On November 28, 2022 a
Motion,Ex Parte
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.
Preview
FILED: NEW YORK COUNTY CLERK 01/03/2023 02:12 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 01/03/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
CHERI PIERSON,
Plaintiff,
Index No. 952002/2022
v.
IAS Part 21 (Adams, J.)
LEON BLACK, ESTATE OF JEFFREY E. EPSTEIN,
DARREN K. INDYKE, in his capacity as the EXECUTOR STIPULATION
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,
Defendants.
WHEREAS, on November 28, 2022, plaintiff Cheri Pierson (“Plaintiff”) commenced this
action by filing a Summons and Complaint;
WHEREAS, on December 16, 2022, defendant Leon Black (“Defendant”) filed his Motion
for Sanctions, pursuant to 22 NYCRR §130-1.1 (the “Motion for Sanctions”) with a return date of
January 4, 2023;
WHEREAS, on December 28, 2022 Plaintiff filed a Cross-Motion for Sanctions with a
return date of January 4, 2023.
NOW THEREFORE, the parties hereby stipulate and agree that:
1. The return date for Defendant’s Motion for Sanctions is extended until Tuesday,
January 10, 2023, in the Motions Submissions Part, Room 130;
2. The deadline for Defendant’s Reply in support of his Motion for Sanctions is
extended until Friday, January 6, 2023;
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1 of 2
FILED: NEW YORK COUNTY CLERK 01/03/2023 02:12 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 01/03/2023
3. The return date for Plaintiff’s Cross-Motion for Sanctions is extended until
Tuesday, January 10, 2023, in the Motions Submissions Part, Room 130;
4. The deadline for Defendant’s Opposition to Plaintiff’s Cross-Motion for Sanctions
is extended until Friday, January 6, 2023;
5. The deadline for Plaintiff’s Reply in support of her Cross-Motion for Sanctions is
extended until Monday, January 9, 2023; and
6. No previous requests have been made for the relief sought herein.
Dated: January 3, 2023 Respectfully submitted,
New York, New York
By:_________________________________ By:_________________________________
Jeanne M. Christensen Michael B. Carlinsky
Renan F. Varghese Jennifer J. Barrett
WIGDOR LLP QUINN EMANUEL URQUHART
85 Fifth Avenue & SULLIVAN, LLP
New York, New York 10003 51 Madison Avenue, 22nd Floor
(212) 257-6800 New York, NY 10010
jchristensen@wigdorlaw.com (212) 849-7000
rvarghese@wigdorlaw.com michaelcarlinsky@quinnemanuel.com
jenniferbarrett@quinnemanuel.com
Attorneys for Plaintiff Cheri Pierson
E. Danya Perry
PERRY GUHA LLP 1740 Broadway, 15th
Floor New York, New York 10019
(212) 399-8330
dperry@perryguha.com
Susan Estrich (pro hac vice pending)
ESTRICH GOLDIN LLP
8605 Santa Monica Blvd, Suite 92780
West Hollywood, CA 90069
(212) 399-2132
susan@estrichgoldin.com
Attorneys for Defendant Leon Black
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2 of 2
Document Filed Date
January 03, 2023
Case Filing Date
November 28, 2022
Category
Torts - Adult Survivors Act
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FILED: NEW YORK COUNTY CLERK 01/03/2023 02:12 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 01/03/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK CHERI PIERSON, Plaintiff, Index No. 952002/2022 v. IAS Part 21 (Adams, J.) LEON BLACK, ESTATE OF JEFFREY E. EPSTEIN, DARREN K. INDYKE, in his capacity as the EXECUTOR STIPULATION 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, Defendants. WHEREAS, on November 28, 2022, plaintiff Cheri Pierson (“Plaintiff”) commenced this action by filing a Summons and Complaint; WHEREAS, on December 16, 2022, defendant Leon Black (“Defendant”) filed his Motion for Sanctions, pursuant to 22 NYCRR §130-1.1 (the “Motion for Sanctions”) with a return date of January 4, 2023; WHEREAS, on December 28, 2022 Plaintiff filed a Cross-Motion for Sanctions with a return date of January 4, 2023. NOW THEREFORE, the parties hereby stipulate and agree that: 1. The return date for Defendant’s Motion for Sanctions is extended until Tuesday, January 10, 2023, in the Motions Submissions Part, Room 130; 2. The deadline for Defendant’s Reply in support of his Motion for Sanctions is extended until Friday, January 6, 2023; 1 1 of 2 FILED: NEW YORK COUNTY CLERK 01/03/2023 02:12 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 01/03/2023 3. The return date for Plaintiff’s Cross-Motion for Sanctions is extended until Tuesday, January 10, 2023, in the Motions Submissions Part, Room 130; 4. The deadline for Defendant’s Opposition to Plaintiff’s Cross-Motion for Sanctions is extended until Friday, January 6, 2023; 5. The deadline for Plaintiff’s Reply in support of her Cross-Motion for Sanctions is extended until Monday, January 9, 2023; and 6. No previous requests have been made for the relief sought herein. Dated: January 3, 2023 Respectfully submitted, New York, New York By:_________________________________ By:_________________________________ Jeanne M. Christensen Michael B. Carlinsky Renan F. Varghese Jennifer J. Barrett WIGDOR LLP QUINN EMANUEL URQUHART 85 Fifth Avenue & SULLIVAN, LLP New York, New York 10003 51 Madison Avenue, 22nd Floor (212) 257-6800 New York, NY 10010 jchristensen@wigdorlaw.com (212) 849-7000 rvarghese@wigdorlaw.com michaelcarlinsky@quinnemanuel.com jenniferbarrett@quinnemanuel.com Attorneys for Plaintiff Cheri Pierson E. Danya Perry PERRY GUHA LLP 1740 Broadway, 15th Floor New York, New York 10019 (212) 399-8330 dperry@perryguha.com Susan Estrich (pro hac vice pending) ESTRICH GOLDIN LLP 8605 Santa Monica Blvd, Suite 92780 West Hollywood, CA 90069 (212) 399-2132 susan@estrichgoldin.com Attorneys for Defendant Leon Black 2 2 of 2