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Case 1:19-cv-10476-PGG-DCF Document 42 Filed 05/11/20 Page 1 of 2
BSF
BOIES
SCH ILLER
FLEXNER
Sigrid S. McCawley
Telephone: (954) 377-4223
Email: smccawley@bsfllp.com
May 11, 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 submit on behalf of Plaintiff Teresa Helm this reply in further support of her letter
motion for a conference to address Defendants’ complete failure to participate in discovery to date
(ECF No. 37), and in response to Defendants’ letter, filed on May 8, 2020 (ECF No. 38). As set
forth in Plaintiff’s opening letter, Defendants refuse to produce documents concerning Jeffrey
Epstein’s sex-trafficking conspiracy. Instead, they offer to produce only documents that directly
mention Plaintiff’s name, and documents only from limited time periods surrounding the specific
dates on which she was abused. ECF No. 37. Defendants also failed to respond to any of Plaintiff’s
Rule 33 interrogatories. Defendants’ opposition admittedly offers no “response to the substantive
issues,” yet asks the Court to deny Plaintiff’s request for a conference because it would somehow
be “an unnecessary waste of the Court’s time.” ECF No. 38 at 1. The Court should reject
Defendants’ transparent delay tactic and order the Defendants to address their discovery
deficiencies immediately.
Defendants’ only basis for arguing that a conference would be “premature” is that, on Ap
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