## KAPLAN HECKER & FINK LLP

## VIA ECF

The Honorable Katherine Polk Failla United States District Court Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007

NEW VORK, NEW YORK 10118

TEL (212) 763-0883 I FAX (212) 564-0883

WWW.KAPLANHECKER.COM

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November 1, 2019

Re: VE v. Nine East 7 hiStreet et aL, No. 19-cv-07625 (S.D.N.Y.) (Nathan, J.); Doe I et aL V. Jeffrey Epstein et aL, No. 19-cv-07675 (S.D.N.Y) (Daniels, J.); Doe v. Darren K Indyke et aL, No. 19-cv-07771 (S.D.N.Y.) (Castel, J.); Doe v. Darren K. Indyke et at, No. 19-cv-07772 (S.D.N.Y.) (Carter, J.); Doe v. Darren K Indyke et at, No. 19-cv-07773 (S.D.N.Y.) (Ramos, J.); Doe v. Indyke et. aL, No. 19-cv-08673 (S.D.N.Y.) (Failla, J.).

Dear Judge Failla:

We represent PlaintiffJane Doe in Doe v. Indyke et. aL, No. 19-cv-08673 a case against the estate of Jeffrey Epstein ("Epstein"). We write to request that the Court mark the six above-captioned actions as related and assigned to a single judge pursuant to Rule 13 of the Rules for the Division of Business Among District Judges in the Southern District ("Rule 13").

Rule 13 permits the Court to designate cases as related when the interests of justice and efficiency will be served. Here, the interests of justice and efficiency will be served by designating the aboveentitled actions as related because: (1) the actions concern the same or substantially similar parties and events; (2) there is substantial factual overlap; and (3) there would be substantial duplication of effort and expense for both the Court and the parties absent a determination of relatedness. See Rule 13(a); see also Poindexter V. Cash Money Records, No. I3-cv-5882, 2014 WL 1383781, at '2 (S.D.N.Y. Apr. 8, 2014).

More specifically, in each of these actions, plaintiffs bring claims against the Epstein estate relating to Epstein's systemic abuse of vulnerable, young girls or women. While the facts vary slightly with respect to each plaintiff, the overall alleged pattern is the same in every case: Epstein lured the young women to his home, where he exploited and sexually assaulted them for his own sexual pleasure.

As a result, many of the issues related to pre-trial litigation in these actions will be the same, and the Court and the parties will benefit from the efficiency of having one judge consider and rule upon the discovery and other pre-trial issues that will inevitably arise. Indeed, the need for uniformity and consistency is arguably even more pronounced here given the complexity of issues surrounding Epstein's estate (being probated in St. [REDACTED]) and concerns that plaintiffs have regarding document preservation. *See Louise Boyle, Exclusive: Executor of Jeffrey Epstein's Estate – Named in Lawsuit – Was Seen Removing a Bag of Items from the Pedophile's Mansion the Day After his Suicide. . . And After Millionaire had Admitted to Having "Damaging" Dirt on High-Powered House Guests*, DAILY MAIL. (Oct. 7, 2019).

Thank you for your consideration of this request. We copy on this letter all the Southern District of New York Judges currently assigned to these cases, the Chief Judge of the Southern District, and counsel in the other related cases.

![](<>)cc: Counsel of Record\
The Honorable Alison J. Nathan\
The Honorable [REDACTED] B. Daniels\
The Honorable P. Kevin Castel\
The Honorable Andrew L. Carter\
The Honorable Edgardo Ramos\
The Honorable Colleen McMahon\
Arick W. Fudali, Esq.\
[REDACTED] James [REDACTED], Esq.\
Brittany [REDACTED], Esq.\
John Pottinger, Esq.