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305 BROADWAY, SUITE 607
CUTI HECKER WANG LLP NEW YORK, NY 10007
MARIANN MEIER WANG
212.620.2603 TEL
212.620.2613 FAX
MWANG@CHWLLP.COM
February 6, 2020
By ECF
Hon. Debra Freeman
U.S. District Court for the Southern District of New York
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Re: Jane Doe 15 v. Indyke et al., 19-cv-10653 (PAE)(DCF)
Mary Doe v. Indyke et al., 19-cv-10758 (PAE)(DCF)
Davies v. Indyke et al., 19-cv-10788 (GHW)(DCF)
Your Honor:
We represent the plaintiffs in the three above-referenced cases. As
directed in Your Honor’s Order dated January 14, 2020, we write jointly with
counsel for Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the
Estate of Jeffrey E. Epstein (the “Co-Executors”), to provide a proposed discovery
schedule for these cases. The area where the parties have not reached agreement is
indicated in italics, and each side’s position is set forth below.
1. Initial disclosures under Rule 26(a)(1) were exchanged on January 23, 2020.
2. Plaintiffs will provide HIPAA-compliant medical records release authorizations to
Defendants no later than 14 days from Defendants’ request, provided such date is
not earlier than February 28, 2020.
3. The parties shall serve initial document requests and interrogatories by 30 days
from the Court’s entry of the discovery schedule. Plaintiffs served Defendants
with their initial document requests and interrogatories but the parties have
agreed that Defendants have until Februar
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