Case 1:19-cv-10476-PGG-DCF Document 43 Filed 05/13/20 Page 1 of 4 troutmar? sanders Troutman Sanders LLP 875 Third Avenue New York, New York 10022 troutman.com Matthew,). Aaronson [email protected] May 13, 2020 Via ECF Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007 Re: 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 action (the "Action"). We write to address the substantive issues raised in Plaintiffs letters to the Court dated May 7 and May 11, prematurely requesting a pre-motion conference on Plaintiffs anticipated motion to compel. For the reasons set forth below and in our May 8 letter, we respectfully request that the Court deny Plaintiffs request. The picture Plaintiff paints is a false one. On their face, Plaintiffs interrogatories are clearly overbroad and unduly burdensome. However, as a compromise and as the Co-Executors said they would do before Plaintiff filed her letter, the Co-Executors have supplemented their responses to those interrogatories. Notwithstanding that Plaintiff has provided no transparency into her own efforts to produce responsive materials (something the Co-Executors hope to resolve before filing letters with the Court), the Co-Executors have collected and are, in connection with this and the numerous other cases against them before Your Honor, reviewing a database of over 730,000 documents. We address Plaintiffs specific points below. First, Plaintiffs proposed 18-year time frame for discovery is not proportional to the needs of this case and would impose an undue burden on the Co-Executors. Although Plaintiff asserts that her alleged abuse by Mr. Epstein occurred at some point in in 2002, she demands discovery from 2002 through the present. Plaintiffs proposed time frame is contrary to the goals of the 2015 am