Troutman Sanders LLP

What this page does and does not contain

This page is about a law firm, not about Bennet J. Moskowitz. He is the lawyer who signs most of this record and he has a page of his own, which carries his invoices and billing rates, the client file number, the fifteen payments Epstein’s office made to this firm, his five declarations, the anonymity record in one Southern District action, and the disambiguation that keeps him apart from a physician of the same surname. None of that is restated here. This page is about what the firm did as a firm: what it was called, where it worked from, who else signed for it, what it was retained to do before the estate litigation began, and how much of its name in this release is its own act rather than someone else’s paper.

The firm’s name reaches a floor of 679 documents in this release, across 4,534 sheets. Of those, 198 carry the firm’s own signature, established in every case by reading the signature line rather than by trusting any database field. That is 29 per cent of the population; the other 71 per cent is mostly other people’s paper naming the firm. A further 254 court-class documents name the firm without the firm having signed them, and 18 more are a court reporter’s list of who appeared. Those are counted separately and are not acts.

The firm’s acts are concentrated to an unusual degree in one year and one hand. 164 of the 198 fall in 2020, and 134 of the 198 are signed by one lawyer. Six other lawyers sign the remaining 64 between them, and this page names all seven.

Nothing on this page is a finding of wrongdoing, and none is alleged. A lawyer acting for a client is not evidence of the lawyer’s knowledge, and this page does not treat it as such. No document read for this page accuses this firm or any of its lawyers of anything.

No complainant or survivor appears here in any form. The 2019-2021 actions this firm defended were brought against the executors of Epstein’s estate by plaintiffs identified in the public record by pseudonym. This page goes no further than the docket numbers and the firm’s own signature blocks, and reproduces nothing any plaintiff said.

No telephone number, fax number, electronic address, bank account number, routing number, taxpayer identification number or wire reference is reproduced here, the firm’s own included.

What it is	An American law firm whose own 2012 letterhead lists fifteen cities, which acted for Jeffrey Epstein from at least 2012, and from 2019 for Darren K. Indyke and Richard D. Kahn as co-executors of his estate12
Names it used, in order	Troutman Sanders LLP on every act to 22 June 2020; Troutman Pepper LLP from July 2020, though six acts of 14 August 2020 revert to the old style. Both styles read at the page image345
Offices on its own 2012 letterhead	TROUTMAN SANDERS LLP / Attorneys at Law / The Chrysler Building, New York. The foot of the sheet lists fifteen cities: ATLANTA CHICAGO HONG KONG NEW YORK NEWARK NORFOLK ORANGE COUNTY PORTLAND RALEIGH RICHMOND SAN DIEGO SHANGHAI TYSONS CORNER VIRGINIA BEACH WASHINGTON, DC. Read at the page image, which corrects a released text reading The Gni Der Sulkies1
New York office in the filings	875 Third Avenue, New York, NY 100223
Chicago office in the filings	One North Wacker Drive, Suite 2905, and later 227 W. Monroe Street, Suite 390067
Lawyers who sign for it in this release	Bennet J. Moskowitz (134 acts); Mary “Molly” S. DiRago (36); Charles L. Glover (16); Matthew J. Aaronson (8); Valerie Sirota (2); Stephen G. Rinehart (1); Mary W. Metcalfe (1)8
Earliest act located	17 June 2012, a seven-sheet letter to the American Arbitration Association over Stephen G. Rinehart’s signature, opening This firm represents Mr. Jeffrey Epstein. Read at the page image1
Latest act located	5 November 2021, a stipulation in No. 1:20-cv-023659
What it was retained to do	Resist an arbitration brought by Epstein’s public-relations firm over its fees (2012); defend Epstein and his Financial Trust Company against noteholders of Towers Financial (2018); answer a newspaper’s unsealing motion for him in the Appellate Division (January 2019); defend the co-executors of his estate in twelve parallel Southern District actions (2019-2021)1101112
Response	None located. No statement by the firm, under either name, or by anyone on its behalf about any document on this page has been found, and no request for one was made from here13
Not established here	That the firm knew of any conduct by its client beyond what the documents it wrote describe; that any matter it handled was connected to any other except where a sheet says so; or that any sequence set out here is a causal one14

Troutman Sanders was Jeffrey Epstein’s New York litigation firm, and after he died it was his executors’. It appears in this release across nine and a half years and four distinct engagements: an arbitration about a public-relations bill in 2012, a class action about a 1990s Ponzi scheme in 2018, a four-line response in a state appellate court in January 2019, and, from September 2019, the defence of Epstein’s estate against twelve parallel suits in the Southern District of New York. In July 2020, in the middle of that last engagement, the firm changed its name, and it told each of those courts so on a form.

