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Case 1:19-cv-10474-NRB Document 26 Filed 03/27/20 Page 1 of 17
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ANNIE FARMER,
Plaintiff, CASE NO.: 1:19-cv-10475 (LGS) (DCF)
v.
DARREN K. INDYKE and RICHARD D.
KAHN, in their capacities as the executors of
the ESTATE OF JEFFREY E. EPSTEIN, and
GHISLAINE MAXWELL,
Defendants.
DEFENDANTS DARREN K. INDYKE AND RICHARD D. KAHN’S, AS CO-
EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, ANSWER
AND AFFIRMATIVE DEFENSES TO PLAINTIFF’S COMPLAINT
Defendants Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of
Jeffrey E. Epstein (the “Co-Executors”), through their undersigned counsel, hereby respond to the
numbered paragraphs of Plaintiff’s Complaint (ECF Doc. 1) as follows:
1. Insofar as the reference to “Defendants” in paragraph 1 of the Complaint includes
the Co-Executors, the Co-Executors deny the allegations in paragraph 1 of the Complaint. To the
extent the reference to “Defendants” does not include the Co-Executors, the Co-Executors lack
knowledge or information sufficient to form a belief about the truth of the allegations in paragraph
1 of the Complaint.
2. Insofar as the reference to “Defendants” in paragraph 2 of the Complaint includes
the Co-Executors, the Co-Executors deny the allegations in paragraph 2 of the Complaint. To the
extent the reference to “Defendants” does not include the Co-Executors, the Co-Executors lack
knowledge or information sufficient to form a belief about the truth of the allegations in paragraph
2 of the Complaint.
41907217v2
Case 1:19-cv-10474-NRB Document 26 Filed 03/27/20 Page 2 of 17
3. The Co-Executors lack knowledge or information sufficient to form a belief about
the truth of the allegations in paragraph
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