This document is a letter from Mary Grace W. Metcalfe of Troutman Pepper Hamilton Sanders LLP, representing Darren K. Indyke and Richard D. Kahn, co-executors of Jeffrey Epstein's estate, to Judge Debra C. Freeman, regarding the case Jane Doe v. Indyke, Kahn, and Maxwell.
The letter, dated August 20, 2020, addresses a misstatement made by Jane Doe's counsel in a previous filing. Specifically, the plaintiff's counsel had claimed to attach the full email string concerning a particular issue, but the defense counsel asserts that their reply was omitted. The letter aims to correct the record by including the complete email chain for the court's review. The case involves allegations against the co-executors of Epstein's estate and Ghislaine Maxwell.
Troutman Pepper Hamilton Sanders LLP 875 Third Avenue New York, New York 10022 troutman.com Mary Grace W. Metcalfe [email protected] August 20, 2020 VIA ECF The Honorable Debra C. Freeman United States District Court Southern District of New York Daniel Patrick Moynihan Courthouse 500 Pearl Street New York, NY 10007 Re: Jane Doe v. Darren K. Indyke and Richard D. Kahn, in their capacities as executors of the Estate of Jefferey E. Epstein, and Ghislaine Maxwell, No. 1:20-cv-00484-JGK-DCF Dear Judge Freeman: We represent Defendants Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jefferey E. Epstein (the “Co-Executors”), in the above-referenced action. We write solely to correct the record with regard to a misstatement in the letter filed by counsel for Plaintiff Jane Doe (“Plaintiff”) this afternoon. Plaintiff’s counsel, in a footnote, represented that they had “attached the full and complete email string concerning this issue for the Court's review and consideration.” Doc. 71 n.1. However, Plaintiff’s counsel omitted our reply sent today, before they filed their letter. The full chain is attached hereto. Respectfully submitted, s/ Mary Grace W. Metcalfe Mary Grace W. Metcalfe CC: All Counsel (via ECF) Case 1:20-cv-00484-JGK-DCF Document 72 Filed 08/20/20


