Case 1:19-cv-10479-ALC-DCF Document 35 Filed 05/14/20 Page 1 of 4 BSF BOIES SCHILLER FLEXNER Sigrid S. McCawley Telephone: (954) 377-4223 Email: [email protected] May 14, 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 submit on behalf of Plaintiff this reply in further support of her letter motion for a conference to address Defendants' failure to comply with their discovery obligations (ECF No. 27), and in response to Defendants' second letter in opposition, filed on May 13, 2020 (ECF No. 34). As an initial matter, the Court should disregard Defendants' latest response as untimely. Pursuant to Individual Rule 1.D., "[u]nless the Court orders otherwise, opposition to any letter motion shall be filed within three (3) days of the moving letter." Notwithstanding this rule, Defendants filed an incomplete and non-substantive opposition on May 8, and requested "permission to submit a response to the substantive issues raised in the Letters by May 13, 2020." ECF No. 28. Defendants' letter did not comply with Individual Rule 1.B., which governs "requests for adjournments or extensions of time." In any event, the Court did not issue an order extending Defendants' time to respond, much less grant Defendants leave to file two oppositions as opposed to one. But even if the Court were to consider Defendants' untimely filing, each of their arguments is meritless, and confirms the need for immediate Court intervention to resolve the parties' disputes. First, Defendants refuse to engage in discovery for more than a narrow, two-year period (2002-2004). This is improper, as information concerning Epstein's abuse ofother girls and young women throughout the span of his sex-trafficking conspiracy is plainly relevant, and therefore discoverable under Rule 26. Defendants deride Plaintiff's allegations as a "sex trafficking sch