission that Plaintiff has any in