Case 1:19-cv-11869-MKV-DCF Document 16 Filed 02/06/20 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X ANASTASIA DOE, Plaintiff, : v. Index No. 1:19-cv-11869-MKV-DCF DARREN K. INDYKE AND RICHARD D. KAHN, AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, Defendants. X JOINT PROPOSED DISCOVERY SCHEDULE Pursuant to the Court's Order dated January 14, 2020 and Rule 26(0(3) of the Federal Rule of Civil Procedure, Plaintiff Anastasia Doe and Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors" and together with Plaintiff, the "Parties") hereby jointly submit the following proposed discovery schedule: I. The Parties shall serve their initial disclosures pursuant to Rule 26(a)(1) no later than February 7, 2020; 2. Plaintiff shall provide HIPAA-compliant medical records release authorizations to the Co-Executors no later than 14 days from the request therefor, 3. The Parties shall serve initial document requests and interrogatories no later than 30 days from the Court's entry of the discovery schedule; 4. Any motion for joinder of other parties or amendment of the pleadings shall be made no later than 45 days from the Court's entry of the discovery schedule; 5. Fact discovery shall be completed no later than 140 days from the Court's entry of the discovery schedule; 6. Expert disclosures and expert discovery shall be completed no later than 200 days from the Court's entry of the discovery schedule; and 1 41356859v1 EFTA02751760