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EFTA02752594

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Case 1:20-cv-02365-LJL-DCF Document 30 Filed 07/30/21 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE, Plaintiff, Docket No. 20-CV-02365 -againstDARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN; NES, LLC; NINE EAST 71sT STREET CORPORATION; FINANCIAL TRUST COMPANY, INC.; NEW YORK STRATEGY GROUP, LLC; DARREN K. INDYKE, in his capacity as trustee of EPSTEIN INTERESTS; DARREN K. INDYKE, in his capacity as a representative of J. EPSTEIN VI FOUNDATION; J. EPSTEIN VIRGIN ISLANDS FOUNDATION, INC.; C.O.U.Q. FOUNDATION, INC.; GRATITUTE AMERICA LTD.; DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as trustees of THE 1953 TRUST; SOUTHERN TRUST COMPANY, INC.; MAPLE, INC.; CYPRESS, INC.; LAUREL, INC.; SCI JEP; POPULAR, INC.; NAUTILUS, INC.; HBRK ASSOCIATES, INC.; JEGE, LLC; JEGE, INC.; PLAN D, LLC; HYPERION AIR, LLC; FREEDOM AIR INTERNATIONAL, INC.; ZORRO DEVELOPMENT CORP.; LSJE, LLC; L.S.J., LLC; ZORRO MANAGEMENT, LLC, DECLARATION OF DANIEL J. KAISER Defendants. Daniel J. Kaiser, being duly sworn, declares and affirms the following: I. I am Daniel J. Kaiser, a principal in the law firm of Kaiser Saurbom & Mair, P.C., and I submit this declaration in support of Plaintiff's motion to proceed anonymously. 2. Attached as Exhibit "A" is copy of the filed complaint. 3. Attached as Exhibit "B" is a copy of Abbie Tuller's Affidavit. 4. During the course of my representation of Jane Doe, I have fielded countless requests for interviews and tv specials. I have declined them all because my client wants to remain anonymous in her pursuit of justice in these proceedings. EFTA02752594

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