Motion Seq. 003
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
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`-------------------------------------------------------------------X Case No.: 1:25-cv-1265
`JENNIFER AN,
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` Plaintiff
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`-against-
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`KANYE WEST a/k/a YE, individually,
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` Defendant.
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`AFFIRMATION OF
`JESSE S. WEINSTEIN, ESQ.
`IN SUPPORT OF PLAINTIFF’S
`OPPOSITION TO DISMISS
`PLAINTIFF’S SECOND
`AMENDED COMPLAINT
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`-------------------------------------------------------------------X
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`JESSE S. WEINSTEIN , ESQ ., an attorney duly admitted to practice before this Court ,
`hereby affirms the following to be true under penalty of perjury:
`1. I am an attorney with Arcé Law Group, P.C., counsel of record for Plaintiff Jenifer An in the
`above-captioned action. I am fully familiar with the facts and circumstances of this case
`through my legal representation of Plaintiff.
`2. I submit this Affirmation in opposition to Defendant Kanye West a/k/a Ye’s (“West”) Motion
`to Dismiss Plaintiff’s Second Amended Complaint pursuant to CPLR 3211(a)(7) and (g), and
`Civil Rights Law §§ 70 -a and 76 -a (Motion Seq. 003), and specifically to authenticate and
`introduce into the record the exhibits attached hereto.
`3. Attached as Exhibit A is a true and correct copy of a sworn affidavit, executed under penalty
`of perjury, from Liz Martins, Eleanor Jackson’s (“La Roux”) make-up artist who was present
`on set during the filming of the “In for the Kill” music video, and personally witnessed
`Defendant West’s conduct toward Plaintiff.
`4. Attached as Exhibit B is a true and correct copy of an excerpt from a confidential investigative
`report prepared by Beau Dietl & Associates, dated October 18, 2024, summarizing its
`interview with “In for the Kill” music video Director, Geremy Jasper.
`FILED: NEW YORK COUNTY CLERK 03/10/2026 07:01 PM INDEX NO. 152284/2025
`NYSCEF DOC. NO. 63 RECEIVED NYSCEF: 03/10/2026
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`5. Attached as Exhibit C is a true and correct copy of an excerpt from a confidential investigative
`report prepared by Beau Dietl & Associates, dated October 18, 2024, summarizing its
`interview with “In for the Kill” music video First Assistant Director, John Mintz.
`6. Attached as Exhibit D is a true and correct copy of a sworn affidavit, executed under penalty
`of perjury, from Michelle An, the current President of Creative Strategy at Interscope , a
`division of UMG Recordings, Inc. Ms. An, a Production Manager at the time, was present on
`set during the filming of the “In for the Kill” music video, and personally witnessed Defendant
`West’s conduct.
`7. Attached as Exhibit E are Instagram messages between Ms. Jackson and Plaintiff, where Ms.
`Jackson and Plaintiff discuss Defendant West’s conduct toward Plaintiff on set during the
`filming of the “In for the Kill” music video.
`8. Exhibits A through E are offered to demonstrate that Plaintiff’s Second Amended Complaint
`is supported by a substantial basis in law, as required under CPLR 3211(g), and to corroborate
`the factual allegations set forth therein.
`9. For the reasons set forth in Plaintiff ’s accompanying Memorandum of Law in Opposition,
`Plaintiff respectfully requests that this Court deny Defendant ’s Motion to Dismiss in its
`entirety and grant Plaintiff such other and further relief as the Court deems just and proper.
`10. I affirm the foregoing under penalty of perjury pursuant to CPLR § 2106.
`Dated: New York, New York
`March 10, 2026
` Respectfully submitted,
`Arcé Law Group, P.C.
`
`/s/_Jesse S. Weinstein____
`Jesse S. Weinstein, Esq.
`Attorneys for Plaintiff
`45 Broadway, Suite 2810
`New York, New York 10006
`T: (212) 248-0120
`FILED: NEW YORK COUNTY CLERK 03/10/2026 07:01 PM INDEX NO. 152284/2025
`NYSCEF DOC. NO. 63 RECEIVED NYSCEF: 03/10/2026
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