Case 1:19-cv-08673-KPF-DCF Document 74 Filed 06/18/20 Page 1 of 10 Troutman Sanders LLP 875 Third Avenue New York, New York 10022 troutman.com troutmar? sanders Bennet J. Moskowitz D: 212-704-6000 [email protected] June 18,2020 VIA ELECTRONIC COURT FILING Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl Street New York, New York 10007 Re: Jane Doe, 1:19-cv-8673 (KPF) (DCF) Dear Judge Freeman: We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"), in the above-referenced action. We write pursuant to Your Honor's Individual Rule 2(A) and Local Rule 37.2 to request a conference in anticipation of filing a motion to compel Plaintiff to produce the following documents and information: 1. in accordance with Fed. R. Civ. P. 26(a)(1)(A)(iii) and the Co-Executors' interrogatories, a computation of the damages she seeks to recover in this action supported by documents, including an analysis supplying the underlying calculations ir fi nulas used in arriving at the damages claimed. See, e.g., Design Strategy, Inc. v. , 469 F.3d 284, 295 (2d Cir. 2006) (quoting Rule 26); 2. communications concerning Jeffrey Epstein ("Decedent" or "Mr. Epstein") which are to, from, or copy members of the press, media, or publishing industry; 3. documents concerning Mr. Epstein which are to, from, or copy other plaintiffs (or their attorneys) who have asserted claims against Mr. Epstein, his Estate, or the CoExecutors; 4. documents concerning all medical procedures and consultations Plaintiff received during the relevant time period, and not just those which Plaintiff deems relevant to her claims; and 5. documents concerning specific medical procedures and conditions, regardless of timeframe, and not just those which Plaintiff deems relevant to her claims. EFTA02751354