Bennet J. Moskowitz bennet.moskowitz@troutman.com¶
November 20, 2019¶
ECF¶
Hon. Paul A. Engelmayer Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007¶
Re: Jane Doe 17 v. Darren K. Indyke and Richard D. Kahn as Joint Personal Representatives of the Estate of Jeffrey E Epstein, et at, 1:19-cv-09610 (PAE)¶
Dear Judge Engelmayer:¶
We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (named herein as "Joint Personal Representativeis) of the Estate of Jeffrey E. Epstein"), Nine East 71st Street, Corporation, Financial Trust Company, Inc., NES, LLC, Laurel, Inc., Maple, Inc., LSJE, LLC, HBRK Associates, Inc., Nautilus, Inc., Cypress, Inc., and JEGE, Inc. (together "Defendants") in the referenced action. We write to respectfully request that the Court vacate its Order dated November 8, 2019 (ECF #25) granting Plaintiff's Motion to Proceed Anonymously (the "Motion") (ECF #24) filed earlier that day. The basis for this request is that Your Honor's Order dated November 5, 2019 (ECF #21) provides Defendants through December 21, 2019 to respond to Plaintiff's Motion.¶
Defendants did not have an opportunity to respond to Plaintiff's Motion. Defendants do not object to Plaintiff proceeding anonymously to prevent the disclosure of her identity to the general public. However, Defendants seek the opportunity to be heard so the relief granted on Plaintiff's Motion ensures Plaintiff may protect her anonymity without jeopardizing Defendants' fundamental right to fully and fairly defend against this action.¶
Plaintiffs' counsel does not consent to this request.¶
Thank you for your attention to this matter.¶
Respectfully submitted,¶
s/Bennet J. Moskowitz Bennet J. Moskowitz¶
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