Case 1:19-cv-08673-KPF-DCF Document 80 KAPLAN HECKER & FINK LLP Filed 06/22/20 350 FIFTH AVENUE Page 1 of 11 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 22, 2020 VIA ECF Hon. Juliaa 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: On behalf of Plaintiff Jane Doe in the above-referenced action, we write in response to Defendants' letter dated June 18, 2020 (Doc No. 74 (the "June 18 Letter")) requesting a conference concerning Defendants' anticipated motion to compel. As an initial matter, Defendants' purported request for a conference is, in reality, a tenpage brief which advances in great detail their legal arguments on each issue in their anticipated motion to compel. Accordingly, Plaintiff sees no reason that the Court should order an extended five-week briefing schedule, which would only serve to cause further delay. Plaintiff provides her opposition to Defendants' anticipated motion below. These papers, together with this week's telephonic conference, should provide a more than adequate opportunity for the parties to make their arguments. To date, Defendants' approach to discovery in this case has been transparently calculated to impose unreasonable burdens on Plaintiff and to delay adjudication on the merits. (See, e.g., Doc No. 71.) Defendants' discovery requests are no different. As their June 18 Letter lays bare, Defendants' discovery requests are strikingly unreasonable: they include, for example, a demand for all communications in the custody of Plaintiff's counsel concerning Jeffrey Epstein and this litigation, even though such communications are obviously overwhelmingly privileged or irrelevant, as well as a demand for records and information about every medical procedure and condition that Plaintiff has ever had, des