Case 1:20-cv-00484-JGK-DCF Troutman Pepper Sanders LLP 875 Third Avenue New York, New York 10022 Document 88 Filed 12/22/20 Page 1 of 2 troutmarili pepper troutman.com Bennet J. Moskowitz bennelmoskowitz©Iroutman.com December 22, 2020 VIA ECF The Honorable Debra C. Freeman 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 Jeffrey E. Epstein (the "Co-Executors"), in the above-referenced matter. We write in response to the December 21, 2020 letter from Plaintiffs counsel [Doc 87], to clarify the record. The Co-Executors have no objection to Plaintiffs request that the Court dismiss this action following her decision to accept the Epstein Victims' Compensation Program's (the "Program") independent Administrator's compensation determination. Accordingly, and as Plaintiff's counsel accurately notes, our clients have already executed the Joint Stipulation for Dismissal of Entire Action With Prejudice In his letter, however, Plaintiffs counsel inaccurately states: "The Epstein Estate and Ghislaine Maxwell mandated that Ms. Maxwell be included in the Program settlement release (presumably because when she committed her tortious and criminal conduct against the victims she was doing so as an agent and/or employee in the scope of her agency and/or employment with Mr. Epstein)." Neither Ms. Maxwell nor her counsel had any say whatsoever regarding the Program, including the scope of the Program release. Only the Estate, various plaintiffs' counsel and the U.S.V.I. Attorney General provided input on the Program. It is not surprising that, in the interest of finality and as expressly explained in the Program Protocol — a document drafted over several months with the assistanc