Motion-Secondary: Cheri Pierson v. 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, The 1953 Trust

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                FILED:         NEW     YORK       COUNTY        CLERK        01/06/2023             07:10        PM                 INDEX    NO.   952002/2022
   NYSCEF     DOC.   NO.   60                                                                                 RECEIVED      NYSCEF:     01/06/2023




                    SUPREME COURT OF THE STATE OF NEW YORK
                    COUNTY OF NEW YORK


                   CHERI PIERSON,                                                            Index No. 952002/2022
                                              Plaintiff,

                                     v.                                                      Mot. Seq. No. 1

                   LEON BLACK, ESTATE OF JEFFREY E. EPSTEIN,                                 AFFIRMATION OF MICHAEL
                   DARREN K. INDYKE, in his capacity as the EXECUTOR                         B. CARLINSKY IN FURTHER
                   FOR THE ESTATE OF JEFFREY E. EPSTEIN and                                  SUPPORT OF DEFENDANT’S
                   ADMINISTRATOR OF THE 1953 TRUST;                                          MOTION FOR SANCTIONS
                   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.



                           MICHAEL        B.  CARLINSKY,         an attorney duly admitted to practice in          the courts of the

                  State of New York, and not a party in the above-captioned action, hereby affirms under penalty of

                  perjury, pursuant to CPLR 2106, that the following is true and correct:

                                    1.       I am a partner in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

                  counsel for Defendant Leon Black.            I respectfully submit this Affirmation in          further support of

                  Defendant’s Motion for Sanctions.           I am fully familiar with the       facts and circumstances recited

                  herein.

                                    2.       A  true  and correct copy of       Black’s   July  19,  2021 letter to    Wigdor     LLP

                  (“Wigdor”) is attached hereto as Exhibit 1.

                                    3.       A  true  and correct copy of       Wigdor’s    August 13,     2021 letter to    Black   is

                  attached hereto as Exhibit 2.




                                                                            1


                                                                        1  of   3
   FILED:         NEW     YORK       COUNTY        CLERK        01/06/2023             07:10        PM                 INDEX    NO.   952002/2022
   NYSCEF     DOC.   NO.   60                                                                                 RECEIVED      NYSCEF:     01/06/2023




                                    4.       A  true and correct copy of Black’s September 8, 2021 letter to Wigdor                  is

                  attached hereto as Exhibit 3.

                                    5.       A  true  and correct copy of Wigdor’s October 25, 2021 letter to                Black is

                  attached hereto as Exhibit 4.

                                    I affirm under penalty of perjury that the foregoing is true and correct.

                  Dated: New York, New York
                           January 6, 2023
                                                                                 /s/ Michael B. Carlinsky_______________
                                                                                 Michael B. Carlinsky




                                                                            2


                                                                        2  of   3
   FILED:         NEW     YORK       COUNTY        CLERK        01/06/2023             07:10        PM                 INDEX    NO.   952002/2022
   NYSCEF     DOC.   NO.   60                                                                                 RECEIVED      NYSCEF:     01/06/2023




                                 ATTORNEY CERTIFICATION PURSUANT TO 22 NYCRR 202.8

                           I, Michael B. Carlinsky, an attorney duly admitted to practice law before the courts of the

                  State of New York, hereby certifies that this affirmation in further support of Defendant’s Motion

                  for Sanctions complies with         the  word   count limit    set  forth in  22  NYCRR       202.8 -b because it

                  contains 183 words, excluding the parts of the            affidavit exempted by the rule. In preparing this

                  certification, I have relied on the word count of the word-processing system used to prepare this

                  memorandum of law.



                  Dated: January 6, 2023
                           New York, New York

                                                                                 /s/ Michael B. Carlinsky
                                                                                 Michael B. Carlinsky




                                                                            3


                                                                        3  of   3