## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

JANE DOE,

Plaintiff,

-against-

DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN; NES, LLC; NINE EAST 71sT STREET CORPORATION; FINANCIAL TRUST COMPANY, INC.; NEW YORK STRATEGY GROUP, LLC; DARREN K. INDYKE, in his capacity as trustee of EPSTEIN INTERESTS; DARREN K. INDYKE, in his capacity as a representative of J. EPSTEIN VI FOUNDATION; J. EPSTEIN VIRGIN ISLANDS FOUNDATION, INC.; C.O.U.Q. FOUNDATION, INC.; GRATITUTE AMERICA LTD.; DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as trustees of THE 1953 TRUST; SOUTHERN TRUST COMPANY, INC.; MAPLE, INC.; CYPRESS, INC.; LAUREL, INC.; SCI JEP; POPULAR, INC.; NAUTILUS, INC.; HBRK ASSOCIATES, INC.; JEGE, LLC; JEGE, INC.; PLAN D, LLC; HYPERION AIR, LLC; FREEDOM AIR INTERNATIONAL, INC.; ZORRO DEVELOPMENT CORP.; LSJE, LLC; L.S.J., LLC; ZORRO MANAGEMENT, LLC,

Defendants.

Docket No. 20-CV-02365

NOTICE OF MOTION TO PROCEED ANONYMOUSLY

PLEASE TAKE NOTICE that, upon the accompanying memorandum of law, and all prior pleadings and proceeding herein, Jane Doe ("Plaintiff") will move this Court, before the Honorable Debra C. Freeman, U.S.D.J., at the United States Courthouse, 500 Pearl Street, New York, New York 10007, for an Order, pursuant to Rule 10(a) of the Federal Rules of Civil

Procedure, for leave to proceed anonymously and for such other and further relief as the Court deems appropriate.

Dated: New York, New York July 30, 2021

KAISER SAURBORN & MAIR, P.C.

By:

Daniel J. Kaiser[DK-9387] 30 Broad Street, 37th Floor New York, New York 10004 (212) 338-9100

To: TROUTMAN PEPPER Bennet J. Moskowitz, Esq. 875 Third Avenue New York, New York 10022 (212) 704-6000