Case 1:19-cv-08673-KPF-DCF Document 67 KAPLAN HECKER & FINK LLP Filed 06/01/20 350 FIFTH AVENUE Page 1 of 2 SUITE 7110 NEW YORK, NEW YORK 10118 TEL (212) 763-0883 I FAX (212) 564-0883 WWW.KAPLANHECKER.COM DIRECT DIAL 212.763.0884 DIRECT EMAIL [email protected] June I, 2020 VIA ECF Hon. JudgeaF Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007 Re: Doe v. Indyke et at, No. 19-cv-8673-KPF (S.D.N.Y.) Dear Judge Freeman: We write on behalf of both parties in the above-referenced action pursuant to this Court's Order dated April 21, 2020 (Doc. No. 60) to update the Court as to the status of discovery and the progress of settlement discussions. Discovery. As the Court is aware, fact discovery in this matter began on January 21, 2020 (Doc. No. 48), and the parties exchanged their First Sets of Interrogatories and Requests for Production of Documents on March 10, 2020. Since that time, the parties have met and conferred repeatedly on the scope and timeline of discovery, including issues pertaining to specifically to electronically-stored information (ESI) discovery. The parties have made substantial progress on narrowing the areas of dispute between them and on agreeing to a process for searching and producing ESI. While some disputes remain, discussions between the parties are ongoing and, as a result, there are no issues that parties wish to raise with the Court at this time, though both parties reserves their rights to do so in future if necessary. Since the commencement of fact discovery, Plaintiff has made two productions of documents and is on track to substantially complete her production of documents by the week of June 8, 2020. Defendants have not yet produced any documents; however, they have represented to Plaintiff that they are working to remedy this and intend to begin production of documents this week. Settlement With respect to settlement, the parties have had no meaningful discussions since the last status c