That is not an inference from a mention count. It is what the firm’s own letters, motions, briefs, stipulations and notices of appearance say, and this page is built on the 198 of them that carry its signature.

The two names on the door

The record settles the successor-name question by itself, and it does so on a form.

On 10 July 2020 a Troutman lawyer, Matthew J. Aaronson, filed a one-page NOTICE OF CHANGE OF ADDRESS in No. 1:19-cv-10479-ALC-DCF, one of the actions against the co-executors. It is the Southern District’s standard Local Rule 1.3 form, and it has two boxes. Against OLD FIRM it gives FIRM NAME: Troutman Sanders LLP and an address at 875 Third Avenue. Against NEW FIRM it gives a new firm name and the same street address, the same telephone number and the same fax number. The box it ticks reads:

I will continue to be counsel of record on the above-entitled case at my new firm/agency.³

Read at the page image. The sheet also ticks I have cases pending.

That form was not filed once. Twenty-two documents were filed between 8 and 10 July 2020 across twelve different dockets, and twenty of the twenty-two carry both the old name and the new one, as the firm notified each court in turn. The other two carry the successor name alone.¹⁵ The ruling this page makes is therefore an evidenced one rather than a matter of general knowledge: the successor name is folded in, because the record shows the same lawyers continuing the same matters for the same clients at the same address, and says so on the court’s own form. Searching the old name alone misses 103 documents of this record.¹⁶

The firm went on signing under the old name after it had changed

The sequence is on the court’s own filing stamps, and it is not tidy.

Every act to 22 June 2020 signs TROUTMAN SANDERS LLP. The change-of-firm notices go out from 8 July. Acts then begin signing under the successor name. And then, on 14 August 2020, six documents across four dockets revert to TROUTMAN SANDERS LLP, a month after the firm had told those same courts the name had changed.⁴ One of the six was read at the page image and the paper confirms the old style.⁴ By 1 October 2020 the successor name is back, in a letter on the same docket, in the same template, over the same signature.⁵

Nothing in the release explains the reversion, and this page does not supply an explanation. It is recorded because a reader searching this record by firm name will hit it, and because it is the reason the old name keeps returning in documents filed long after the firm stopped bearing it.

This page uses only the two forms of the firm’s name that it read at the page image: Troutman Sanders LLP and Troutman Pepper LLP.³⁴⁵

June 2012: the public-relations bill

The earliest act of this firm in the release has nothing to do with the estate, nothing to do with any complainant, and nothing to do with the lawyer who signs the rest of this record. It is six years older than anything else here.

On 17 June 2012 Troutman Sanders wrote seven sheets to the American Arbitration Association in Fresno, California, marked CONFIDENTIAL and VIA E-MAIL AND U.S. MAIL, in a matter captioned Sitrick and Company v. Jeffrey Epstein. The letter opens:

This firm represents Mr. Jeffrey Epstein. We understand that on or about March 22, 2012 Sitrick and Company (“Sitrick”) unilaterally commenced an arbitration against Mr. Epstein (the “Arbitration”) before the American Arbitration Association (the “AAA”).¹

Its account of what the arbitration was about is one sentence:

Sitrick claims in this Arbitration that Mr. Epstein owes Sitrick money for public relations work that Sitrick allegedly performed for Mr. Epstein in connection with negative press circulated about the latter in 2011.¹

The firm’s position was that the arbitration clause Sitrick relied on had been signed years earlier by a different firm, Black, Srebnick, Kornspan & Stumpf, a Miami, Florida law firm, and had long since lapsed.¹ It closes:

For all of the above reasons, the Arbitration should be dismissed, or, alternatively, stayed pending a ruling by a court of competent jurisdiction on whether the claims are subject to arbitration.

Sincerely,

TROUTMAN SANDERS LLP¹⁷

Both the first and the last sheet were read at the page image, and the paper corrects the released text of this document repeatedly. The letterhead, which the released text renders The Gni Der Sulkies, reads The Chrysler Building. The addressee’s title, which the released text renders Mana r f ADR, reads Manager of ADR Services. The city, which the released text renders resno,, reads Fresno. And the document-control footer, which the released text renders 1498201O, reads 1498201v1.¹¹⁷

The signature is Stephen G. Rinehart’s, and he is not Bennet Moskowitz.¹⁷ It is the only act in this population signed by him. Several later acts are also letters rather than motions, among them the two joint status letters to a magistrate judge quoted elsewhere on this page.⁴⁵

A message of 13 September 2010 quoted at Bennet J. Moskowitz names a Steve Reinhart in connection with this firm, and that page records as unsettled whether the name is a different person or the sender’s error. This page does not settle it either. What the record establishes is only that a Stephen G. Rinehart signed for Troutman Sanders in 2012; that he is the man named in the 2010 message is not asserted here.

