On November 28, 2022 a
Party Notice
was filed
involving a dispute between
Cheri Pierson,
and
Darren K. Indyke
In His Capacity As The Executor For The Estate Of Jeffrey E. Epstein And Administrator Of The 1953 Trust,
Estate Of Jeffrey E. Epstein,
Leon Black,
Richard D. Kahn
In His Capacity As The Executor For The Estate Of Jeffrey E. Epstein And Administrator Of The 1953 Trust,
The 1953 Trust,
for Torts - Adult Survivors Act
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 12/28/2022 09:14 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 12/28/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
------------------------------------------------------------------------ X
CHERI PIERSON, :
: Index No.: 952002/2022
Plaintiff, :
: Hon. Suzanne Adams
v. :
: Motion Seq. No. 001
LEON BLACK, ESTATE OF JEFFREY E. EPSTEIN, :
DARREN K. INDYKE, in his capacity as the EXECUTOR :
FOR THE ESTATE OF JEFFREY E. EPSTEIN and :
ADMINISTRATOR OF THE 1953 TRUST; :
RICHARD D. KAHN, in his capacity as the EXECUTOR :
FOR THE ESTATE OF JEFFREY E. EPSTEIN and :
ADMINISTRATOR OF THE 1953 TRUST; and THE :
1953 TRUST, :
:
Defendant. :
----------------------------------------------------------------------- X
NOTICE OF CROSS-MOTION FOR SANCTIONS
PLEASE TAKE NOTICE, that upon the accompanying Memorandum of Law, dated
December 28, 2022, the annexed Affirmation of Jeanne M. Christensen, dated December 28, 2022,
and the exhibits attached thereto, and all the pleadings and proceedings had heretofore herein, in
accordance with CPLR 2214 and 2215, Plaintiff Cheri Pierson will cross-move this Court in the
Motion Submission Part 39 Courtroom, Room 623 at the Supreme Court of the State of New York,
New York County, located at 111 Centre Street, New York, New York 10013, on January 4, 2023
at 9:30 a.m. or as soon thereafter as counsel can be heard, for an Order pursuant to 22 NYCRR §
130.1-1 against Defendant Leon Black and his counsel, Perry Guha LLP and Quinn Emanuel
Urquhart & Sullivan, LLP for recovery of attorneys’ fees, costs and sanctions in connection with
their motion filed against Plaintiff and Wigdor LLP on December 16, 2022 (Dkt. No. 10, Mtn.
Seq. No. 1).
1 of 2
FILED: NEW YORK COUNTY CLERK 12/28/2022 09:14 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 12/28/2022
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR 2215, answering affidavits,
if any, and any other papers in opposition to the above-noticed cross-motion if any, shall be served
by January 3, 2023.
Dated: December 28, 2022 Respectfully submitted,
New York, New York
WIGDOR LLP
By: _____________________________
Jeanne M. Christensen
Renan F. Varghese
85 Fifth Avenue
New York, NY 10003
Telephone: (212) 257-6800
Facsimile: (212) 257-6845
jchristensen@wigdorlaw.com
rvarghese@wigdorlaw.com
Counsel for Plaintiff
2 of 2
Document Filed Date
December 28, 2022
Case Filing Date
November 28, 2022
Category
Torts - Adult Survivors Act
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FILED: NEW YORK COUNTY CLERK 12/28/2022 09:14 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 12/28/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ------------------------------------------------------------------------ X CHERI PIERSON, : : Index No.: 952002/2022 Plaintiff, : : Hon. Suzanne Adams v. : : Motion Seq. No. 001 LEON BLACK, ESTATE OF JEFFREY E. EPSTEIN, : DARREN K. INDYKE, in his capacity as the EXECUTOR : FOR THE ESTATE OF JEFFREY E. EPSTEIN and : ADMINISTRATOR OF THE 1953 TRUST; : RICHARD D. KAHN, in his capacity as the EXECUTOR : FOR THE ESTATE OF JEFFREY E. EPSTEIN and : ADMINISTRATOR OF THE 1953 TRUST; and THE : 1953 TRUST, : : Defendant. : ----------------------------------------------------------------------- X NOTICE OF CROSS-MOTION FOR SANCTIONS PLEASE TAKE NOTICE, that upon the accompanying Memorandum of Law, dated December 28, 2022, the annexed Affirmation of Jeanne M. Christensen, dated December 28, 2022, and the exhibits attached thereto, and all the pleadings and proceedings had heretofore herein, in accordance with CPLR 2214 and 2215, Plaintiff Cheri Pierson will cross-move this Court in the Motion Submission Part 39 Courtroom, Room 623 at the Supreme Court of the State of New York, New York County, located at 111 Centre Street, New York, New York 10013, on January 4, 2023 at 9:30 a.m. or as soon thereafter as counsel can be heard, for an Order pursuant to 22 NYCRR § 130.1-1 against Defendant Leon Black and his counsel, Perry Guha LLP and Quinn Emanuel Urquhart & Sullivan, LLP for recovery of attorneys’ fees, costs and sanctions in connection with their motion filed against Plaintiff and Wigdor LLP on December 16, 2022 (Dkt. No. 10, Mtn. Seq. No. 1). 1 of 2 FILED: NEW YORK COUNTY CLERK 12/28/2022 09:14 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 12/28/2022 PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR 2215, answering affidavits, if any, and any other papers in opposition to the above-noticed cross-motion if any, shall be served by January 3, 2023. Dated: December 28, 2022 Respectfully submitted, New York, New York WIGDOR LLP By: _____________________________ Jeanne M. Christensen Renan F. Varghese 85 Fifth Avenue New York, NY 10003 Telephone: (212) 257-6800 Facsimile: (212) 257-6845 jchristensen@wigdorlaw.com rvarghese@wigdorlaw.com Counsel for Plaintiff 2 of 2