Extraction Summary

6
People
6
Organizations
2
Locations
3
Events
3
Relationships
3
Quotes

Document Information

Type: Legal correspondence / court order
File Size: 105 KB
Summary

A letter from attorney Bennet J. Moskowitz to Judge Alison J. Nathan requesting a two-week extension for the Epstein Estate executors and associated entities to respond to a complaint in the case 'VE v. Nine East 71st Street'. The Judge granted the request on November 14, 2019, extending the deadline to November 29, 2019, but handwritten notes explicitly state 'No further extensions'.

People (6)

Name Role Context
Bennet J. Moskowitz Attorney
Counsel for Defendants (Troutman Sanders LLP)
Alison J. Nathan Judge
United States District Judge, SDNY
Darren K. Indyke Co-Executor
Co-Executor of the Estate of Jeffrey E. Epstein
Richard D. Kahn Co-Executor
Co-Executor of the Estate of Jeffrey E. Epstein
Jeffrey E. Epstein Deceased
Estate mentioned as defendant
VE Plaintiff
Plaintiff in the case VE v. Nine East 71st Street (pseudonym)

Organizations (6)

Name Type Context
Troutman Sanders LLP
Law firm representing Defendants
Estate of Jeffrey E. Epstein
Defendant
Nine East 71st Street Corporation
Defendant
Financial Trust Company, Inc.
Defendant
NES, LLC
Defendant
United States District Court
Southern District of New York

Timeline (3 events)

2019-11-14
Judge Nathan orders the extension but notes 'No further extensions'.
SDNY Courthouse
2019-11-29
New deadline for Defendants to respond to Complaint.
Court
2019-12-06
Initial Pretrial Conference scheduled.
Court

Locations (2)

Location Context
Address of Troutman Sanders LLP
Address of Thurgood Marshall United States Courthouse

Relationships (3)

Co-Executors of the Estate of Jeffrey E. Epstein
Co-Executors of the Estate of Jeffrey E. Epstein
Bennet J. Moskowitz Legal Counsel Darren K. Indyke
We represent Darren K. Indyke...

Key Quotes (3)

"No further extensions"
Source
029.pdf
Quote #1
"Plaintiff's counsel does not consent to this request, stating: 'I cannot agree to extend your time to respond any further and cannot agree to postpone the conference.'"
Source
029.pdf
Quote #2
"We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein"
Source
029.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (1,982 characters)

Case 1:19-cv-07625-AJN-DCF Document 29 Filed 11/14/19 Page 1 of 1
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutman.com
Bennet J. Moskowitz
bennet.moskowitz@troutman.com
[Stamp: USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: NOV 1 4 2019]
November 12, 2019
ECF
Hon. Alison J. Nathan
Thurgood Marshall
United States Courthouse
40 Foley Square
New York, NY 10007
Re: VE v. Nine East 71st Street, et al., 1:19-cv-07625 (AJN)
Dear Judge Nathan:
We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (incorrectly named herein as "Joint Personal Representatives" of the Estate of Jeffrey E. Epstein), Nine East 71st Street, Corporation, Financial Trust Company, Inc., and NES, LLC (together, "Defendants") in the referenced action. We write to respectfully request a two week extension of Defendants' time to answer, move or otherwise respond to Plaintiff's Complaint, from November 15, 2019 to November 29, 2019. [Handwritten: SO ORDERED] The Initial Pretrial Conference is scheduled for December 6, 2019. The requested extension would not affect any other scheduled dates in this action.
This is the first request for an extension of this deadline. The Court previously So Ordered the parties' agreement whereby we accepted service of Plaintiff's Complaint and setting the November 15 response deadline (ECF #21).
Plaintiff's counsel does not consent to this request, stating: "I cannot agree to extend your time to respond any further and cannot agree to postpone the conference." However, as explained above, this is the first request to extend the November 15 deadline; and we do not request an adjournment of the Initial Pretrial Conference.
Thank you for your attention to this matter.
Respectfully submitted,
s/Bennet J. Moskowitz
Bennet J. Moskowitz
[Handwritten: No further extensions]
[Handwritten: SO ORDERED: 11/14/19]
[Signature]
HON. ALISON J. NATHAN
UNITED STATES DISTRICT JUDGE

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