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Case 1:19-cv-10476-PGG-DCF Document 38 Filed 05/08/20 Page 1 of 2
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutmariP
troutman.com
sanders
MatthewJ. Aaronson
Matthew.aaronson@troutman.com
May 8, 2020
Via ECF
Hon. Debra C. Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007
Re: Jane Doe 1000, 1:19-cv-10577-LJL-DCF; Teresa Helm, 1:19-cv-10476-PGG-DCF;
Juliette Bryant, 1:19-cv-10479-ALC-DCF
Dear Judge Freeman:
We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the
Estate of Jeffrey E. Epstein (together, the “Co-Executors”), in the above-referenced actions
commenced by Plaintiffs Jane Doe 1000, Teresa Helm and Juliette Bryant (the “Actions”).
Plaintiffs filed a letter in each of the Actions yesterday seeking a pre-motion conference on
Plaintiffs’ anticipated motions to compel, among other things, interrogatory responses (the
“Letters”). While we address threshold issues with the Letters below – primarily that they are
premature and inconsistent with Your Honor’s individual rules and directions regarding the parties’
obligation to engage in meaningful efforts to resolve discovery issues before seeking the court’s
intervention – one of Your Honor’s explicitly stated pet peeves – we respectfully request that the
Court deny the requests for pre-motion conferences as an unnecessary waste of the Court’s time.
Alternatively, the Co-Executors request permission to submit a response to the substantive issues
raised in the Letters by May 13, 2020, by which time Co-Executors expect to have supplemented
their interrogatory responses, which is something the Co-Executors agreed to do as a
compromise, before Plaintiffs went ahead and filed the Letters with the Court.
The timing of the Letters is particula
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