Draft: efta02737992

CASE NO. 19-cv-9610¶

JANE DOE 17,¶

Plaintiff,¶

v.¶

DARREN K. INDYKE AND RICHARD D. KAHN, AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN, NINE EAST 71st STREET CORPORATION, LAUREL, INC., FINANCIAL TRUST COMPANY, INC., NES, LLC, MAPLE, INC., LSJE, LLC, HBRK ASSOCIATES, INC., NAUTILUS, INC., CYPRESS, INC. and JEGE, INC.¶

Defendants.¶

UNOPPOSED MOTION TO ADMIT COUNSEL PRO HAC VICE¶

PURSUANT TO RULE 1.3(c) of the Local Rules of the United States District Courts for the Southern and Eastern Districts of New York, I, Andrew S. Buzin, a member in good standing of the bar of this Court, hereby move for an Order allowing the admission pro hac vice of:¶

David C. Appleby, Esq. FBN 500089 100 S.E. 2nd Street, Suite 4500 Miami, FL 33131 Ph: (305) 371-3111 Fax: (305) 577-8375 dappleby@goldfarbpa.com Attorney for Plaintiff, Jane Doe 17¶

Mr. Appleby is a member in good standing of the Florida Bar. There are no pending disciplinary proceedings against Mr. Appleby in any State or Federal court.¶

I have consulted with counsel for Defendants, Bennet Moskowitz, Esq., of "nominal, Sanders LLP, who has advised that Defendants do not oppose this Motion.¶

Dated: New York, New York October 24, 2019¶

Respectfully Submitted,¶

By: /s/ Andrew S. Buzin Andrew S. Buzin BUZIN LAW, P.C. 111 Broadway, Suite 1204 New York, NY 10006 Tel: (646) 470-4878 Fax: (347) 736-9490 abuzin@buzinlaw.com Attorneys for Plaintiff, Jane Doe 17¶

CERTIFICATE OF SERVICE¶

I hereby certify that on October 24, 2019, I caused true and correct copies of the foregoing Motion to Unopposed Motion To Admit Counsel Pro Hac Vice, Affidavit of David C. Appleby, Esq. in Support of Motion to Admit Counsel Pro Hac Vice, and Order for Admission Pro Hac Vice on Written Motion to be served by electronic mail on defense counsel listed below:¶

Bennet J. Moskowitz Troutman Sanders 875 Third Avenue New York, NY 10022 Direct: 212.704.6087 bennet.moskowitz@troutman.com

¶

By:

¶

AND S. BU abuzin®buzinlaw.¶

CASE NO. 19-cv-9610¶

JANE DOE 17,¶

Plaintiff,¶

v.¶

DARREN K. INDYKE AND RICHARD D. KAHN, AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN, NINE EAST 71st STREET CORPORATION, LAUREL, INC., FINANCIAL TRUST COMPANY, INC., NES, LLC, MAPLE, INC., LSJE, LLC, HBRK ASSOCIATES, INC., NAUTILUS, INC., CYPRESS, INC. and JEGE, INC.¶

Defendants.¶

DECLARATION OF DAVID C. APPLEBY, ESQ. IN SUPPORT OF MOTION TO ADMIT COUNSEL PRO HAC VICE¶

I, David C. Appleby, Esq., declare under penalty of perjury as follows:¶

• I. Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern Districts of New York, I hereby seek admission from this Court to practice Pro Hac Vice to appear as counsel for Plaintiff JANE DOE 17 in the above-captioned action.
• 2. I am in good standing of the bar of the State of Florida and there are no pending disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3.
• 3. I have consulted with counsel for Defendants, Bennet Moskowitz, Esq., of Troutman Sanders LLP, who has advised that Defendants do not oppose this Motion.

Dated: Lake Worth, Florida October 24, 2019¶

Respectfully submitted,¶

DAVID C. APPLEBY, P.A.¶

/s/ David C. Appleby¶

David C. Appleby, Esq. FBN 500089¶

100 S.E. 2" Street, Suite 4500¶

Miami. FL 33131¶

Ph: (305) 371-3111¶

Fax: (305) 577-8375¶

dap_plebv goldMrbpa.com¶

Attorney for Plaintiff, Jane Doe 17¶

CASE NO.¶

JANE DOE 17,¶

Plaintiff,¶

v.¶

DARREN K. INDYKE AND RICHARD D. KAHN, AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN, NINE EAST 71st STREET CORPORATION, LAUREL, INC., FINANCIAL "FROST COMPANY, INC., NES, LLC, MAPLE, INC., LSJE, LLC, HBRK ASSOCIATES, INC., NAUTILUS, INC., CYPRESS, INC. and JEGE, INC.¶

Defendants.¶

AFFIDAVIT¶

I, DAVID C. APPLEBY, hereby declare as follows:¶

• 1. I make this Affidavit in connection with my Motion for Admission Pro Hac Vice in the above-captioned matter as co-counsel for Plaintiff, Jane Doe 17.
  • 2. I am an associate at the law firm of Alan Goldfarb, P.A.
  • 3. I am a member in good standing of the bar of the State of Florida (Exhibit "A").
  • 4. I have never been convicted of a felony.
• 5. I have never been censured, suspended, disbarred, or denied admission or readmission by any court.
• 6. There arc no pending disciplinary proceedings against me in any state or Federal Court.

FURTHER AFFIANT SAYETH NAUGHT.¶

¶

DAVID C. APPLEBY¶

STATE OF FLORIDA )
) SS
COUNTY OF MIAMI-DADE )¶

The foregoing instrument was acknowledged before me this 17^th day of October, 2019,¶

by DAVID C. APPLEBY, who is personally known to me.¶

¶

upreme Court of Artoriba Certificate of oob 6tanbing¶

I JOHN A. TOMASINO, Clerk of the Supreme Court of the State of Florida, do hereby certify that¶

DAVID CHARLES APPLEBY¶

was admitted as an attorney and counselor entitled to practice law in all the Courts of the State of Florida on October 17, 1985, is presently in good standing, and that the private and professional character of the attorney appear to be good.¶

WITNESS my hand and the Seal of the Supreme Court of Florida at Tallahassee, the Capital, this October 24, 2019.

¶

¶

Clerk of the Supreme Court of Florida.¶

CASE NO. 1:19-cv-09610-PAE¶

JANE DOE 17,¶

Plaintiff,¶

v.¶

DARREN K. INDYKE AND RICHARD D. KAHN, AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN, NINE EAST 71st STREET CORPORATION, LAUREL, INC., FINANCIAL TRUST COMPANY, INC., NES, LLC, MAPLE, INC., LSJE, LLC, HBRK ASSOCIATES, INC., NAUTILUS, INC., CYPRESS, INC. and JEGE, INC.¶

Defendants.¶

!PROPOSED] ORDER GRANTING DAVID C. APPLEBY ADMISSION TO APPEAR PRO HAC VICE¶

Upon motion, for an order permitting him to appear and practice pro hac vice in the within action on behalf of Plaintiff, Jane Doe 17, it is hereby¶

ORDERED that the Motion for David C. Appleby to Appear Pro Hac Vice be GRANTED.¶

UNITED STATES DISTRICT JUDGE¶

Dated: October, 2019¶