Case 1:20-cv-00484-JGK-DCF Document 72-1 Filed 08/20/20 Page 1 of 6 Metcalfe, Mary From: Sent: To: Cc: Subject: Metcalfe, Mary Thursday, August 20, 2020 3:18 PM 'Robert Glassman'; Moskowitz, Bennet J. Nathan Werksman; Laura Menninger; Weiner, Daniel H.; Kevin Boyle; Andrew Tomback RE: Jane Doe, 1:20-cv-00484-JGK-DCF Robert, We will make Mr. Kahn available for a deposition in his capacity as co-executor only, on a mutually agreeable date in the second half of September or in October. Please keep in mind September is very difficult with the various holidays. Please let us know several possible dates on your side within the proposed window. This is without prejudice to our clients' rights and legal positions, including regarding the potential stay of discovery or the entire action. Thanks, Mary W. Metcalfe Associate troutman pepper Direct: 212.704.6029 I Mobile: 425.984.4165 [email protected] From: Robert Glassman Sent: Thursday, August 20, 2020 12:38 PM To: Moskowitz, Bennet J. Cc: Metcalfe, Mary ; Nathan Werksman; Laura Menninger; Weiner, Daniel H.; Kevin Boyle; Andrew Tomback Subject: RE: Jane Doe, 1:20-cv-00484-JGK-DCF EXTERNAL SENDER Hi Bennet, as I stated on Tuesday, we would still like to proceed with Mr. Indyke's deposition next week even if you still haven't given us documents before then. I am sorry if you did not understand that the first time I said it. In that regard, please confirm you received the Zoom link we circulated earlier this week for his deposition. I'm not sure you correctly stated the chronology of events concerning your proposed confidentiality order and NDA. I provided you with my edits to it on August 10—ten days ago. Up until last night, we did not hear from you whether you had issues with or were satisfied with them. As Judge Freeman stated, the PO should protect the identity of other alleged Epstein/Maxwell minor victims. Other than that, I can't think of any other subject matter that ought to be legitimately protect