## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

VE,

Plaintiff,

Index No. 1:19-cv-07625-AJN

v.

DARREN K. INDYKE AND RICHARD D. KAHN, AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN, NINE EAST 71st STREET, CORPORATION, FINANCIAL TRUST COMPANY, INC., NES, LLC,

Defendants.

## DECLARATION IN SUPPORT OF DEFENDANTS' MOTION TO DISMISS PLAINTIFF'S FIRST AMENDED COMPLAINT

X

BENNET J. MOSKOWITZ hereby declares as follows:

- 1. I am a member of the bar of the State of New York.
- 2. I am a partner at Troutman Sanders LLP, counsel of record for Defendants Darren
- K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, Nine East 71st Street, Corporation, Financial Trust Company, Inc., and NES, LLC (together "Defendants").
  - 3. I am fully familiar with the facts and circumstances set forth herein.
- 4. I submit this declaration in support of Defendants' Motion to Dismiss Plaintiff VE's First Amended Complaint (ECF #3).
- 5. The sole purpose of this Declaration is to place before the Court a copy of Plaintiff's First Amended Complaint, which is attached hereto as Exhibit A.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: November 29, 2019

New York, New York /s/ Bennet J. Moskowitz Bennet J. Moskowitz