EFTA00597904.pdf

Case 1:17-cv-00616-JGK Document 41 Filed 05/19/17 Page 1 of 2 q , Cass Cenonal AbusP wale ul Death vThistletioser Cam WWW.PATHTOJUSTICE.COM Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, P.L. Bradley J. Edwards May 19, 2017 Honorable John G. Koeltl Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 RE: Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, et. Al Case No. No. 17 Civ. 00616 (JGK) Dear Judge Koeltl: We are counsel for Jane Doe 43 in the above referenced matter and we write in response to the letter submitted by Defendants on May 18, 2017 requesting an adjournment of the June 2, 2017 hearing. Defendants ignored your individual practice rules and failed to set forth Plaintiff's position that she objects to any further delay of this hearing. From the initial Rule 26(f) conferral, Plaintiff and Defendants have had one fundamental disagreement in need of immediate resolution. Plaintiff desires to exchange Rule 26 disclosures immediately and begin discovery, while Defendant refuses to do so and insists on doing nothing until the Motion to Dismiss is fully briefed and the Court rules on it. Plaintiff recently communicated with Defendants' counsel on May 16, 2017, her desire to proceed with the scheduled hearing and raise with the Court that both parties should be required to submit their Rule 26 disclosures without further delay and proceed with discovery. Defendants are taking the position that the hearing should be adjourned and Defendants should not be required to exchange their Rule 26 disclosures or otherwise participate in discovery until the Court has resolved the Motion to Dismiss, which according to the briefing schedule will delay even basic disclosures in this case for months. Defendants cannot unilaterally decide against 425 N. Andrews Avenue • Suite 2 • Fort Lauderdale, FL 33301 Toll Free: 800.400.1098 • Office: 954.524.2820 • Fax: 954.524.2822 EFTA00597904 Case 1 :17-cv-00616 -JG K Honorable John G. Koeltl May 19, 2017 Page 2 Document 41 Filed 05/19/17 Page 2 of 2 exchanging Rule 26 disclosures and effectively grant themselves a stay by seeking June 2, 2017 hearing; however, that is exactly what they have done. Plaintiff respectfully requests that the Court proceed with the June 2, 2017 hearing Defendants' efforts at delay can be properly addressed. Very Truly Yours, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS and LEHRMAN, PL Bradley J Tiwar& Bradley J. Edwards BJE:mwk to adjourn the at which time EFTA00597905