034.pdf
205 KB
Extraction Summary
8
People
3
Organizations
2
Locations
7
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal correspondence / court order
File Size:
205 KB
Summary
A letter from attorney Bennet J. Moskowitz to Judge Debra C. Freeman dated April 15, 2020, requesting a 30-day extension for various deadlines in civil cases filed by Jane Doe 1000, Teresa Helm, and Juliette Bryant against the Epstein Estate executors. The request cites the ongoing pandemic as the reason for the delay and lists specific new dates for discovery and reports, which Judge Freeman approved via a 'SO ORDERED' endorsement on the same day.
People (8)
| Name | Role | Context |
|---|---|---|
| Bennet J. Moskowitz | Attorney |
Author of the letter, representing Defendants Indyke and Kahn (Troutman Sanders LLP)
|
| Debra C. Freeman | Judge |
United States Magistrate Judge receiving the request and granting the order
|
| Darren K. Indyke | Defendant |
Co-Executor of the Estate of Jeffrey E. Epstein
|
| Richard D. Kahn | Defendant |
Co-Executor of the Estate of Jeffrey E. Epstein
|
| Jeffrey E. Epstein | Deceased |
Estate mentioned as the entity for which Indyke and Kahn are executors
|
| 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
|
|
| Estate of Jeffrey E. Epstein |
Defendant entity managed by Co-Executors
|
|
| United States District Court |
Southern District of New York (implied by address and Judge Freeman)
|
Timeline (7 events)
2020-04-15
2020-06-01
New deadline for Plaintiffs to file motions to amend pleadings or join parties (extended from April 30).
Court
Plaintiffs
2020-06-01
New deadline for joint status reports regarding discovery and settlement (extended from April 30).
Court
All Parties
2020-07-10
New deadline for completion of fact discovery (extended from June 10).
N/A
All Parties
2020-07-10
New deadline for service of Plaintiffs' expert reports (extended from June 10).
N/A
Plaintiffs
2020-08-10
New deadline for service of Defendants' rebuttal reports (extended from July 10).
N/A
Defendants
2020-08-31
New deadline for completion of expert discovery (extended from July 31).
N/A
All Parties
Locations (2)
| Location | Context |
|---|---|
Relationships (3)
We represent Defendants Darren K. Indyke...
We represent Defendants... Richard D. Kahn
Co-Executors of the Estate of Jeffrey E. Epstein
Key Quotes (3)
"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
034.pdf
Quote #1
"This is the first request for an extension of these deadlines."Source
034.pdf
Quote #2
"SO ORDERED"Source
034.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (2,214 characters)
Case 1:19-cv-10476-PGG-DCF Document 34 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:
• 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 to June 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 Defendants’ rebuttal reports be extended from July 10, 2020 to August 10, 2020; and
Case 1:19-cv-10476-PGG-DCF Document 34 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.
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)
April 15, 2020
SO ORDERED
/s/ Debra Freeman
DEBRA FREEMAN
United States Magistrate Judge
42069001v1
SO ORDERED
/s/ Debra Freeman
DEBRA FREEMAN
United States Magistrate Judge
42069001v1
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