Case 1:20-cv-00484-JGK-DCF Troutman Pepper Sanders LLP 875 Third Avenue New York, New York 10022 Document 76 Filed 08/26/20 Page 1 of 3 troutmario pepper troutman.com Bennet J. Moskowitz [email protected] August 26, 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 together with counsel for Defendant Ghislaine Maxwell to request that the Court enter the attached draft Confidentiality Agreement and Protective Order ("Proposed Order"). In accordance with Your Honor's Order dated August 14, counsel for the CoExecutors, Ms. Maxwell, and Plaintiff Jane Doe ("Plaintiff"), respectively, conferred regarding the Proposed Order, exchanging multiple drafts and comments thereto. While counsel for the Parties have been able to agree on the majority of the Proposed Order's provisions, a few disagreements remain, as follows: Paragraph 4: Plaintiff's counsel indicates that they will only agree to designate "medical, mental health and/or other health care records", "Social Security numbers, personal telephone numbers, tax returns, and credit and banking information", and the "names of alleged minor victims of sexual abuse" as confidential under the Proposed Order. However, these limitations would remove many documents from the protection of the Proposed Order, including those containing sensitive and private information such as an individual's health or private habits, education, finances, home address, or history of abuse. Such documents are routinely form the subject of protective o