Case 1:20-cv-00484-JGK-DCF Troutman Pepper Sanders LLP 875 Third Avenue New York, New York 10022 Document 56 Filed 07/16/20 Page 1 of 2 troutman 1 pepper troutman.com Mary W. Metcalfe [email protected] July 16, 2020 VIA ECF The Honorable Debra C. Freeman United States District Court Southern rict of New York Daniel Moynihan Courthouse 500 Pearl Street New York, NY 10007 Re: Jane Doe v. Darren K. lndyke and Richard D. Kahn, in their capacities as executors of the Estate of Jefferey E. Epstein, and Ghislaine Maxwell, No. 1:20-cv-00484-JGK-DCF Dear Judge Freeman: We represent Defendants Darren K. lndyke and Richard D. Kahn, as Co-Executors of the Estate of Jefferey E. Epstein (the "Co-Executors") in the above-referenced action. We write in response to the letter counsel for Plaintiff Jane Doe, Robert Glassman, filed yesterday afternoon (Doc. 54). Mr. Glassman's letter is, as counsel for Ms. Maxwell stated in an email yesterday, "very premature." It also misrepresents what occurred. As evidenced by the email chain submitted herewith as Exhibit A, last Friday, July 10, 2020, counsel for Co-Defendant Ghislaine Maxwell, who had only appeared in this action a day earlier, asked the parties to meet and confer, among other things, to set new dates for Mr. Indyke's deposition and all other discovery dates and deadlines set before her appearance. Moreover, and as we promptly advised Mr. Glassman, shortly after we agreed to commence our rolling document production earlier this week, we realized that the Parties have yet to agree upon a confidentiality order, which must occur before we produce documents that refer to the Plaintiff, who filed this case anonymously, by her real name. That is for Plaintiff's benefit. The terms of the confidentiality order will also be discussed during the Parties' upcoming meet and confer call. As indicated in the attached email chain, rather than discuss the confidentiality order or advise us that he thought we were mistaken