Case 1:20-cv-00484-JGK-DCF Document 5 Filed 01/17/20 Page 1 of 7 1 UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF NEW YORK 3 JANE DOE, Case No. 1:20-cv-00484 4 Plaintiff, 5 v. 6 DARREN K. INDYKE and RICHARD D. 7 KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, 8 9 MEMORANDUM IN SUPPORT OF PLAINTIFF'S MOTION TO PROCEED BY PSEUDONYM Defendants. 10 Plaintiff Jane Doe ("Plaintiff"), by her undersigned attorneys, respectfully submits this a., 11 g memorandum of law in support of her motion for leave to proceed under a pseudonym. 12 I. O1 01,4 13 INTRODUCTION 14 HE a 31 Plaintiff Jane Doe suffered tremendous harm as a result of being sexually abused as a child 14 x2 2a v) a g 15 X $k 16 I 17 by the late Jeffrey Epstein. Epstein and his associates, in particular, Ghislaine Maxwell, coerced Jane Doe into becoming their sexual puppet for years through power, money and exploitation. And like countless others, Plaintiff was victimized for so long by Epstein and Maxwell and at such an early age that she has done everything she could to remain anonymous and live a normal life 18 now despite constant media requests for interviews and statements. 19 The details underlying Plaintiff's sexual abuse are highly personal, intimate and 20 humiliating to Plaintiff. Jane Doe has suffered drastically due to the Defendants' actions. Keeping 21 her identity protected from public disclosure in this already high-profile matter is imperative. 22 Indeed, public disclosure of her name in this litigation will expose some of the most intimate and 23 humiliating moments of Plaintiff's life, furthering her ongoing psychological harm and injuring 24 her family, including young children. 25 Additionally, there is no public interest in revealing the identity of one of Epstein's many 26 victims; to the contrary, allowing Plaintiff to proceed by pseudonym fosters the public interest in 27 having victims come forward