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Case 1:19-cv-07625-AJN-DCF Document 20 Filed 09/18/19 Page 1 of 1
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutmariP
troutman.com
sanders
Bennet J. Moskowitz
bennet.moskowitz@troutman.com
September 18, 2019
ECF
Hon. Alison J. Nathan
Thurgood Marshall
United States Courthouse
40 Foley Square
New York, NY 10007
Re: VE v. Nine East 71st Street, et al., 1:19-cv-07625 (AJN)
Dear Judge Nathan:
We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E.
Epstein (named herein as “Joint Personal Representatives” of the Estate of Jeffrey E. Epstein),
Nine East 71st Street, Corporation, Financial Trust Company, Inc., and NES, LLC (together,
“Defendants”) in the referenced action. We write to respectfully request the Court’s approval of
the parties’ agreement described below.
On September 10, 2019, subject to the Court’s approval: (1) we agreed to accept service of
Plaintiff’s First Amended Complaint (ECF #3) on Defendants’ behalf; and (2) Plaintiff consented
to Defendants having through November 15, 2019 to answer, move or otherwise respond to
Plaintiff’s First Amended Complaint. There have been no previous requests for adjournments or
extensions of time in this action.
Thank you for your attention to this matter.
Respectfully submitted,
s/Bennet J. Moskowitz
Bennet J. Moskowitz