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Case 1:19-cv-10577-LJL-DCF Document 52 Filed 05/13/20 Page 1 of 4
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutmariP
troutman.com
sanders
MatthewJ. Aaronson
Matthew.aaronson@troutman.com
May 13, 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
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
action (the “Action”). We write to address the substantive issues raised in Plaintiff’s letters
to the Court dated May 7 and May 11, prematurely requesting a pre-motion conference
on Plaintiff’s anticipated motion to compel. For the reasons set forth below and in our
May 8 letter, we respectfully request that the Court deny Plaintiff’s request.
The picture Plaintiff paints is a false one. On their face, Plaintiff’s interrogatories
are clearly overbroad and unduly burdensome. However, as a compromise and as the
Co-Executors said they would do before Plaintiff filed her letter, the Co-Executors have
supplemented their responses to those interrogatories. Notwithstanding that Plaintiff has
provided no transparency into her own efforts to produce responsive materials (something
the Co-Executors hope to resolve before filing letters with the Court), the Co-Executors
have collected and are, in connection with this and the numerous other cases against
them before Your Honor, reviewing a database of over 730,000 documents. We
address Plaintiff’s specific points below.
First, Plaintiff’s proposed 21-year time frame for discovery is not proportional to
the needs of this case and would impose an undue burden on the Co-Execut
[…]