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Case 1:19-cv-10577-LJL-DCF Document 7 Filed 11/20/19 Page 1 of 9

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

JANE DOE 1000,

Plaintiff, CASE NO: 19-cv-10577-LGS

DARREN K. INDYKE and RICHARD D. KAHN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,

Defendants.

_____________________________________

MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF’S
MOTION FOR LEAVE TO PROCEED ANONYMOUSLY

1
Case 1:19-cv-10577-LJL-DCF Document 7 Filed 11/20/19 Page 2 of 9

Plaintiff Jane Doe 1000, by her undersigned attorneys, respectfully submits this

memorandum of law in support of her motion for leave to proceed anonymously.

INTRODUCTION

This lawsuit arises out of Jeffrey Epstein’s years-long sexual abuse of Plaintiff. Because

of Jeffrey Epstein’s death on August 10, 2019, Plaintiff’s civil lawsuit against Defendants for

battery and intentional infliction of emotional distress is the only avenue for obtaining some form

of justice. But releasing her name to the public will expose some of her darkest moments and tie

those moments to her name in perpetuity. Using her real name in this litigation, therefore, would

cause her significant harm and distress, and would inhibit her ability to heal. For these and similar

reasons, other courts have allowed Epstein’s victims to proceed anonymously in numerous cases.

See, e.g., Doe 17 v. Indyke et al., No. 19 Civ. 9610 (S.D.N.Y. Nov. 8, 2019), Dkt. 25; Katlyn Doe

v. Darren K. Indyke, et al., No. 19 Civ. 7771 (S.D.N.Y. Sept. 12, 2019), Dkt. 28; Jane Doe 43

v. Epstein et al., No. 17 Civ. 616 (S.D.N.Y. Apr. 5, 2017), Dkt. 28; Jane Doe No. 103 v. Epstein,

No. 10 Civ. 80309 (S.D. Fla. Mar. 9, 2010), Dkt. 5; Doe v. Eps

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