Case 1:20-cv-00484-JGK-DCF Document 63 Filed 08/12/20 Page 1 of 2 PANISH SHEA & BOYLE ,, I August 12, 2020 VIA ECF Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 Re: Doe v. Indyke, et at, I:20-cv-000484-JGK-DCF Status Update Following 8/5/20 Scheduling Conference Dear Judge Freeman: We are writing on behalf of our client, plaintiff Jane Doe, in the above-referenced litigation and to update the Court on some discovery issues in our case following the August 5, 2020 scheduling conference. First, on August 5, 2020, this Court ordered defendant Ghislaine Maxwell to serve her initial disclosures no later than August 10, 2020. The Court's specific order was that: "/t is hereby ORDERED that: 1. Defendant Ghislaine Maxwell ("Maxwell") shall serve her initial disclosures no later than August 10, 2020." As of the time of submitting this letter, however, Ms. Maxwell has not served her initial disclosures on the parties. Moreover, Ms. Maxwell has not sought any relief from the Court to excuse her of complying with the order of the Court. Accordingly, as it stands, Ms. Maxwell has violated the Court's order. Second, it has now been over 4 months since Plaintiff served the Epstein Estate with document requests and she has still failed to receive a single substantive response nor a single page of evidence from the Epstein Estate to date. Indeed, even after providing counsel for the Epstein Estate with her proposed edits to their draft confidentiality order and non-disclosure agreement they have insisted all Epstein victims sign before producing any information to them, Plaintiff received no response and no documents have been released. And third, despite Plaintiff's multiple attempts at getting available deposition dates for defendant Richard Kahn, the co-executor of the Epstein Estate, his attorneys simply just refuse to provide them. Instead, they are insisting that Plaintiffs counsel first tell them what Mr. Kahn is to