Case 1:19-cv-08673-KPF-DCF Troutman Sanders LLP 875 Third Avenue New York, New York 10022 troutman.com Document 43 Filed 01/13/20 Page 1 of 3 troutmaril sanders Bennet J. Moskowitz bennet.moskowitz©troutman.com January 13, 2020 ECF Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007 Re: Jane Doe v. Darren K. Indyke and Richard D. Kahn, in their capacities as the Executors of the Estate of Jeffrey E. Epstein, 1:19-cv-08673-KPF-DCF Dear Judge Freeman: We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the to -Executors"), in the above-referenced action. We write to correct several inaccuracies in Plaintiff Jane Doe's status report filed on Friday, January 10, 2020 (ECF Doc. 42). First, as we indicated to Your Honor on Friday, in a joint status report submitted on behalf of all parties in five other actions against the Estate,' we understand that the vast majority of the plaintiffs in these and other actions pending in this District will or are likely to participate in the Epstein Victims' Compensation Program (the "Program"). Although none is required to do so in order to participate in the Program, five plaintiffs have voluntarily stayed their actions pending their participation therein.2 Respective counsel for all have conferred extensively with the Program administrator and designers — Jordana , Kenneth Feinberg and Camille Biros — including in person, to consider the Program's design and to rovide specific input on the draft Program protocol circulated on December 13, 2019 by , Mr. Feinberg and Ms. Biros. As counsel for five plaintiffs wrote to Your Honor on Friday, "we agree with Defendants' assertion that our discussions with the designers and administrator of the ... Program have been positive and productive."3 ' See VE, 1:19-cv-07625-AJN-DCF (ECF No. 52). 2 See Jane Doe 1, et at, 1:19-cv-07675-GBD-DCF (ECF No. 36): Jane Doe 17, 1:19-cv-09610PAE-DCF