UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK¶
X JANE DOE 17, Plaintiff, v. DARREN K. INDYKE AND : Case No. I :19-cv-09610-PAE-DCF 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. X¶
NOTICE OF DEFENDANTS' MOTION TO DISMISS PLAINTIFF'S COMPLAINT¶
PLEASE TAKE NOTICE that upon the accompanying Memorandum of Law, the Declaration of Bennet J. Moskowitz dated December 23, 2019 and the exhibit thereto, and all prior pleadings and proceedings in this action, 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., NES, LLC, Laurel, Inc., Maple, Inc., LSJE, LLC, HBRK Associates, Inc., Nautilus, Inc., Cypress, Inc., and JEGE, Inc. will move this Court before the Hon. Paul E. Engelmayer, United States District Judge, at the Thurgood Marshall United States Courthouse, 40 Foley Square, New York, New York 10007, on January 17, 2019 at 10:00 a.m., or as soon thereafter as counsel may be heard, for an Order pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure dismissing Plaintiff Jane Doe 17's Complaint (Doc. # I) in its entirety with¶
prejudice for failure to state a claim; and for such other and further relief as may be just and proper.¶
Dated: New York, New York¶
December 23.2019 Respectfully submitted,¶
TROUTMAN SANDERS LLP 875 Third Avenue New York, New York 10022¶
By: /s/ Bennet J. Moskowitz Bennet .1. Moskowitz¶
Attorneys for Defendants¶