The arbitration letter is invisible to the firm’s name

Five documents in Epstein’s own office refer to a letter from this firm seeking exactly what this one sought, and not one of them can be reached by searching for the firm’s name. That they mean this letter is a strong inference from its date, its subject and its relief, and is not asserted here as a documented identity. They are calendar reminders set by Darren Indyke in June 2012, and each reads, in substance:

Remind me on June 25, 2012 that Sitrick is to provide a response to Troutman’s letter seeking dismissal or stay of the Sitrick arbitration in California.¹⁸

The firm is Troutman there and nothing else: no Sanders, no LLP. A sixth document, a July 2010 message from Richard Kahn, is the same shape.¹⁹ All six are in this page’s population only because the bare surname was checked by hand, and the method section explains what that cost.

2018: the Towers defence

In August 2018 noteholders of Towers Financial Corporation sued Epstein and his Financial Trust Company in the Southern District of New York. Troutman Sanders ran the defence, and the memorandum of law in support of the motion to dismiss carries the firm’s block on its cover:

TROUTMAN SANDERS LLP

875 Third Avenue

New York, New York 10022¹⁰

The firm is named there as Attorneys for Defendants The Financial Trust Company and Jeffrey E. Epstein, one of three engagements in this release in which it acts for Epstein himself rather than for his executors, the others being the 2012 arbitration and the January 2019 filing below.¹⁰ Two of the firm’s 198 acts belong to this matter, both dated 14 September 2018, and one of them is a sheet headed DRAFT; PRIVILEGED; ATTORNEY WORK PRODUCT.¹⁰²⁰ The matter itself, the case history and the firm’s bill for it are set out at Towers Financial Corporation and at Bennet J. Moskowitz, and are not repeated here.

January 2019: the last filing for Epstein alive

Seven months before Epstein died, and between the Towers defence and the estate work, the firm filed a four-line response for him in a state appellate court. Its caption names THE PEOPLE OF THE STATE OF NEW YORK as respondent and Epstein as Defendant-Appellant on separate lines, gives the number App. Div. No. 6081, and heads the document RESPONSE TO MOTION TO UNSEAL APPELLATE BRIEFS. It opens:

Defendant-Appellant Jeffrey E. Epstein, by and through undersigned counsel, does not oppose NYP Holding, Inc’s request to unseal the appellate briefs in the above-captioned matter …¹¹

It is the firm’s only act in this release captioned in a court other than the Southern District of New York, and the last act it signs for Epstein in his lifetime.¹¹ What the response said about redaction, who else signed it and what the newspaper’s motion sought are set out at NYP Holdings and at Bennet J. Moskowitz, and are not repeated here.

September 2019 to November 2021: the estate defence

This is where almost the whole of the firm’s act record lies.

The first act is a notice of appearance filed on 18 September 2019 in No. 1:19-cv-07625-AJN-DCF.² That docket and eleven others, twelve Southern District actions in all, make up the estate defence, every one of them brought against Indyke and Kahn as co-executors:

Docket	Acts
1:19-cv-10577	22
1:19-cv-10476	21
1:19-cv-10479	20
1:19-cv-10475	20
1:19-cv-07625	19
1:20-cv-00484	18
1:19-cv-08673	15
1:19-cv-11869	13
1:20-cv-02365	12
1:19-cv-09610	9
1:19-cv-10788	9
1:19-cv-10474	9

¹²

The work is the same work twelve times over. The acts are notices of appearance, motions to dismiss, answers, memoranda of law, responses to interrogatories, protective-order stipulations, joint status letters and stipulations of dismissal, filed in near-identical form across the parallel dockets within days of each other. On 8 May 2020, for instance, three Troutman lawyers, Aaronson, Glover and Sirota, filed notices of appearance in identical wording in several actions on the same day.²¹

The concentration in time is extreme. 164 of the 198 acts fall in 2020, more than four in five of the entire act record in a single year.⁸ Sixteen are dated 2019 and fifteen 2021, with one in 2012 and two in 2018.

