Case 1:19-cv-09610-PAE-DCF

Document 27

Filed 11/20/19

Page 1 of 2

Troutman Sanders LLP
875 Third Avenue
New York, New York 10022

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sanders

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Bennet J. Moskowitz
bennet.moskowitz@troutman.com

November 20, 2019

ECF

Hon. Paul A. Engelmayer
Thurgood Marshall
United States Courthouse
40 Foley Square
New York, NY 10007

Re: Jane Doe 17 v. Darren K. Indyke and Richard D. Kahn as Joint Personal Representatives of the Estate of Jeffrey E. Epstein, et al., 1:19-cv-09610 (PAE)

Dear Judge Engelmayer:

We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (named herein as “Joint Personal Representative[s] 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. (together, “Defendants”) in the referenced action. We write to respectfully request that the Court vacate its Order dated November 8, 2019 (ECF #25) granting Plaintiff’s Motion to Proceed Anonymously (the “Motion”) (ECF #24) filed earlier that day. The basis for this request is that Your Honor’s Order dated November 5, 2019 (ECF #21) provides Defendants through December 21, 2019 to respond to Plaintiff’s Motion.

Defendants did not have an opportunity to respond to Plaintiff’s Motion. Defendants do not object to Plaintiff proceeding anonymously to prevent the disclosure of her identity to the general public. However, Defendants seek the opportunity to be heard so the relief granted on Plaintiff’s Motion ensures Plaintiff may protect her anonymity without jeopardizing Defendants’ fundamental right to fully and fairly defend against this action.

Plaintiffs’ counsel does not consent to this request.

Thank you for your attention to this matter.

Case 1:19-cv-09610-PAE-DCF

Document 27

Filed 11/20/19

Page 2 of 2

November 20, 2019

Page 2

troutman
sanders

Respectfully submitted,
s/Bennet J. Moskowitz
Bennet J. Moskowitz

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