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Case 1:19-cv-07625-AJN-DCF Document 52 Filed 01/10/20 Page 1 of 2
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutmariP
troutman.com
sanders
Bennet J. Moskowitz
bennet.moskowitz@troutman.com
January 10, 2020
ECF
Hon. Debra C. Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 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-AJN-DCF
Dear Judge Freeman:
We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of
Jeffrey E. Epstein (the “Estate”), Nine East 71st Street, Corporation, Financial Trust Company,
Inc., NES, LLC, Florida Science Foundation, Inc., HBRK Associates, Inc., JEGE, Inc., Maple,
Inc., and LSJ, LLC (together, “Defendants”; and Defendants together with Plaintiffs VE, Katlyn
Doe, Priscilla Doe, Lisa Doe and Anastasia Doe, the “Parties”) in the referenced actions, as
applicable. We write on behalf of all Parties to report to the Court regarding settlement and to
respectfully request that the Court approve the Parties’ discovery proposal.
We understand that the vast majority of the plaintiffs in the above referenced and other actions
against the Estate pending in this District will or are very likely to participate in the Epstein
Victims’ Compensation Program (the “Program”), with five plaintiffs having already voluntarily
stayed their actions pending their participation in the Program. Counsel for all such plaintiffs
have conferred extensively with the Program designers and administrator, including in person,
to, among other things, provide specific input on the draft Program protocol issued on
December 13, 2019. We understand such discussions h
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