Case 1:19-cv-07625-AJN-DCF Troutman Sanders LLP 875 Third Avenue New York, New York 10022 Document 63 troutman.com Filed 06/01/20 Page 1 of 20 troutmariP sanders Bennet J. Moskowitz [email protected] June 1, 2020 ECF Hon. Debra C. Freeman Thurgood Marshall United States Courthouse 500 Pearl Street New York, NY 10007 Re: VE, 1:19-cv-07625-AJN-DCF; Katlyn Doe, 1:19-cv-07771-PKC-DCF; Priscilla Doe, 1:19-cv-07772-ALC-DCF; Lisa Doe, 1:19-cv-07773-ER-DCF; Anastasia Doe, 1:19-cv11869-MKV-DCF Dear Judge Freeman: We represent Defendants in the above-referenced actions. We write on behalf of all parties to update the Court regarding settlement and discovery. As the Court is aware, there have been no settlement discussions in any of the individual above-referenced cases. The parties' efforts regarding settlement have been singularly focused on the establishment of a voluntary, independent claims resolution program, the Epstein Victims' Compensation Program. We are pleased to report that, this past weekend, the CoExecutors entered into a tripartite agreement with claimants' counsel (specifically, counsel for Plaintiffs in the above-referenced actions, Brad , and counsel for plaintiffs in four other actions pending before Your Honor, David Boies) and the Attorney General of the United States Virgin Islands pursuant to which the Program may now move forward. Earlier today, the CoExecutors of the Estate of Jeffrey E. Epstein filed in the Superior Court of the Virgin Islands the status report attached hereto as Exhibit A. As stated therein, the Co-Executors, with the support of claimants' counsel and the USVI Attorney General, intend to authorize commencement of the Program on Monday, June 15, 2020. Most, if not all, of the Plaintiffs in the above-referenced actions intend to participate in the Program. Meanwhile, the parties continue to meet and confer in efforts to resolve various discovery disputes. Thank you for your attention to this matter. EFTA02846417