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Case 1:19-cv-11869-MKV-DCF Document 28 Filed 04/15/20 Page 1 of 3
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutmariP
troutman.com
sanders
Bennet J. Moskowitz
D: 212-704-6000
bennet.moskowitz@troutman.com
April 15, 2020
VIA ECF
Hon. Debra C. Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl Street
New York, New York 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-cv-
11869-MKV-DCF
Dear Judge Freeman:
We represent Defendants Darren K. Indyke and Richard D. Kahn, as Co-Executors of the
Estate of Jeffrey E. Epstein, in the above-referenced actions. We write in response to the
“Status Update” dated April 15, 2020, submitted by plaintiffs’ counsel, Brad Edwards and
Brittany Henderson, to Your Honor (ECF Doc. 27).
Mr. Edwards and Ms. Henderson’s letter is accurate in several important respects:
First: The Co-Executors have – with no legal obligation to do so – worked hard for more than
five months to establish an independent and voluntary claims resolution program, titled the
“Epstein Victims’ Compensation Program,” for purposes of resolving sexual abuse claims
against Mr. Epstein. If the Program fails to launch, it will be an extraordinary lost opportunity for
eligible claimants to receive compensation and voluntarily resolve their claims through a
confidential, non-adversarial alternative to litigation.
Second: After interviewing several potential candidates to design and administer the Program,
the Co-Executors selected the nationally acclaimed trio of Jordana Feldman, Kenneth Feinberg
and Camille Biros, who have designed, implemented and administered extensive mass tort
compensation programs including t
[…]