Case 1:19-cv-07625-AJN-DCF

Document 37

Filed 11/29/19

Page 1 of 1

# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

X

VE,

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, FINANCIAL
TRUST COMPANY, INC., NES, LLC,

Index No. 1:19-cv-07625-AJN

DECLARATION IN SUPPORT OF
DEFENDANTS’ MOTION TO DISMISS
PLAINTIFF’S FIRST AMENDED
COMPLAINT

Defendants.

X

BENNET J. MOSKOWITZ hereby declares as follows:

	1. I am a member of the bar of the State of New York.

2. I am a partner at Troutman Sanders LLP, counsel of record for 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., and NES, LLC (together, “Defendants”).

	3. I am fully familiar with the facts and circumstances set forth herein.

4. I submit this declaration in support of Defendants’ Motion to Dismiss Plaintiff VE’s First Amended Complaint (ECF #3).

5. The sole purpose of this Declaration is to place before the Court a copy of Plaintiff’s First Amended Complaint, which is attached hereto as Exhibit A. I declare under penalty of perjury that the foregoing is true and correct.

Executed on: November 29, 2019
New York, New York

/s/ Bennet J. Moskowitz
Bennet J. Moskowitz
documents/doj-86f159a7af4133b6.pdf
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