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Case 1:19-cv-07625-AJN-DCF Document 54 Filed 02/06/20 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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VE, :
:
Plaintiff, :
:
v. :
Index No. 1:19-cv-07625-AJN-DCF
:
DARREN K. INDYKE AND RICHARD D. :
KAHN, AS JOINT PERSONAL :
REPRESENTATIVES OF THE ESTATE OF :
JEFFREY E. EPSTEIN, NINE EAST 71st :
STREET, CORPORATION, FINANCIAL :
TRUST COMPANY, INC., NES, LLC, :
:
Defendants.
:
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JOINT PROPOSED DISCOVERY SCHEDULE
Pursuant to the Court’s Order dated January 14, 2020 and Rule 26(f)(3) of the Federal
Rule of Civil Procedure, Plaintiff VE and Defendants Darren K. Indyke and Richard D. Kahn,
Co-Executors of the Estate of Jeffrey E. Epstein (together, the “Co-Executors”), Nine East 71st
Street, Corporation, Financial Trust Company, Inc, and NES, LLC (together the “Corporate
Defendants”, and together with the Co-Executors, the “Defendants”; and the Defendants together
with the Plaintiff, the “Parties”) hereby jointly submit the following proposed discovery
schedule:
1. The Corporate Defendants1 shall serve their initial disclosures pursuant to Rule
26(a)(1) no later than February 13, 2020;
2. Plaintiff shall provide HIPAA-compliant medical records release authorizations to
Defendants no later than 14 days from the request therefor;
3. The Parties shall serve initial document requests and interroga
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