025.pdf
64.6 KB
Extraction Summary
8
People
3
Organizations
2
Locations
2
Events
7
Relationships
2
Quotes
Document Information
Type:
Legal correspondence (letter motion)
File Size:
64.6 KB
Summary
This document is a letter from attorney Bennet J. Moskowitz to Judge Debra C. Freeman dated April 15, 2020. It requests a 30-day extension for various discovery and filing deadlines in civil cases brought by Jane Doe 1000, Teresa Helm, and Juliette Bryant against the Estate of Jeffrey Epstein, citing delays caused by the COVID-19 pandemic.
People (8)
| Name | Role | Context |
|---|---|---|
| Bennet J. Moskowitz | Attorney |
Attorney for Defendants (Troutman Sanders LLP), author of the letter
|
| Debra C. Freeman | Judge |
Honorable Magistrate Judge, recipient of the letter
|
| Darren K. Indyke | Defendant/Co-Executor |
Co-Executor of the Estate of Jeffrey E. Epstein
|
| Richard D. Kahn | Defendant/Co-Executor |
Co-Executor of the Estate of Jeffrey E. Epstein
|
| Jeffrey E. Epstein | Deceased |
Estate mentioned as defendant
|
| Jane Doe 1000 | Plaintiff |
Plaintiff in case 1:19-cv-10577-LJL-DCF
|
| Teresa Helm | Plaintiff |
Plaintiff in case 1:19-cv-10476-PGG-DCF
|
| Juliette Bryant | Plaintiff |
Plaintiff in case 1:19-cv-10479-ALC-DCF
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Troutman Sanders LLP |
Law firm representing the Defendants
|
|
| United States District Court |
Implied by 'United States Courthouse' address
|
|
| Estate of Jeffrey E. Epstein |
Defendant entity
|
Timeline (2 events)
2020-04-15
Locations (2)
Relationships (7)
We represent Defendants Darren K. Indyke
We represent Defendants... Richard D. Kahn
Co-Executors of the Estate of Jeffrey E. Epstein
Co-Executors of the Estate of Jeffrey E. Epstein
actions commenced by Jane Doe 1000... against... Estate of Jeffrey E. Epstein
actions commenced by... Teresa Helm... against... Estate of Jeffrey E. Epstein
actions commenced by... Juliette Bryant against... Estate of Jeffrey E. Epstein
Key Quotes (2)
"In light of the ongoing pandemic and the various difficulties it has presented for all parties, we write with the consent of Plaintiffs to request that the Court extend the remaining deadlines"Source
025.pdf
Quote #1
"We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein"Source
025.pdf
Quote #2
Full Extracted Text
Complete text extracted from the document (2,155 characters)
Case 1:19-cv-10479-ALC-DCF Document 25 Filed 04/15/20 Page 1 of 2
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutman.com
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutman.com
Bennet J. Moskowitz
bennet.moskowitz@troutman.com
bennet.moskowitz@troutman.com
April 15, 2020
Via ECF
Hon. Debra C. Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007
Re: Jane Doe 1000, 1:19-cv-10577-LJL-DCF; Teresa Helm, 1:19-cv-10476-PGG-DCF;
Juliette Bryant, 1:19-cv-10479-ALC-DCF
Juliette Bryant, 1:19-cv-10479-ALC-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 1000, Teresa Helm and Juliette Bryant (together, “Plaintiffs”, and with the Co-
Executors, the “Parties”). In light of the ongoing pandemic and the various difficulties it has
presented for all parties, we write with the consent of Plaintiffs to request that the Court extend
the remaining deadlines in the above-referenced actions, as set by this Court’s Order dated
February 11, 2020, by thirty (30) days, as follows:
Jeffrey E. Epstein (together, the “Co-Executors”), in the above-referenced actions commenced
by Jane Doe 1000, Teresa Helm and Juliette Bryant (together, “Plaintiffs”, and with the Co-
Executors, the “Parties”). In light of the ongoing pandemic and the various difficulties it has
presented for all parties, we write with the consent of Plaintiffs to request that the Court extend
the remaining deadlines in the above-referenced 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;
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
to June 1, 2020;
discovery and the progress of settlement discussions, be extended from April 30, 2020
to June 1, 2020;
• the deadline for the completion of fact discovery be extended from June 10, 2020 to July
10, 2020;
10, 2020;
• the deadline for service of Plaintiffs’ expert reports be extended from June 10, 2020 to
July 10, 2020;
July 10, 2020;
• the deadline for service of the Defendants’ rebuttal reports be extended from July 10,
2020 to August 10, 2020; and
2020 to August 10, 2020; and
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Case 1:19-cv-10479-ALC-DCF Document 25 Filed 04/15/20 Page 2 of 2
April 15, 2020
Page 2
April 15, 2020
Page 2
• the deadline for the completion of expert discovery be extended from July 31, 2020 to
August 31, 2020.
August 31, 2020.
This is the first request for an extension of these deadlines.
Respectfully submitted,
s/Bennet J. Moskowitz
Bennet J. Moskowitz
Bennet J. Moskowitz
cc: Counsel of Record (via ECF)
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troutman
sanders
troutman
sanders
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