📧 Communication

This document is a legal filing from Plaintiff Jane Doe 1000's counsel requesting a pre-motion conference to compel Defendants (Epstein's executors Indyke and Kahn) to produce discovery documents and answer interrogatories. The filing includes exhibits of the discovery requests, which seek detailed information on Epstein's flight logs, financial transactions, communications with high-profile individuals (Prince Andrew, Bill Clinton, Alan Dershowitz), and the structure of his alleged sex-trafficking operation. The Defendants have objected to almost all requests, claiming they are overbroad or that they lack knowledge because Epstein is deceased, prompting the Plaintiff to seek court intervention. Note: While flight logs are requested, no actual flight data is contained in this document.