Case 1:19-cv-08673-KPF-DCF Document 82 Troutman Sanders LLP 875 Third Avenue New York, New York 10022 troutman.com Filed 06/24/20 Page 1 of 4 troutmar? sanders Bennet J. Moskowitz D: 212-704-6000 [email protected] June 24, 2020 VIA ELECTRONIC COURT FILING Hon. D 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 matter. We write in reply to Plaintiffs letter filed June 23, 2020 [ECF 80) in response to the Co-Executors' pre-motion letter [ECF 79]. Plaintiff repeats two false premises throughout her June 23 letter: (i) the Co-Executors failed to articulate reasons why the information they seek is relevant, and (ii) it "goes without saying" that the Co-Executors' Requests are "highly burdensome." These arguments are unsupported and incorrect for at least two key reasons. First, the parties have had numerous conversations in which the Co-Executors have explained the relevance of the material sought, including, for example, to the extent the materials include discussions among various plaintiffs' counsel or with the press regarding an alleged "trafficking scheme" or the relative strengths of claims asserted by numerous individuals against the Estate. Although Plaintiff's counsel may not wish the Co-Executors to see such communications, that is not a valid basis to withhold them. Second, Plaintiff never articulates why a search for the documents at issue is "highly burdensome." Absent a showing of undue burden or a legitimate privilege, Plaintiff is required to produce the materials. Given the importance of the discovery at issue, the Co-Executors request that the Court either compel Plaintiff to produce the subject documents or permit the parties to more fully brief these issues followed b