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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
___________________________________________x
TEALA DAVIES, Case No. 19 Civ. 10788 (GHW) (DCF)
Plaintiff,
-against-
DARREN K. INDYKE and RICHARD D. KAHN,
as EXECUTORS OF THE ESTATE OF JEFFREY E.
EPSTEIN,
Defendants.
___________________________________________x
DECLARATION OF DANIEL MULLKOFF
Daniel Mullkoff, Esq. declares under penalty of perjury, pursuant to 28 U.S.C. § 1746,
that the following is true and correct to the best of my knowledge:
1. I am an attorney admitted to practice in this Court and am an associate at Cuti Hecker
Wang LLP, which, along with Allred, Maroko & Goldberg, represents Plaintiff Teala Davies in
this matter. I submit this declaration in opposition to Defendants’ Motion to Dismiss (ECF 26).
2. Attached as Exhibit A hereto is a true and correct copy of the Last Will and
Testament of Jeffrey E. Epstein, dated August 8, 2019.
3. Attached as Exhibit B hereto is a true and correct copy of the First Amended
Complaint filed by the Government of the United States Virgin Islands on February 5, 2020 in
Government of the United States Virgin Islands v. Indyke et al. in the Superior Court of the
Virgin Islands.
4. Attached as Exhibit C hereto is a true and correct copy of an Affidavit of Service filed
on July 29, 2019 in Araoz v. Epstein, Index No. 156728/2019, in the Supreme Court of the State
New York, County of New York.
Dated: March 27, 2020
New York, New York __/s/ Daniel Mullkoff_______
Daniel Mullkoff