Case 1 20-cv-00484-3GK-DCF Document 71 Filed 08/20/20 Page 1 of 8 PANISH SHEA& BOYLE I August 20, 2020 VIA ECF Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 Re: Doe v. Indyke, et al., 1:20-cv-000484-JUK-DCF Dear Judge Freeman: We are writing on behalf of our client, plaintiff Jane Doe, in the above-referenced litigation. Earlier today, counsel for the Jeffrey Epstein Estate submitted a letter to the Court seeking to cancel the deposition of Darren Indyke scheduled for next week on Wednesday, August 26, 2020. This is a date that Mr. Indyke's own counsel selected last month that was agreed upon by the parties. Now, however, the Epstein Estate attorneys are raising a myriad of excuses to avoid producing Mr. Indyke for his properly noticed deposition. Since Mr. Indyke is being deposed in both his personal capacity and as a co-executor of the Epstein Estate, we expect him to offer extremely relevant testimony concerning the allegations set forth in Plaintiffs complaint. Indeed, we have reason to believe he has firsthand knowledge of Jeffrey Epstein's relationship with Plaintiff while she was a minor and even acted on Jeffrey Epstein's behalf to communicate with Plaintiff on several occasions. His testimony is vital to Plaintiffs case and the Epstein Estate should not be allowed to prevent his deposition from going forward. And despite counsel for the Epstein Estate representing to this Court that Plaintiff has not agreed to only take one deposition of Mr. Indyke, that is untrue. As stated in our emails to counsel for the Epstein Estate', we understand that Mr. Indyke is only being produced one time for his deposition. And even though the Epstein Estate has still failed to provide Plaintiff with a single document or piece of evidence in this case despite sending requests for them over 4 We have attached the full and complete email string concerning this issue for the Court's review and consideration. 11111 Sant