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Case 1:19-cv-10476-PGG-DCF Document 37 Filed 05/07/20 Page 1 of 5
BSF
BOIES
SCH ILLER
FLEXNER
Sigrid S. McCawley
Telephone: (954) 377-4223
Email: smccawley@bsfllp.com
May 7, 2020
VIA ECF
The Honorable Debra Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Re: Teresa Helm v. Darren K. Indyke & Richard D. Kahn, 19-10476-PGG-DCF
Dear Judge Freeman:
We write on behalf of Plaintiff Teresa Helm in the above-captioned litigation. Pursuant to
Individual Rule II.A and Local Civil Rule 37.2, Plaintiff respectfully requests a pre-motion
conference on Plaintiff’s anticipated motion to compel Defendants Darren K. Indyke and Richard
D. Kahn (1) to produce responsive documents from the Relevant Period as defined in Plaintiff’s
discovery requests; (2) to produce documents responsive to Plaintiff’s requests, not simply
documents that directly mention Plaintiff’s name; and (3) to respond to Plaintiff’s interrogatories.1
The Court has made clear that discovery in this case would not be stayed pending the approval of
the claims administration program or a motion to dismiss absent a contrary order from the Court.
See Tr. of Nov. 21, 2019 Conf. at 26:10–12. Yet by failing to comply with their clear and
unequivocal discovery obligations, including not producing a single document to date, Defendants
are attempting to grant themselves a de facto stay of discovery. Defendants have provided no basis
for their delay.
I. Background
Plaintiff alleges that Jeffrey Epstein and his co-conspirators operated a de
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