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047.pdf
This document is a letter dated December 26, 2019, from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Alison J. Nathan. It requests a one-week extension (until January 2, 2020) for the defendants, including the Co-Executors of Jeffrey Epstein's estate (Indyke and Kahn) and related corporate entities, to file a reply supporting their Motion to Dismiss in the case VE v. Nine East 71st Street. The plaintiff consented to this extension request.
041.pdf
This document is a letter filed on December 9, 2019, by attorney Bradley J. Edwards to Judge Alison J. Nathan regarding the case VE v. Nine East 71st Street (1:19-cv-07625). The letter informs the court that the Plaintiff (VE) will not file an amended pleading in response to the Defendants' Motion to Dismiss filed in November 2019, but will instead defend the existing First Amended Complaint. The document establishes the legal representation of the plaintiff by Edwards Pottinger LLC in this civil action against an Epstein-related entity.
029.pdf
A letter from attorney Bennet J. Moskowitz to Judge Alison J. Nathan requesting a two-week extension for the Epstein Estate executors and associated entities to respond to a complaint in the case 'VE v. Nine East 71st Street'. The Judge granted the request on November 14, 2019, extending the deadline to November 29, 2019, but handwritten notes explicitly state 'No further extensions'.
028.pdf
This document is a letter from attorney Bradley J. Edwards to Judge Alison J. Nathan in the case of VE v. Nine East 71st Street, et al., dated November 12, 2019. Edwards opposes the Defendants' request for a two-week extension to respond to the complaint, arguing that they have already been granted a 45-day extension and that the upcoming Rule 26(f) conference should proceed. The letter notes that the Defendants' delay is related to a filing in the U.S. Virgin Islands regarding a 'claims resolution program' for the Estate of Jeffrey E. Epstein, which the Plaintiff argues should not halt the current litigation.
027.pdf
A letter from attorney Bennet J. Moskowitz to Judge Alison J. Nathan dated November 12, 2019, requesting a two-week extension for the Defendants (Executors of Epstein's Estate and related entities) to respond to the Plaintiff's complaint in the case VE v. Nine East 71st Street, et al. The letter notes that Plaintiff's counsel refused to consent to the extension.
021.pdf
This document is a legal letter dated September 18, 2019, from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Alison J. Nathan. It concerns the case VE v. Nine East 71st Street, et al., representing the Estate of Jeffrey Epstein and associated entities. The letter confirms an agreement between the parties to accept service of the complaint and extends the defendants' deadline to respond until November 15, 2019; the request was 'So Ordered' by the judge on September 19, 2019.
030.pdf
This document is a letter dated March 20, 2020, from attorney Joshua I. Schiller of Boies Schiller Flexner LLP to Judge Paul G. Gardephe. It requests oral argument regarding the Defendants' motion to dismiss the complaint in the case of Helm v. Indyke et al. The letter argues that the Plaintiff's claims are timely under New York law and doctrines of equitable estoppel/tolling, contrary to the Defendants' assertions.
013.pdf
Legal correspondence from Boies Schiller Flexner LLP to Judge Gardephe regarding the case Helm v. Indyke et al. The letter argues against the Defendants' anticipated motion to dismiss, asserting that Plaintiff Teresa Helm's claims are timely under NY CPLR § 215(8)(a) due to the recent termination of Epstein's criminal case (August 2019) and the doctrine of equitable estoppel based on Epstein's intimidation and manipulation tactics. The letter also argues that challenges to punitive damages are premature at this stage of litigation.
027.pdf
A letter from defense attorney Bennet J. Moskowitz to Judge Paul A. Engelmayer in the case of Jane Doe 17 v. Estate of Jeffrey Epstein. The defense requests the court vacate a recent order granting the plaintiff anonymity, not to oppose the anonymity itself, but to ensure they have the opportunity to respond regarding the specific terms of that anonymity to protect their defense rights, citing a previous deadline of December 21, 2019.
021.pdf
A legal filing from Troutman Sanders LLP on behalf of the Estate of Jeffrey Epstein and associated corporate entities in the case Jane Doe 17 v. Indyke et al. The letter informs Judge Engelmayer of an agreement between parties regarding the acceptance of service and an extension of time until December 21, 2019, for the defendants to respond to the complaint. The judge granted and signed the order on November 5, 2019.
025.pdf
A legal letter from Boies Schiller Flexner LLP to Judge Lorna G. Schofield arguing against the Defendants' anticipated motion to dismiss in the case of Jane Doe 1000 v. Indyke et al. The letter argues that the Plaintiff's claims are timely under New York Law (CPLR § 215(8)(a) and § 213-c) and the doctrine of equitable estoppel due to Epstein's intimidation tactics. It also asserts that punitive damages should be addressed after discovery.
EFTA00030015.pdf
Defense attorney Bobbi Sternheim writes to Judge Alison Nathan objecting to a second superseding indictment filed against Ghislaine Maxwell just months before the scheduled July 2021 trial. The defense argues this expansion of charges (covering 1994-2004) constitutes tactical gamesmanship and abuse of power, potentially necessitating a delay in the trial. The letter also requests an in-person arraignment and a new bail hearing, citing issues with remote proceedings and referencing Maxwell's difficult detention conditions.
EFTA00029590.pdf
Defense attorney Jeffrey Pagliuca writes to Judge Nathan objecting to the government's recent attempts to avoid disclosing the identities of unnamed co-conspirators and specific co-conspirator statements intended for trial. The defense characterizes the government's position as an improper 'motion to reconsider' prior court orders without showing extraordinary circumstances. The letter requests the Court confirm its orders requiring disclosure by October 11, 2021, to allow the defense to prepare motions in limine regarding the admissibility of statements from Jeffrey Epstein and an unnamed employee.
