026.pdf
205 KB
Extraction Summary
8
People
3
Organizations
2
Locations
1
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal letter/motion and court order
File Size:
205 KB
Summary
A letter dated April 15, 2020, from attorney Bennet J. Moskowitz to Judge Debra C. Freeman requesting a 30-day extension for various deadlines in lawsuits filed by Jane Doe 1000, Teresa Helm, and Juliette Bryant against the Estate of Jeffrey Epstein. The request cites the ongoing pandemic as the reason for the delay and notes the consent of the plaintiffs. The document is signed 'SO ORDERED' by Judge Freeman on the same date.
People (8)
| Name | Role | Context |
|---|---|---|
| Bennet J. Moskowitz | Attorney |
Author of the letter representing the Co-Executors; Partner at Troutman Sanders LLP.
|
| Debra C. Freeman | Judge |
United States Magistrate Judge addressed in the letter; signed the 'SO ORDERED' approval.
|
| 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 |
His estate is the defendant in the lawsuits.
|
| 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 Epstein).
|
|
| United States District Court |
Southern District of New York (implied by address 500 Pearl St).
|
|
| Estate of Jeffrey E. Epstein |
Defendant entity in the lawsuits.
|
Timeline (1 events)
2020-04-15
Request for extension of legal deadlines due to COVID-19 pandemic submitted and approved by Judge Freeman.
New York, NY
Locations (2)
| Location | Context |
|---|---|
|
Address of Troutman Sanders LLP.
|
|
|
Address of the court.
|
Relationships (3)
Described as 'Co-Executors of the Estate of Jeffrey E. Epstein'
Described as 'Co-Executors of the Estate of Jeffrey E. Epstein'
States 'We represent Defendants Darren K. Indyke...'
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
026.pdf
Quote #1
"SO ORDERED"Source
026.pdf
Quote #2
"We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein"Source
026.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (2,246 characters)
Case 1:19-cv-10479-ALC-DCF Document 26 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 26 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)
April 15, 2020
SO ORDERED
DEBRA FREEMAN
United States Magistrate Judge
United States Magistrate Judge
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