The firm’s last act in the release is a stipulation filed on 5 November 2021 in No. 1:20-cv-02365, signed for the co-executors and approved by the court.⁹

What the firm did not sign

A court filing is an act of this firm only where this firm signed it, and most of these court documents are not. Of the 679 documents the firm’s name reaches:

• 198 carry a Troutman signature.
• 254 are court-class documents in which the firm is named but someone else signed: certificates of service by opposing counsel listing Troutman as a party served; affidavits by other firms’ lawyers recording that they had consulted Troutman; orders signed by judges granting Troutman lawyers leave to appear; and service blocks in plaintiffs’ own filings.⁸
• 18 are a court reporter’s APPEARANCES list, recording that Troutman lawyers were present at a hearing. That is evidence the firm appeared; it is not the firm’s signed act, and it is counted apart.⁸

The distinction matters because the project’s own document-type label attaches to all three classes without distinguishing them. 431 documents in this population carry a court-class label and only 198 are the firm’s act, so taken at face value that label would credit the firm with 2.18 times the record it signed.

Who signed for the firm

Lawyer	Acts	Where
Bennet J. Moskowitz	134	New York; every engagement from 2018
Mary “Molly” S. DiRago	36	Chicago; pro hac vice motions and stipulations of dismissal
Charles L. Glover	16	New York; notices of appearance, May 2020
Matthew J. Aaronson	8	New York; notices of appearance and the change-of-firm notices
Valerie Sirota	2	New York; notices of appearance, 8 May 2020
Stephen G. Rinehart	1	the 2012 arbitration letter
Mary W. Metcalfe	1	New York; notice of appearance, 16 July 2020

⁸

No document in this population is signed by two Troutman lawyers.⁸ Moskowitz signs 68 per cent of the firm’s acts; the firm’s record in this release is, to a degree unusual even for a single-partner relationship, one hand.

Six of those seven names are new to this wiki. The seventh, Bennet J. Moskowitz, has a page of his own, and what he did personally (what he billed, what he was paid, what he declared and what he argued about anonymity) belongs there and is deliberately not restated here.

DiRago’s route into the dockets is worth naming because it is the firm’s standard move. She is an Illinois lawyer, and in each New York action she filed a MOTION FOR ADMISSION PRO HAC VICE and a supporting affidavit describing herself as

a member in good standing of the State Bar of Illinois and an associate with the law firm Troutman Sanders LLP, counsel for Defendants, Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate of Jeffrey E. Epstein⁶

Sixteen of her thirty-six acts are such motions. The motions are the firm’s acts; the orders granting them are the court’s, and the two are counted on opposite sides of the line above.

Scope, method and what the counts rest on

The population is a floor built from the firm’s name, not a census of the firm’s work.

Forms tested, all against the desk’s full-text index of the release on 6 November 2026, counting distinct documents. The index was pinned by path and its size compared against the known figure before every run; a firing control and a null control were run in the same pass.¹⁶

Form	Documents	Kept?
troutman sanders	562	yes
troutman pepper	141	yes, 103 of them new
troutman sanders llp	500	subset
troutman, sanders	562	identical set to troutman sanders
troutman sanders llp.	500	identical set to troutman sanders llp
troutmansanders	12	yes, 0 new
troutman.com	313	yes, 4 new
troutman llp	2	yes
troutman sanders strickland	0	silent
troutmanpepper	0	silent
ts llp	1	not this firm: a damaged rendering of a different firm’s name22
troutman (bare)	687	not mined as the firm

The comma and the trailing period are discarded inside a token boundary, so troutman, sanders and troutman sanders llp. are not separate queries; both were tested rather than assumed.¹⁶

Three damaged shapes were tested as candidates and each turned out to be a real document: troutman anders, troutman smokes and trourman sanders return one document each, and all three are this firm: a certificate of service, a bank statement line and a wire instruction respectively. Seven further damage candidates returned nothing, and two more returned only documents already in the population.¹⁶ A damaged shape is treated here as a candidate to be checked, never as a form of the name.

The union of every form is 673 documents. The floor stated on this page is 679, because the bare surname was checked by hand and six further documents proved to be this firm and reachable no other way.¹⁶

The bare surname, and what pruning it cost

Troutman alone returns 687 documents and must not be mined as the firm. Twenty-two of those are reachable by no firm-name form, and each of the twenty-two was opened and its bearer read:

• Thirteen are the firm: five calendar reminders about the 2012 arbitration, one message about the firm’s accountants, four documents reaching the firm only through its mail domain, and three through damaged spellings of its name.
• Nine are not, and would have inflated this page by that much had the surname been taken as the firm. They are a town in North Carolina; a nominee to the Environmental Protection Agency; a surname in a bulk people-search printout; and six newspaper bylines, the same surname appearing as a reporter’s name in New York Post and Patch news digests.²³

The bar for excluding a document is the same as the bar for admitting one, and both directions were checked by hand here.

