Case 1:20-cv-00484-JGK-DCF Troutman Pepper Sanders LLP 875 Third Avenue New York, New York 10022 Document 70 Filed 08/20/20 Page 1 of 3 troutmaril pepper troutman.com Bennet J. Moskowitz bennet.moskowitz©troutman.com August 20, 2020 VIA ECF The Honorable Debra C. Freeman United States District Court Southern District 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 to obtain relief from Plaintiff Jane Doe's ("Plaintiff') refusal to reschedule the deposition of Darren K. Indyke, scheduled for August 26, 2020. Given recent case developments, holding the deposition next week defies the parties' obligations to promote judicial economy and avoid wasting party resources, as well as common sense. There are five reasons the deposition should not proceed next Wednesday. First if the deposition occurs next week then Plaintiff will undoubtedly seek to hold another deposition at a later date, following the parties' substantial completion of document discovery. Per this Court's Order dated August 14, document production has been stayed pending the entry of a protective order. The parties are required to make a joint proposal to Your Honor regarding the protective order by August 26, the day upon which the deposition is currently scheduled. Even if the parties are able to jointly propose, and the Court approve, a mutually agreed upon protective order in the next several days (which seems unlikely given that we are still waiting on feedback from counsel for the other parties), there would not be nearly enough time for the parties to complete their document productions, let alone to