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collectively, the "Sexual Abuse Claims"). To date, twelve lawsuits involving Sexual Abuse Claims have been filed in the state and federal courts of the State of New York, where claimants assert some of the complained-of conduct occurred, and which recently amended its statute of limitations to permit such claims. The
requested herein substantially in the form of the attached proposed order. Respectfully, Dated: November 14, 2019 CHRISTOPHER ALLEN KROBLIN, ESQ. ANDREW W. HEYMANN, ESQ. WILLIAM L. BLUM, ESQ. SHARI N. D'ANDRADE, ESQ. MARJORIE WHALEN, ESQ. V.I. Bar Nos. 966, 266, 136, 1221 & R2019 KELLERHALS FERGUSON KROBIAN
collectively, the "Sexual Abuse Claims"). To date, twelve lawsuits involving Sexual Abuse Claims have been filed in the state and federal courts of the State of New York, where claimants assert some of the complained-of conduct occurred, and which recently amended its statute of limitations to permit such claims. The
requested herein substantially in the form of the attached proposed order. Respectfully, Dated: November 14, 2019 CHRISTOPHER ALLEN KROBLIN, ESQ. ANDREW W. HEYMANN, ESQ. WILLIAM L. BLUM, ESQ. SHARI N. D'ANDRADE, ESQ. MARJORIE WHALEN, ESQ. V.I. Bar Nos. 966, 266, 136, 1221 & R2019 KELLERHALS FERGUSON KROBIAN
collectively, the "Sexual Abuse Claims"). To date, twelve lawsuits involving Sexual Abuse Claims have been filed in the state and federal courts of the State of New York, where claimants assert some of the complained-of conduct occurred, and which recently amended its statute of limitations to permit such claims. The
ia regular mail, postage prepaid, with a courtesy copy sent by email to counsel of record on January 23, 2020 to: CHRISTOPHER ALLEN KROBLIN, ESQ. ANDREW W. HEYMANN, ESQ., WILLIAM BLUM, ESQ. SHAR1 D'ANDRADE, ESQ. MARJORIE WHALEN, ESQ. KELLERHALS FERGUSON KROBLIN PLLC Royal Palm Professional Building 9053 Es
collectively, the "Sexual Abuse Claims"). To date, twelve lawsuits involving Sexual Abuse Claims have been filed in the state and federal courts of the State of New York, where claimants assert some of the complained-of conduct occurred, and which recently amended its statute of limitations to permit such claims. The
requested herein substantially in the form of the attached proposed order. Respectfully, Dated: November 14, 2019 CHRISTOPHER ALLEN KROBLIN, ESQ. ANDREW W. HEYMANN, ESQ. WILLIAM L. BLUM, ESQ. SHARI N. D'ANDRADE, ESQ. MARJORIE WHALEN, ESQ. V.I. Bar Nos. 966, 266, 136, 1221 & R2019 KELLERHALS FERGUSON KROBLIN
collectively, the "Sexual Abuse Claims"). To date, twelve lawsuits involving Sexual Abuse Claims have been filed in the state and federal courts of the State of New York, where claimants assert some of the complained-of conduct occurred, and which recently amended its statute of limitations to permit such claims. The
Page: EFTA00018905 →equested herein substantially in the form of the attached proposed order. Respectfully, Dated: November 14, 2019 CHRISTOPHER ALLEN )(ROBLIN, ESQ. ANDREW W. HEYMANN, ESQ. WILLIAM L. BLUM, ESQ. SHARI N. D'ANDRADE, ESQ. MARJORIE WHALEN, ESQ. V.I. Bar Nos. 966, 266, 136, 1221 & R2019 KELLERHALS FERGUSON KROBLIN
Page: EFTA00018916 →Entities connected to both the State of New York and ANDREW W. HEYMANN

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONDarren Indyke
PERSON
George W. Bush
PERSON
New York
LOCATION
U.S. Virgin Islands
LOCATIONJane Doe
PERSON
Financial Trust Company
ORGANIZATION
Joi Ito
PERSON
Prince Andrew
PERSON
Richard Kahn
PERSON
Virginia Giuffre
PERSONSouthern Trust Company
ORGANIZATIONSouthern District
LOCATIONMartin Weinberg
PERSON
Palm Beach
LOCATION
NEW YORK NY
LOCATION
Woody Allen
PERSON
Puerto Rico
LOCATION