The act test

An act is a document on which a Troutman lawyer’s name stands in a signing position next to the firm’s name, read on the sheet. A screen proposed candidates; the screen was then corrected four times against controls that could fail, and every correction was an error of this desk’s own:

1. It counted a court reporter’s APPEARANCES list as a signature. 18 documents were moved out.
2. It missed a signature where the line break fell between By: and the name.
3. It missed the surname where the scan truncates Moskowitz to Mos owl and Mosko.
4. The screen and the tally were running different patterns, so a dozen pro hac vice motions counted in one and not the other. Both were rewritten to read from one source.

The final screen was run against 14 documents that must not fire and 15 that must, and passed on all 29.⁸

Replication, and the deflation that is not there

It is smaller than a court docket would lead you to expect. The 198 acts resolve to 189 distinct instruments once same-docket, same-date, same-signer copies are merged: a replication of 1.05, with only nine documents a second copy of something already counted.⁸

A looser measure, text similarity alone, would put it at 1.47, but that measure is wrong here, and wrong in an interesting way. The near-identical documents it merges are not duplicate copies; they are the same template filed in twelve parallel actions. Reporting 1.47 would describe as duplication the very thing that is the finding: that this firm filed the same document twelve times in twelve cases.

The figure of 708 sheets against 562 documents is not a replication figure and must not be read as one. It counts only the sheets on which the name appears. The 679 documents hold 4,534 sheets in total, 6.68 apiece.¹⁶

Two instruments that returned nothing, reported as results

The damaged From: form adds nothing here. The token fran, which is the scan’s rendering of From: elsewhere in this release, reaches 20,604 documents corpus-wide; fran together with troutman reaches zero. The control fires and the aim is right, so this is a measured zero rather than an untested silence.¹⁶

The union touches no native attachment. Tested against every EFTA member of the native-attachment population, the intersection is nil.¹⁶ This desk’s own count of that population returns 15 EFTA members where the desk’s standing note records sixteen; the discrepancy is not resolved here and is recorded rather than smoothed over.¹⁶

What is not established

• The 679 is a floor and the 198 is a floor. A document naming the firm in a form not tested here, or an act whose signature the scan destroyed, would not be in either count.
• Nothing is established about why the firm reverted to the old name on 14 August 2020.⁴
• No document read for this page says what the Hong Kong, Shanghai or Orange County offices on the 2012 letterhead consisted of, or whether any of them touched this work.¹
• Whether the Steve Reinhart of a 2010 message is Stephen G. Rinehart is not established, here or at Bennet J. Moskowitz.¹⁷
• The firm’s work between June 2012 and August 2018 is not in this release as an act. Six years separate the arbitration letter from the next signed document, and the firm was being paid throughout that gap; the payment record is at Bennet J. Moskowitz.¹⁴
• No document in this release accuses this firm or any lawyer named on this page of anything.¹⁴

Footnotes

Page and sheet convention. Printed page numbers on this page are 1-indexed, as the sheets themselves print them. Document counts are of documents, not sheets, and a document may hold many sheets.

Footnotes

1. Troutman Sanders LLP to Sandra L. Marshall, Manager of ADR Services, American Arbitration Association, Fresno, California, 17 June 2012, marked CONFIDENTIAL and VIA E-MAIL AND U.S. MAIL, re an arbitration captioned Sitrick and Company v. Jeffrey Epstein. EFTA01082714 printed p. 1. Read at the page image, rendered from the documented route at the sheet’s native 96 ppi. The letterhead sets TROUTMAN SANDERS LLP / Attorneys at Law / The Chrysler Building at the right of the sheet and the firm’s logotype at the centre; the foot of the sheet carries the fifteen city names quoted in the infobox, in small capitals across two lines. The paper corrects the released text of this sheet in at least three places: The Gni Der Sulkies is The Chrysler Building, Mana r f ADR is Manager of ADR Services, and a damaged two-line run of the address reads Fresno, CA 93704 on the paper. The street element of the firm’s own address and the addressee’s street are not reproduced here, nor is the arbitration reference printed on the sheet. The run is 7 sheets. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹

2. Notice of appearance, Dated: New York, New York September 18, 2019, over s/ Bennet J. Moskowitz for TROUTMAN SANDERS LLP, 875 Third Avenue, in No. 1:19-cv-07625-AJN-DCF (S.D.N.Y.). EFTA02846113 printed p. 1. Released text only. It is the earliest act of the firm in the estate litigation located for this page; an earlier appearance in some other action is not excluded. ↩ ↩²

