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

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                                FILED: NEW YORK COUNTY CLERK 02/01/2023 04:28 PM                                                   INDEX NO. 952002/2022
NYSCEF DOC. NO. 76                                                                         RECEIVED NYSCEF: 02/01/2023




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

          Cheri Pierson,
                                          Plaintiff,                     Index No. 952002/2022

                 vs.                                                    Hon. Suzanne J. Adams

          Leon Black; Estate of Jeffrey E. Epstein; Darren K.           (Motion Seq. 005)
          Indyke, in his capacity as the Executor for the Estate
          of Jeffrey E. Epstein and Administrator of The 1953           AFFIRMATION OF
          Trust; Richard D. Kahn, in his capacity as the                BENNET J. MOSKOWITZ
          Executor for the Estate of Jeffrey E. Epstein and
          Administrator of The 1953 Trust; and The 1953
          Trust,

                                          Defendants.



                 BENNET J. MOSKOWITZ, an attorney duly admitted to practice before the Courts of

          the State of New York, hereby affirms the following under penalty of perjury:

                 1.        I am a Partner at Troutman Pepper Hamilton Sanders LLP, counsel for Defendants

          Estate of Jeffrey E. Epstein, Darren K. Indyke, in his capacity as Co-Executor for the Estate and

          Co-Administrator of The 1953 Trust, Richard D. Kahn, in his capacity as Co-Executor for the

          Estate and Co-Administrator of The 1953 Trust, and The 1953 Trust (together, the “Epstein

          Defendants”).

                 2.        I submit this Affirmation solely to present to the Court certain materials cited in the

          Epstein Defendants’ Motion to Dismiss Plaintiff’s Fifth Cause of Action (Motion Seq. 004), which

          materials are attached hereto as described below.

                 3.        Attached hereto as Exhibit 1 is a copy of Plaintiff’s Complaint filed on November

          28, 2022 (NYSCEF Doc. No. 1).




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FILED: NEW YORK COUNTY CLERK 02/01/2023 04:28 PM                            INDEX NO. 952002/2022
NYSCEF DOC. NO. 76                                                   RECEIVED NYSCEF: 02/01/2023




          Dated: New York, New York     TROUTMAN PEPPER HAMILTON
                 February 1, 2023       SANDERS LLP

                                        By: /s/ Bennet J. Moskowitz
                                           Bennet J. Moskowitz
                                           875 Third Avenue
                                           New York, NY 10022
                                           (212) 704-6000
                                            bennet.moskowitz@troutman.com


                                        Attorneys for Defendants 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




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FILED: NEW YORK COUNTY CLERK 02/01/2023 04:28 PM                                               INDEX NO. 952002/2022
NYSCEF DOC. NO. 76                                                                      RECEIVED NYSCEF: 02/01/2023




                                     CERTIFICATION OF WORD COUNT

                 I hereby certify that the foregoing affirmation complies with the word count limits set forth

          in Rule 202.8-b(b) of the Uniform Civil Rules for the Supreme Court and the County Court (22

          NYCRR § 202.8-b(b)). This affirmation contains 145 words, excluding parts of the document

          exempted by Rule 202.8-b (22 NYCRR § 202.8-b(b)). In preparing this certification, I have relied

          on the word count of the word-processing system used to prepare this affirmation.

           Dated: New York, New York
                  February 1, 2023

                                                          By: /s/ Bennet J. Moskowitz
                                                              Bennet J. Moskowitz




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