Case 1:20-cv-00484-JGK-DCF Troutman Pepper Sanders LLP 875 Third Avenue New York, New York 10022 Document 67 Filed 08/12/20 Page 1 of 3 troutmariP pepper troutman.com Mary W. Metcalfe [email protected] August 12, 2020 VIA ECF The Honorable Debra C. Freeman United States District Court Southei l ict of New York Daniel Moynihan Courthouse 500 Pearl Street New York, NY 10007 Re: Jane Doe v. Darren K. Indyke 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. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jefferey E. Epstein (the "Co-Executors"), in the above-referenced action. We write both in response to the letter that counsel for Plaintiff Jane Doe filed this afternoon without any advance notice and pursuant to Your Honor's Order dated August 5, 2020 (the "Order"). Counsel for Plaintiffs letter is inaccurate and omits critical information. Prior to Plaintiffs counsel filing their letter, counsel for the Co-Executors understood and intended that counsel for Plaintiff, the Co-Executors, and Defendant Ghislaine Maxwell would submit a joint letter pursuant to Your Honor's Order. In accordance with the directives Your Honor issued during the August 5 telephonic conference, on Monday, counsel for the parties met and conferred about a confidentiality agreement, discovery deadlines, and the possibility of a stay of this action in light of Plaintiffs intent to participate in the Epstein Victims' Compensation Program and, separately, Ms. Maxwell's pending criminal action. Regarding the confidentiality order, the issue is straightforward: (1) Your Honor directed all parties to meet and confer to attempt to reach agreement on a proposed order; and (2) counsel for Ms. Maxwell expressly stated during the meet-and-confer that she needed more time to be able to speak to her client about the issue. Here i