Case 1:19-cv-10479-ALC-DCF Document 27 Filed 05/07/20 Page 1 of 6 BSF' BOIES SCHILLER FLEXNER Sigrid S. McCawley Telephone: (954) 377-4223 Email: [email protected] May 7, 2020 VIA ECF The Honorable Debra Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: v. Darren K. Indyke & Richard D. Kahn, 19-10479-ALC-DCF Dear Judge Freeman: We write on behalf of Plaintiff in the above-captioned litigation. Pursuant to Individual Rule II.A and Local Civil Rule 37.2, Plaintiff respectfully requests a pre-motion conference on Plaintiff's anticipated motion to compel Defendants Darren K. Indyke and Richard D. Kahn (I) to produce responsive documents from the Relevant Period as defined in Plaintiff's discovery requests; (2) to produce documents responsive to Plaintiff's requests, not simply documents that directly mention Plaintiff's name; and (3) to respond to Plaintiff's interrogatories.' The Court has made clear that discovery in this case would not be stayed pending the approval of the claims administration program or a motion to dismiss absent a contrary order from the Court. See Tr. of Nov. 21, 2019 Conf. at 26:10-12. Yet by failing to comply with their clear and unequivocal discovery obligations, including not producing a single document to date, Defendants are attempting to grant themselves a defacto stay of discovery. Defendants have provided no basis for their delay. I. Background Plaintiff alleges that Jeffrey Epstein and his co-conspirators operated a decades-long sex-trafficking scheme by which they recruited young women for sexual abuse. Comp1.11 27, 28. Plaintiff was one of those women. Epstein and his associates trafficked her from South Africa in 2002 and sexually abused her for several years thereafter in New York, Florida, the U.S. Virgin Islands, New Mexico, and France. Id. 11 41, 55. After years of suffering in silence due to fear and Epstein's psychological manipulation, she filed a complaint against Defendants