On November 28, 2022 a
Exhibit,Appendix
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 01/06/2023 07:10 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 65 RECEIVED NYSCEF: 01/06/2023
EXHIBIT 4
FILED: NEW YORK COUNTY CLERK 01/06/2023 07:10 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 65 RECEIVED NYSCEF: 01/06/2023
Jeanne M. Christensen
jchristensen@wigdorlaw.com
October 25, 2021
VIA EMAIL
E. Danya Perry, Esq.
Perry Guha LLP
35 E. 62nd Street
New York, New York 10065
Re: Ganieva v. Black; Index No. 155262/2021
Dear Danya:
We write in connection with the dilatory tactics by Black concerning discovery. Clearly this conduct
is intentional. On September 22, 2021, after numerous requests by Black, the Court agreed to a
conference. During that conference, several times, you represented to the Court that you would not
produce critical evidence in this matter absent an order of confidentiality. In response, I represented
to the Court, several times, that we would not agree to a confidentiality order.1 We discussed specific
items, including, inter alia, the audio files Black claims he has, as well as the “agreement.” Based
on this, the Court said in sum and substance that he expects “another motion” on his desk. Rather
than timely filing your motion, as of today, nothing has been filed. Contrary to the multitude of
representations you made to the Court about the “urgency” of discovery, Black is doing nothing.
Because of this, any claim by Black that our client is not in compliance with agreed upon internal
dates for discovery, outside of a Court order, is meritless. We agreed to dates believing that Black
would actually be producing discovery. As your responses on October 18, 2021 make obvious,
the last thing Black intends to do is produce relevant information.
Sincerely,
Jeanne M. Christensen
1
Our objection was detailed to you in correspondence dated September 23, 2021.
Document Filed Date
January 06, 2023
Case Filing Date
November 28, 2022
Category
Torts - Adult Survivors Act
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FILED: NEW YORK COUNTY CLERK 01/06/2023 07:10 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 65 RECEIVED NYSCEF: 01/06/2023 EXHIBIT 4 FILED: NEW YORK COUNTY CLERK 01/06/2023 07:10 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 65 RECEIVED NYSCEF: 01/06/2023 Jeanne M. Christensen jchristensen@wigdorlaw.com October 25, 2021 VIA EMAIL E. Danya Perry, Esq. Perry Guha LLP 35 E. 62nd Street New York, New York 10065 Re: Ganieva v. Black; Index No. 155262/2021 Dear Danya: We write in connection with the dilatory tactics by Black concerning discovery. Clearly this conduct is intentional. On September 22, 2021, after numerous requests by Black, the Court agreed to a conference. During that conference, several times, you represented to the Court that you would not produce critical evidence in this matter absent an order of confidentiality. In response, I represented to the Court, several times, that we would not agree to a confidentiality order.1 We discussed specific items, including, inter alia, the audio files Black claims he has, as well as the “agreement.” Based on this, the Court said in sum and substance that he expects “another motion” on his desk. Rather than timely filing your motion, as of today, nothing has been filed. Contrary to the multitude of representations you made to the Court about the “urgency” of discovery, Black is doing nothing. Because of this, any claim by Black that our client is not in compliance with agreed upon internal dates for discovery, outside of a Court order, is meritless. We agreed to dates believing that Black would actually be producing discovery. As your responses on October 18, 2021 make obvious, the last thing Black intends to do is produce relevant information. Sincerely, Jeanne M. Christensen 1 Our objection was detailed to you in correspondence dated September 23, 2021.