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Case 1:19-cv-10476-PGG-DCF Document 10 Filed 01/10/20 Page 1 of 2
BSF
BOIES
SCHILLER
FLEXNER
January 10, 2020
VIA ECF
The Honorable Debra Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Re: Juliette Bryant v. Darren K. Indyke and Richard D. Kahn, in their capacities as
executors of the Estate of Jeffrey Edward Epstein, 19-10479
Jane Doe 1000 v. Darren K. Indyke and Richard D. Kahn, in their capacities as
executors of the Estate of Jeffrey Edward Epstein, 19-10577
Annie Farmer v. Darren K. Indyke and Richard D. Kahn, in their capacities as
executors of the Estate of Jeffrey Edward Epstein, and Ghislaine Maxwell, 19-
10475
Teresa Helm v. Darren K. Indyke and Richard D. Kahn, in their capacities as
executors of the Estate of Jeffrey Edward Epstein, 19-10476
Dear Judge Freeman:
Pursuant to the Court’s request at the November 21, 2019, Case Management Conference,
Plaintiffs and Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of
Jeffrey E. Epstein, jointly submit this letter to provide the Court with an update as to the progress
of discussions regarding both discovery and settlement.
The parties have thus far engaged in two productive conferences pursuant to Rule 26(f) of
the Federal Rules of Civil Procedure. During those conferences, the parties agreed to exchange
initial disclosures by January 23, 2020, and to exchange discovery plans one week thereafter, on
January 30, 2020.
As the Court is aware, Defendants have arranged for a Victims’ Compensation Program
that will be available to Plaintiffs. Plaintiffs’ counsel has conferred with the Program’s designers
and administrators, the Program
[…]