3. NOTICE OF CHANGE OF ADDRESS, the Southern District of New York’s Local Rule 1.3 form, filed 10 July 2020 as Document 49 in No. 1:19-cv-10479-ALC-DCF, over s/Matthew J. Aaronson. EFTA02732313 printed p. 1. Read at the page image at the sheet’s native 96 ppi. The form prints OLD FIRM: with FIRM NAME: Troutman Sanders LLP and an address line giving 875 Third Avenue, New York, NY 10022, and NEW FIRM: with the successor name and the same address. The punctuation of that address line is not settled at 96 ppi and the line is therefore described rather than quoted. the telephone and fax lines repeat the same values in both boxes and are not reproduced here. The box ticked is I will continue to be counsel of record on the above-entitled case at my new firm/agency; the alternative, I am no longer counsel of record, is not ticked. The sheet also ticks I have cases pending and An attorney, and gives the filer’s bar numbers. This page makes no statement of any kind about how any producing party has treated anything on any sheet. ↩ ↩² ↩³ ↩⁴

4. Six acts carry ECF filing stamps of 14 August 2020 and sign in the old style, across four dockets: EFTA02732314 and EFTA02732316 in No. 1:19-cv-10479; EFTA02737894 in No. 1:19-cv-10577; EFTA02778219 in No. 1:19-cv-10475; and EFTA02819473 and EFTA02819475 in No. 1:19-cv-10476. One of the six was read at the page image: EFTA02732314 printed p. 1, Document 50, Filed 08/14/20, a joint status letter on opposing counsel’s letterhead whose second signature block reads /s/Bennet J. Moskowitz / Bennet J. Moskowitz, Esq. / Troutman Sanders LLP. Nothing of the letter’s content is reproduced, summarised or characterised here; the sheet is cited only for the firm’s signature block and the court’s filing stamp. The other five are cited from the released text. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

5. EFTA02732317 printed p. 1, Document 53 in No. 1:19-cv-10479-ALC-DCF, Filed 10/01/20. Read at the page image. The same template, the same docket and the same two signature blocks as ⁴, the second reading /s/ Bennet J. Moskowitz / Bennet J. Moskowitz, Esq. / Troutman Pepper LLP. As with ⁴, none of this letter’s content is reproduced here; the sheet is cited for the firm style and the filing stamp only. A method note. This desk first dated this document 26 June 2020, taking a date out of the letter’s body, and recorded a conclusion about when the successor name first appeared. The page image refuted it: the sheet is stamped and dated 1 October 2020. The dating of every act on this page was rebuilt afterwards on the court’s own ECF filing stamp, and the two sheets rendered here were used as the control that the rebuilt instrument agreed with the paper. It did, on both. ↩ ↩² ↩³ ↩⁴

6. AFFIDAVIT IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE of Mary “Molly” S. DiRago. EFTA02737263 printed p. 1 for the passage quoted. The accompanying MOTION FOR ADMISSION PRO HAC VICE is at EFTA02737267 printed p. 2, signed Mary "Molly" S. DiRago for Troutman Sanders LLP, One North Wacker Drive, Suite 2905, Chicago. Released text only. Orders granting these motions are signed by the court and are counted among the 254 documents the firm did not sign. ↩ ↩²

7. A filing of 18 August 2021 over /s/Mary "Molly" S. Dirago gives the firm’s Chicago address as 227 W. Monroe, Suite 3900. EFTA02752631 printed p. 2. Released text only. The spelling of the surname is as extracted and is not silently repaired. ↩

8. Act determination, 6 November 2026. An act is a document on which one of the firm’s lawyers’ names stands in a signing position (after /s/, s/, By: or an equivalent, including the scan’s damaged forms of those markers) within a short window of the firm’s name, read on the sheet. 198 of the 679 documents qualify, 29.2 per cent; the 198 hold 1,079 sheets of the population’s 4,534. Signing lawyer: Moskowitz 134, DiRago 36, Glover 16, Aaronson 8, Sirota 2, Rinehart 1, Metcalfe 1; 198 in total, and no document is signed by two of them. Excluded and counted separately: 18 documents in which the only appearance of a Troutman name in a signing position is inside a court reporter’s APPEARANCES list, and 254 court-class documents naming the firm over another party’s or the court’s signature. The screen was corrected four times, in each case against a control that could fail and in each case for an error of this desk’s own: it counted APPEARANCES lists as signatures; it could not bridge a line break between By: and a name; it required ow after Mos where the scan truncates the surname to Mosko and Mos owl; and the screen and the tally were running divergent patterns until both were rewritten to read from a single source. The final screen was run against 14 documents that must not fire and 15 that must, and classified all 29 correctly. Dates are taken from the court’s own ECF filing stamp where the sheet carries one (184 of 198), from a signature-anchored date on five more, and by hand on the remaining nine, which are the 2012 letter, the two 2018 Towers documents, two documents of 2019 and four of 2020. An earlier dating instrument that read dates out of the body prose was refuted at the page image and discarded, as recorded at ⁵. The resulting distribution is 2012: 1; 2018: 2; 2019: 16; 2020: 164; 2021: 15. Replication: merging acts that share a docket, a date, a signer and their text leaves 189 distinct instruments, a factor of 1.05, with 9 documents a second copy. A looser text-similarity measure gives 1.47 but conflates duplicate copies with the same template filed in parallel actions, and is not used. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸

