📧 Communication

This document is a Plaintiff's Memorandum of Law opposing a Motion to Dismiss in the case of VE v. Indyke et al. The plaintiff, a victim of Jeffrey Epstein's sexual abuse beginning in 2001 at age 16, argues that the corporate defendants (Nine East 71st Street Corp, Financial Trust Company, and NES LLC) are liable for negligence, negligent security, and negligent supervision. The memorandum asserts these entities were integral to Epstein's sex trafficking enterprise, with employees facilitating the recruitment and scheduling of victims, and argues that claims are valid under the New York Child Victims Act.