Case 1:19-cv-08673-KPF-DCF Document 79 Troutman Sanders LLP 875 Third Avenue New York, New York 10022 troutman.com Filed 06/22/20 Page 1 of 10 troutmar? sanders Bennet J. Moskowitz D: 212-704-6000 [email protected] June 22, 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) (DCFI 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 calculationsiimulas used in arriving at , 469 F.3d 284, 295 (2d the damages claimed. See, e.g., Design Strategy, Inc. v. 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 Co-Executors; 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. EFTA02751514