9. Stipulation in No. 1:20-cv-02365-LJL-DCF (S.D.N.Y.), dated 5 November 2021, carrying the plaintiff’s firm’s signature block and the firm’s, and approved SO ORDERED by the court. EFTA02752686 printed p. 2. Released text only; this sheet was not read at the page image. ↩ ↩²

10. DEFENDANTS' MEMORANDUM OF LAW IN SUPPORT OF THEIR MOTION TO DISMISS PLAINTIFFS' COMPLAINT, No. 1:18-cv-07580-JPO (S.D.N.Y.), dated 14 September 2018. EFTA00802452 printed p. 1 for the cover block quoted, which names the firm as Attorneys for Defendants The Financial Trust Company and Jeffrey E. Epstein. Released text only; this sheet was not read at the page image for this page. The case history and the firm’s bill for the matter are set out at Towers Financial Corporation and Bennet J. Moskowitz. ↩ ↩² ↩³ ↩⁴

11. RESPONSE TO MOTION TO UNSEAL APPELLATE BRIEFS, Supreme Court of the State of New York, Appellate Division - First Department, App. Div. No. 6081, dated 6 January 2019, signed for TROUTMAN SANDERS LLP. EFTA00801681 printed p. 1. Released text only; this sheet was not read at the page image for this page. The caption prints the newspaper’s corporate name as NYP Holding, Inc and the appellant’s forename as it stands on the sheet; neither is silently repaired here. The sentence quoted in the body continues beyond the point at which it is cut, and the cut is marked with an ellipsis; the remainder, which states the condition the firm attached to its non-opposition, is quoted in full at the two pages named below. The remainder of the filing, including what it asked be redacted and the second signature on it, is set out at NYP Holdings and at Bennet J. Moskowitz and is deliberately not restated on this page. ↩ ↩² ↩³

12. Act counts by docket, taken over the 198 acts described at ⁸ and keyed on the Southern District case number printed in the ECF header of each sheet. The table omits two further acts in No. 1:18-cv-07580, the 2018 Towers matter at ¹⁰ and ²⁰, which is not one of the estate actions. 9 acts carry no case number in a machine-readable header and are not in the table; they are in the 198, and the twelve estate dockets plus the Towers action account for the other 189. ↩ ↩²

13. No response from Troutman Sanders, from the successor firm, or from any lawyer named on this page about any document on this page has been located. No statement, denial, comment or explanation has been found in this release. A response is not recorded as absent because anyone declined to give one. No request was made from here; the finding is only that none has been found. ↩

14. Statements of absence on this page are scoped to the documents read and returned for it, and to the searches described at ¹⁶ and ⁸, run on 6 November 2026. They are not claims about what the release holds and they are not claims about the world. In each case the control that shows the query could have found the thing is named at ¹⁶: the firing controls "richard m berman" and jeevacation, and the null control, were run in the same passes as the measurements they qualify. ↩ ↩² ↩³

15. 22 documents bearing ECF filing stamps between 8 and 10 July 2020, across 12 distinct Southern District dockets, each carrying both the old firm name and the successor name. Enumerated from the act set described at ⁸; the dockets are those tabulated at ¹². ↩

