Subject: 2020.11.09 call w/ Kaplan Hecker re: Dawn Hughes

From: aMIE> I Subject: 2020.11.09 call w/ Kaplan Hecker re: Dawn Hughes Date: Mon, 09 Nov 2020 17:51:26 +0000 (USANYS)" Mike Ferrara Alex Conlon During a call with Alex Conlon and Mike Ferrara, we explained that we are considering retaining Dr. Dawn Hughes as an expert to testify about several concepts. We understand Dr. Hughes examined a plaintiff represented by KH, so we explained that we wanted to ask about scope of representation to see if this posed any issues we should consider. Mike and Alex explained: • The plaintiff who was examined by Dr. Hughes is In connection with the evaluation, they provided Dr. Hughes with several documents relating to the case, including documents obtained from the government through a Touhy request. Dr. Hughes generated a report, and also communicated directly with Epstein's estate in connection with discussions about a resolution. • Alex noted that...disclosed more to Dr. Hughes than she disclosed to the government during interview