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Case 1:19-cv-07625-AJN-DCF Document 36 Filed 11/29/19 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-------------------------------------- X
VE, :
:
Plaintiff, :
:
v. : Index No. 1:19-cv-07625-AJN
:
DARREN K. INDYKE AND RICHARD D. :
KAHN, AS JOINT PERSONAL :
REPRESENTATIVES OF THE ESTATE OF :
JEFFREY E. EPSTEIN, NINE EAST 71st :
STREET, CORPORATION, FINANCIAL :
TRUST COMPANY, INC., NES, LLC, :
:
Defendants.
-------------------------------------- X
NOTICE OF DEFENDANTS’ MOTION TO DISMISS
PLAINTIFF’S FIRST AMENDED COMPLAINT
PLEASE TAKE NOTICE that upon the accompanying Memorandum of Law, the
Declaration of Bennet J. Moskowitz dated November 29, 2019 and the exhibit thereto, and all
prior pleadings and proceedings in this action, Defendants Darren K. Indyke and Richard D.
Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, Nine East 71st Street, Corporation,
Financial Trust Company, Inc., and NES, LLC will move this Court before the Hon. Alison J.
Nathan, United States District Judge, at the Thurgood Marshall United States Courthouse, 40
Foley Square, New York, New York 10007, on December 13, 2019 at 10:00 a.m., or as soon
thereafter as counsel may be heard, for an Order pursuant to Rule 12(b)(6) of the Federal Rules
of Civil Procedure dismissing Counts I and III - V of Plaintiff VE’s First Amended Complaint
(Doc. # 3) in their entity and Count II to the extent it is time barred, with prejudice for failure to
state a claim; and for such other and further relief as may be just and proper.
Case 1:19-cv-07625-AJN-DCF Docume
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