Case 1:19-cv-10476-PGG-DCF Document 38 Filed 05/08/20 Page 1 of 2 Troutman Sanders LLP 875 Third Avenue New York, New York 10022 troutman.com troutmariP sanders MatthewJ. Aaronson [email protected] May 8, 2020 Via ECF Hon. Debra Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007 Re: Jane Doe 1000, 1:19-cv-10577-LJL-DCF; 1:19-cv-10479-ALC-DCF 1:19-cv-10476-PGG-DCF; Dear Judge Freeman: We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors'), in the above-referenced actions commenced by Plaintiffs Jane Doe 1000, and I (the "Actions"). Plaintiffs filed a letter in each of the Actions yesterday seeking a pre-motion conference on Plaintiffs' anticipated motions to compel, among other things, interrogatory responses (the "Letters"). While we address threshold issues with the Letters below — primarily that they are premature and inconsistent with Your Honor's individual rules and directions regarding the parties' obligation to engage in meaningful efforts to resolve discovery issues before seeking the court's intervention — one of Your Honor's explicitly stated pet peeves — we respectfully request that the Court deny the requests for pre-motion conferences as an unnecessary waste of the Court's time. Alternatively, the Co-Executors request permission to submit a response to the substantive issues raised in the Letters by May 13, 2020, by which time Co-Executors expect to have supplemented their interrogatory responses, which is something the Co-Executors agreed to do as a compromise, before Plaintiffs went ahead and filed the Letters with the Court. The timing of the Letters is particularly troubling considering that the parties' meet-andconfer process was still very much on-going with respect to issues raised by both sides. In fact, we emailed Plaintiffs' counsel on May 6 seeking confirmation that, in light of the parties' continued communi