Case 1:20-cv-00484-JGK-DCF Troutman Pepper Sanders LLP 875 Third Avenue New York, New York 10022 Document 77 Filed 08/27/20 Page 1 of 4 troutmario pepper troutman.com Bennet J. Moskowitz [email protected] August 27, 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. lndyke 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. lndyke and Richard D. Kahn, as Co-Executors of the Estate of Jefferey E. Epstein (the "Co-Executors") in the above-referenced action. We write in response to the Letter Motion to Stay Proceedings ("Motion to Stay") filed by Defendant Ghislaine Maxwell. Doc. 69. As explained below, the Co-Executors consent to the entry of a stay and join in the request that it apply to the entire proceeding. The Co-Executors agree that a complete stay of this action is appropriate under the circumstances Ms. Maxwell sets forth in her Motion to Stay. Given (i) the readily apparent, significant overlap between the criminal case and the allegations in the Complaint that Plaintiff Jane Doe ("Plaintiff") filed in this action, (ii) the fact that Ms. Maxwell has been indicted and her trial has been scheduled, (iii) the decades that have already elapsed since the allegations in the Complaint, (iv) the challenges Ms. Maxwell has identified with regard to her participation in this action, and (v) the near certainty that the resolution of Ms. Maxwell's criminal matter will address the core issues presented in this case, the interests of the parties, the Court, and the public all weigh in favor of the entry of a stay. S.E.C. v. Downe, No. 92-cv-4092-PKL, 1993 WL 22126, at *14 (S.D.N.Y. Jan. 26, 1993). A partial stay would unduly prejudice the Co-Executors' ability to defend ag