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      Case 1:20-cv-02365-LJL-DCF        Document 35     Filed 08/13/21   Page 1 of 5




                        UNITED STATES DISTRICT COURT
                       SOUTHERN DISTRICT OF NEW YORK

JANE DOE,

                           Plaintiff,
             v.                                       Case No. 1:20-cv-02365-LJL-DCF
DARREN K INDYKE and RICHARD D. KAHN, in
their capacities as executors of THE ESTATE OF
JEFFERY E. EPSTEIN,
                           Defendants.



                  CO-EXECUTORS’ STATEMENT ON PLAINTIFF’S
                   APPLICATION TO PROCEED ANONYMOUSLY




                   TROUTMAN PEPPER HAMILTON SANDERS LLP
                              875 Third Avenue
                          New York, New York 10022
                              Tel: 212-704-6000
                              Fax: 212-704-6288

              Attorneys for Defendants Darren K. Indyke and Richard D. Kahn,
                       Co-Executors of the Estate of Jeffrey E. Epstein




118390227
         Case 1:20-cv-02365-LJL-DCF               Document 35           Filed 08/13/21         Page 2 of 5




          Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey

E. Epstein (the “Co-Executors”)1, respectfully submit this Statement On Plaintiff Jane Doe’s

(“Plaintiff”) Application to Proceed Anonymously (ECF No. 31) (the “Application”).

    I.    The Co-Executors Have Never Opposed The Right Of Alleged Victims To Maintain
          Anonymity And Do Not Do So Here.

          The Co-Executors have never sought to prevent any alleged victim of Mr. Epstein from

proceeding anonymously; they do not do so here. To the contrary, after Mr. Epstein’s death, the

Co-Executors established and funded in its entirety the independently administered Epstein

Victims’ Compensation Program, which gave Mr. Epstein’s alleged victims the opportunity to

resolve their claims in complete confidence if they so desired.2 The Program ultimately awarded


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