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Case 1:20-cv-02365-LJL-DCF Document 33 Filed 08/13/21 Page 1 of 2
Troutman Pepper Hamilton Sanders LLP
875 Third Avenue troutmariii
New York, New York 10022
pepper
troutman.com
Bennet J. Moskowitz
bennet.moskowitz@troutman.com
August 13, 2021
VIA ECF
Hon. Debra C. Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007
Re: Jane Doe v. Darren K. Indyke and Richard D. Kahn, in their capacities as
the Executors of the Estate of Jeffrey E. Epstein, 1:20-cv-02365-LJL-DCF
Dear Judge Freeman:
We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors
of the Estate of Jeffrey E. Epstein (the “Co-Executors”), in the above-referenced action.
We write pursuant to Your Honor’s Individual Practices § (III)(B) to request approval to
file the Co-Executors’ Statement on Plaintiff’s Application to Proceed Anonymously
(“Statement”) with redactions to ensure Plaintiff’s identity is not made public pending the
Court’s determination of her Application (ECF No. 29) (the “Application”). The unredacted
and redacted versions of the Statement and accompanying Declaration of Bennet J.
Moskowitz 1 are being filed under seal and publicly, respectively, contemporaneously
herewith in accordance with Individual Practices § (III)(B).
As a matter of context, on March 17, 2020, Plaintiff filed her complaint under the
pseudonym “Jane Doe.” (ECF No. 1.) On July 30, 2021, Plaintiff filed the Application,
requesting approval to prosecute this lawsuit pseudonymously. The Co-Executors have
never sought to prevent any alleged victim of Mr. Epstein from proceeding under a
pseudonym—and they do not do so here. However, in this unique situation, the Co-
Executors have determined that it is appropriate to bring to the Court’s attention material
facts
[…]