Case 1:17-cv-00616-JGK Document 43 Filed 05/22/17 Page 1 of 2 Michael C. Miller VIA ECF Hon. John G. Koeltl Re: May 22, 2017 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Steptoe STEPTOE i JOHNSON LIP Dear Judge Koeltl: We are counsel to defendants Jeffrey Epstein and in the above-referenced matter. We write in response to Plaintiffs May 19, 201 letter to the Court, in which Plaintiff contends that discovery should proceed now, i.e., before the Plaintiff files her amended complaint and the Court resolves the inevitable motions to dismiss. We respectfully submit that, for the reasons set forth below, the Court should stay discovery pending the resolution of Defendants' motions to dismiss the Plaintiff's amended complaint. We are advised that Defendant oins in this request. Plaintiff's counsel recently advised us that Plaintiff is likely to file an amended complaint and will do on or before June 5, 2017. Plaintiff arrived at this conclusion after receiving letters n Ma 1 2017 from this firm (on behalf of Defendants Epstein and and counsel for which outlined the many deficiencies in the current complaint that warrant its dismissal ("May 15 Letters"). Pursuant to this Court's May 15, 2017 Stipulation and Order, Defendants will have until June 19, 2017 to move to dismiss the Plaintiff's amended complaint, and briefing will be completed by August 2, 2017. We respectfully submit that discovery should be stayed until the Court resolves the inevitable motions to dismiss the amended complaint, for the following reasons: First, and in any event, the Plaintiff has not yet served her amended complaint. It is not possible to properly assess the propriety of any discovery propounded by the Plaintiff until her amended complaint has been served on and reviewed by the Defendants. Rogen v. Scheer, 1991 EFTA00285470