16. Index measurements taken 6 November 2026 against the desk’s full-text index of the released page text, counting distinct documents. The index was pinned by absolute path and its size compared against the known figure of 10,982,875,136 bytes before every run, and the comparison printed; a decoy file of the same name and zero length exists elsewhere on this machine and was confirmed to be 0 bytes and not the file used. Controls run in the same passes: the firing control "richard m berman" returns 371 documents across 885 sheets and the firing control jeevacation returns 567,984 documents across 752,295 sheets, both matching the desk’s standing figures; the null control returns 0. Form counts are tabulated in the body. Equivalences were tested, not assumed: troutman, sanders returns the same 562 as troutman sanders, and troutman sanders llp. the same 500 as troutman sanders llp, the comma and the period being discarded inside the token boundary. Set algebra was computed at document level from materialised identifier lists, not with the index’s boolean operators, which combine per sheet rather than per document and gave an overlap of 37 where the document-level figure is 38. Damage candidates tested: troutman anders, troutman smokes and trourman sanders return 1 document each, all three this firm; troutrnan sanders, troutman sanclers, troutman sandars, troutman sauders, troutman sanders ilp, troutman sanders iip and troutman sanders l.l.p. return 0; troutman sanders lip returns 5 and troutman sanders up 14, both being damage to the LLP element inside documents already counted, so neither adds a document. Union: the forms together reach 673 documents; with the 6 admitted at ²³ that reach the firm only through the bare surname, the floor is 679 documents across 4,534 sheets. Damaged From: form: the token fran returns 20,604 documents corpus-wide; fran AND troutman returns 0, so the damaged form adds nothing to this population. Native attachments: the intersection of the 679 with every EFTA member of the native-attachment population is 0. This desk’s own enumeration of that population returns 25 documents across 43 sheets, of which 15 are EFTA members, where the desk’s standing note records 26, 44 and sixteen; the marker family XLS/XLSX/CSV/TXT reaches 26 documents. The discrepancy is unresolved and is reported rather than reconciled. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹

17. Same letter, signature sheet. EFTA01082714 printed p. 7. Read at the page image. It carries the firm’s logotype, the continuation header the addressee’s name, the date, CONFIDENTIAL and Page 7 on four successive lines, the conclusion quoted above, then Sincerely, / TROUTMAN SANDERS LLP / /s/ Stephen G. Rinehart in italic script / Stephen G. Rinehart, and cc: Jonathan B. Cole, Esq. The released text renders the document-control footer 1498201O; the paper reads 1498201v1. This sheet carries no mark of any kind. ↩ ↩² ↩³ ↩⁴

18. Calendar reminders and alarms in Epstein’s office, June 2012. EFTA00410667 printed p. 1 for the wording quoted, a message of 21 June 2012; the same reminder recurs at EFTA00410439, EFTA00410669, EFTA02165970 and EFTA02167094, in two cases over Darren Indyke’s name. Released text only. None of the five contains any form of the firm’s name except the bare surname, which is why they are reachable only through the bearer check at ²³. ↩

19. Richard Kahn to Jeffrey Epstein, 8 July 2010, subject re: accountants, reading in part Per Bennet - Troutman uses E&Y, and he is going to send me a contact at Friedman. EFTA02410151 printed p. 1. Released text only. Like the five reminders, it names the firm by the bare surname only. ↩

20. A sheet in the same matter headed DRAFT; PRIVILEGED; ATTORNEY WORK PRODUCT, dated 14 September 2018 and closing Respectfully submitted, / TROUTMAN SANDERS LLP. EFTA00806706 printed p. 2. Released text only. The legend is printed on the face of the produced page; this desk records that and reasons no further about it. ↩ ↩²

21. Notices of appearance dated New York, New York. May 8, 2020, in identical wording, over the typed names Matthew J. Aaronson (EFTA02732138), Charles L. Glover (EFTA02732139) and Valerie Sirota (EFTA02732140), each printed p. 1, each giving TROUTMAN SANDERS LLP and 875 Third Avenue and each closing Attorneys for Defendants. Released text only, and the electronic signature line above the typed name is damaged in the extraction on two of the three sheets; those lines are therefore not reproduced here. The same three notices recur in several other actions in the same days. ↩

22. The single document returned by ts llp is not this firm. The sheet carries a service block reading, as extracted, KIRK AND & Fs.r TS LLP above an address at 601 Lexington Avenue, and names the attorneys for a defendant-appellant in a state appeal; the string is damage to a different firm’s name. EFTA00231917 printed p. 647. Released text only. The document is excluded from this page’s population, and the exclusion was made by reading the sheet rather than by inspecting the count. ↩

23. Bearer check, run by hand on 6 November 2026. The bare token troutman returns 687 documents. 665 of them carry a firm-name form. The remaining 22 were each opened and the bearer of the name read on the sheet. 13 are this firm and are admitted: five calendar reminders at ¹⁸; the message at ¹⁹; four documents carrying only the firm’s mail domain; and three carrying damaged spellings, namely EFTA00030306 (a certificate of service by opposing counsel, which is in the population but is not an act), EFTA01483728 (a bank statement line) and EFTA01585320. 9 are pruned, the bearer in each case being someone or something other than this firm: a municipality in North Carolina; a nominee for an Environmental Protection Agency post; a surname in a bulk people-search printout; and six documents in which the same surname is a newspaper reporter’s byline in news digests. Sanders alone was not searched, being certainly a different and much larger population. ↩ ↩² ↩³