Case 1:19-cv-10788-GHW-DCF

Document 38

Filed 04/14/20

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Troutman Sanders LLP
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Bennet J. Moskowitz
D: 212-704-6000
bennet.moskowitz@troutman.com

MEMORANDUM ENDORSED

April 13, 2020

VIA ELECTRONIC COURT FILING

Hon. Debra C. Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl Street
New York, New York 10007

Re: Jane Doe 15, 1:19-cv-10653-PAE-DCF; Mary Doe, 1:19-cv-10758-PAE-DCF; Teala
Davies, 1:19-cv-10788-GHW-DCF

Dear Judge Freeman:

We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the “Co-Executors”), in the above-referenced actions commenced by Jane Doe 15, Mary Doe and Teala Davies (together, “Plaintiffs,” and together with the CoExecutors, the “Parties”). In light of the ongoing pandemic and the various difficulties it has presented, we write with Plaintiffs’ consent to request that the Court extend the remaining deadlines in the above-refenced actions, as set by this Court’s Order dated February 11, 2020, by thirty (30) days, as follows:

- the deadline for Plaintiffs to file any motions to amend the pleadings or to join any additional parties be extended from April 30, 2020 to June 1, 2020;

- the deadline for the Parties to submit joint status reports to the Court, regarding discovery and the progress of settlement discussions, be extended from April 30, 2020 toJune 1, 2020;

- the deadline for the completion of fact discovery be extended from June 10, 2020 to July 10, 2020 ;

- the deadline for service of Plaintiffs’ expert reports be extended from June 10, 2020 to July 10, 2020;

 the deadline for service of the Co-Executors’ rebuttal reports be extended from July 10, 2020 to August 10, 2020; and

Case 1:19-cv-10788-GHW-DCF

Document 38

Filed 04/14/20

Page 2 of 2

April 13, 2020

Page 2

troutman
sanders

• the deadline for the completion of expert discovery be extended from July 31, 2020 to August 31, 2020.
This is the first request for an extension of these deadlines.

Respectfully submitted,

s/Bennet J. Moskowitz
Bennet J. Moskowitz

cc: Counsel of Record (via ECF)

April 14, 2020
SO ORDERED

<signature>
DEBRA FREEMAN

United States Magistrate Judge
court-records/Davies v. Indyke, No. 119-cv-10788 (S.D.N.Y. 2019)/038.pdf
{"year":"2019","court":"S.D.N.Y","people":["bennett moskowitz","debra c. freeman","darren indyke","richard kahn","jeffrey epstein","teala davies"]}