Epstein Secrets

, No. 1:20-cv-00484-JGK-DCF Dear Judge Freeman: We represent Defendants Darren K. Indyke and Ri

currently written. Respectfully submitted, /s/ Bennet J. Moskowitz Bennet J. Moskowitz cc: All counsel of record

ent from those imposed by the Federal Rules of Civil Procedure, the Local Rules of the Southern District of New York, or Judge Schofield's or Judge Freeman's Individual Rules and Practices. 3. Any objection to any of the Interrogatories is not an admission that Plaintiff has any information or documen

hn's First Set of Interrogatories has been provided by electronic mail to all counsel of record identified below, on this 16th day of April, 2020. Bennet J. Moskowitz, Esq. Molly S. DiRago, Esq. TROUTMAN SANDERS LLP 875 Third Avenue New York, New York 10022 Tel: (212)-704-6087 Fax: (212)-704-6288 Email: benn

LP Attorneys for Plaintiff BY: ROBERTA KAPLAN ALEXANDRA CONLON KATE L. DONIGER LOUIS FISHER TROUTMAN SANDERS LLP Attorneys for Defendants BY: BENNET J. MOSKOWITZ CHARLES GLOVER SOUTHERN DISTRICT REPORTERS, P.C. EFTA00027884 --- PAGE BREAK --- JCB3DOEC 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

was to have the discovery assigned to a single magistrate judge, and which is what was done. The reason that I'm having this conference, and Judge Freeman is not, is it does not appear that the discussion of motions to strike or motion practice is occurring in all of the cases. And so for those in wh