Case 1:20-cv-00484-JGK-DCF Troutman Pepper Sanders LLP 875 Third Avenue New York, New York 10022 Document 95 Filed 02/05/21 Page 1 of 2 troutmarili pepper troutman.com Bennet J. Moskowitz bennelmoskowitz©Iroutman.com February 5, 2021 VIA ECF Hon. John G. Koeltl 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 Koeltl: 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 filed yesterday by Plaintiff (Doc. 94) in which she asks the Court to "continue her Motion to Dismiss and defer its ruling on it until after we know whether or not the settlement reached among the parties will be honored by the [Epstein Victims' Compensation Program ("EVCP")]."1 The Court should deny Plaintiffs request, which is based on her counsel's apparent misunderstanding of the letter annexed thereto from the EVCP's Administrator. Yesterday, the EVCP's Administrator announced a prospective, temporary suspension of new compensation determinations pending the Estate's resolution of liquidity issues. This temporary suspension in no way affects Plaintiff, who accepted her compensation determination before the suspension. Therefore, there was no need for Plaintiff's new request, let alone her counsel's erroneous suggestion of "collusive efforts" to "disenfranchise" her. There is only one reason Plaintiff has not yet received her payout from the EVCP: Defendant Ghislaine Maxwell's refusal to stipulate to dismissal of this action absent Because there is no "settlement ... among the parties," we assume that Plaintiff is referring to her acceptance of the EVCP's independent Administrator's comp