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Case 1:19-cv-07625-AJN-DCF Document 4-1 Filed 08/20/19 Page 1 of 7
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
CASE NO.: 1:19-cv-07625-AJN
VE
Plaintiff,
vs.
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,
Defendant.
___________________________________/
MEMORANDUM OF LAW IN SUPPORT OF
PLAINTIFF’S MOTION FOR LEAVE
TO PROCEED ANONYMOUSLY
Case 1:19-cv-07625-AJN-DCF Document 4-1 Filed 08/20/19 Page 2 of 7
ARGUMENT
I. PLAINTIFF IS PERMITTED TO PROCEED ANONYMOUSLY IN
THIS CIRCUIT.
This action involves Jeffrey Epstein’s sexual assault of Plaintiff (“Plaintiff”)
in violation of the New York Law and/or the Trafficking Victims Protection Act
under 18 U.S.C. §§ 1591 through 1595. Plaintiff submits this Memorandum of Law
in support of Plaintiff’s Motion for Leave to Proceed Anonymously. Allowing
Plaintiff to proceed anonymously will protect her highly sensitive personal
information that will remain the focus of this litigation. There is no prejudice to
Defendants in allowing Plaintiff to proceed anonymously, nor is there any significant
public interest in the disclosure of the Plaintiff’s identity. In fact, the public interest
in this case weighs in favor of granting Plaintiff’s request to proceed anonymously
for her protection.
Federal Rule of Civil Procedure 10(a) requires a Complaint to “include the
names of all the parties.” However, the court has discretion to allow a plaintiff to
proceed anonymously. Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, 190 (2d.
Cir. 2008). “[C]ourts have granted anonymity to protect against disclosure of a wide
ra
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