EFTA00027169.pdf
Defense attorney Jeffrey Pagliuca writes to Judge Alison Nathan arguing against the government's request to defer ruling on Ghislaine Maxwell's motion to suppress evidence until after the trial on non-perjury counts. The defense contends that an evidentiary hearing is necessary immediately because the government's alleged misconduct (misleading a judge to obtain a subpoena) constitutes a due process violation that could suppress all 90,000 pages of evidence and any derivatives ('fruit of the poisonous tree'). Furthermore, the defense argues that Maxwell cannot knowingly decide whether to testify without knowing the admissibility of this evidence, as the government has only promised not to use it in its case-in-chief but reserved rights for impeachment.
EFTA00023329.pdf
Defense counsel Christian Everdell writes to Judge Alison Nathan opposing the government's request to delay the disclosure of evidence (photographs and documents) regarding alleged victims of Jeffrey Epstein. The defense argues these materials are exculpatory under Brady because they relate to post-1997 allegations where witnesses do not implicate Maxwell, thereby supporting her defense against perjury charges that she was unaware of Epstein's abuse. The letter also argues the government has failed to show 'good cause' under Rule 16 to delay this discovery.
EFTA00019579.pdf
This document is an email dated April 16, 2019, from a Courtroom Deputy to the Hon. Sarah Netburn at the SDNY. The email notifies a recipient (Mr. [Redacted]) of an attached sealed order regarding the application to unseal civil discovery materials in case 19-mc-00179.
EFTA00019577.pdf
This document is an email chain from March and April 2019 involving an Assistant U.S. Attorney for the Southern District of New York and the chambers of Judge Sarah Netburn regarding the case 'Jane Doe 43 v. Epstein, et al.' The correspondence discusses the submission of a letter providing additional authority for a government application and a request from the Judge's chambers for a Word version of a Sealed Order.
EFTA00019482.pdf
This document is an email chain from March 14, 2019, between a Courtroom Deputy for Judge Sarah Netburn (SDNY) and an Assistant U.S. Attorney. The deputy requests a Microsoft Word version of a 'Sealed Order' for Judge Netburn regarding the civil case 'Jane Doe 43 v. Epstein, et al.' The Assistant U.S. Attorney replies affirmatively and attaches the document titled '2019-03-14, _JE,_unsealing_proposed_order_(as_submitted_2019-02-05).docx'.
EFTA00018214.pdf
This document is a subpoena from the US District Court (SDNY) in the case of USA v. Ghislaine Maxwell, issued to Jordana Feldman of the Epstein Victim's Compensation Program (EVCP). The defense (Maxwell's legal team) is demanding the production of all claim forms, communications, payment records, and releases related to four specific (redacted) accusers who submitted claims to the EVCP. The deadline for production was set for November 29, 2021.
EFTA00017821.pdf
This document is a letter from Ghislaine Maxwell's attorney, Bobbi Sternheim, to Judge Alison Nathan, dated November 24, 2020. It details complaints about Maxwell's detention conditions at the MDC, including harsh quarantine measures after COVID-19 exposure, lack of basic hygiene items like soap and a toothbrush, deletion of legal emails, and sleep deprivation due to flashlight checks every 15 minutes. The letter concludes with a request to summon Warden Heriberto Tellez, followed by a court order from Judge Nathan requiring the parties to meet and confer on the matter.
EFTA00016720.pdf
This document is a letter from defense attorney Jeffrey Pagliuca to Judge Alison Nathan dated October 14, 2021, regarding the case United States v. Ghislaine Maxwell. The defense requests confirmation that the deadline for filing a motion under Federal Rule of Evidence 412 (regarding alleged victims' sexual behavior) is November 15, 2021. The letter argues that recent massive discovery disclosures (over 8,000 pages of 3500 material) and notices regarding Rule 404(b) witnesses received just three days prior require additional time for review, especially given Maxwell's incarceration.
EFTA00010224.pdf
This document is a subpoena issued by the defense team of Ghislaine Maxwell (Case No. 20CR330) to an undisclosed recipient (likely an administrator of the Epstein Victims' Compensation Program). The subpoena demands the production of materials submitted by accusers to the EVCP, including claim forms, communications, payment records, and releases. Attached to the subpoena is the 'Independent Epstein Victims' Compensation Program Protocol' (dated May 29, 2020), which details the rules, eligibility requirements, and procedures for victims seeking compensation from the Epstein Estate, noting that the program is voluntary, independent, and confidential.
EFTA00010045.pdf
This document is a subpoena issued by Ghislaine Maxwell's defense team in November 2021, commanding the production of records from the Epstein Victims' Compensation Program (EVCP). The subpoena seeks all materials submitted by accusers, communications between the EVCP and accusers, records of payments, and executed releases. Attached to the subpoena is the 'Protocol' for the EVCP dated May 29, 2020, which outlines the independent program's purpose, eligibility requirements, claims administration process, and confidentiality rules for compensating victims of Jeffrey Epstein.
DOJ-OGR-00008431.jpg
This legal document is a letter dated December 15, 2021, from defense attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. The letter is a response to the government's motion to prevent a witness, Alexander Hamilton, from testifying about four specific topics related to an individual named 'Kate'. The defense argues that providing Hamilton's declaration to the government under Rule 26.2 does not obligate them to introduce all of its contents as evidence.
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