058.pdf
198 KB
Extraction Summary
7
People
2
Organizations
2
Locations
3
Events
1
Relationships
2
Quotes
Document Information
Type:
Legal letter / court filing
File Size:
198 KB
Summary
This document is a letter dated April 14, 2020, from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Debra C. Freeman. It requests a 30-day extension for various legal deadlines in several cases filed by 'Doe' plaintiffs (VE, Katlyn, Priscilla, Lisa, Anastasia) against the Defendants, citing the ongoing pandemic as the reason. The request notes that it is made with the Plaintiffs' consent.
People (7)
| Name | Role | Context |
|---|---|---|
| Bennet J. Moskowitz | Attorney |
Sender, representing Defendants, from Troutman Sanders LLP
|
| Debra C. Freeman | Judge |
Recipient, Honorable Judge at United States Courthouse
|
| VE | Plaintiff |
Plaintiff in case 1:19-cv-07625-AJN-DCF
|
| Katlyn Doe | Plaintiff |
Plaintiff in case 1:19-cv-07771-PKC-DCF
|
| Priscilla Doe | Plaintiff |
Plaintiff in case 1:19-cv-07772-ALC-DCF
|
| Lisa Doe | Plaintiff |
Plaintiff in case 1:19-cv-07773-ER-DCF
|
| Anastasia Doe | Plaintiff |
Plaintiff in case 1:19-cv-11869-MKV-DCF
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Troutman Sanders LLP |
Law firm representing the Defendants
|
|
| United States District Court |
Southern District of New York (implied by address and Judge)
|
Timeline (3 events)
2020-04-14
Locations (2)
| Location | Context |
|---|---|
Relationships (1)
We represent Defendants in the above-referenced actions.
Key Quotes (2)
Full Extracted Text
Complete text extracted from the document (1,979 characters)
Case 1:19-cv-07625-AJN-DCF Document 58 Filed 04/14/20 Page 1 of 2
troutman
sanders
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutman.com
troutman
sanders
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutman.com
Bennet J. Moskowitz
D: 212-704-6000
bennet.moskowitz@troutman.com
D: 212-704-6000
bennet.moskowitz@troutman.com
April 14, 2020
VIA ELECTRONIC COURT FILING
Hon. Debra C. Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl Street
New York, New York 10007
Daniel Patrick Moynihan
United States Courthouse
500 Pearl Street
New York, New York 10007
Re: VE, 1:19-cv-07625-AJN-DCF; Katlyn Doe, 1:19-cv-07771-PKC-DCF; Priscilla Doe,
1:19-cv-07772-ALC-DCF; Lisa Doe, 1:19-cv-07773-ER-DCF; Anastasia Doe, 1:19-cv-
11869-MKV-DCF
1:19-cv-07772-ALC-DCF; Lisa Doe, 1:19-cv-07773-ER-DCF; Anastasia Doe, 1:19-cv-
11869-MKV-DCF
Dear Judge Freeman:
We represent Defendants in the above-referenced actions. 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:
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;
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
• the deadline for the completion of expert discovery be extended from July 31, 2020 to
August 31, 2020.
August 31, 2020.
Case 1:19-cv-07625-AJN-DCF Document 58 Filed 04/14/20 Page 2 of 2
April 14, 2020
Page 2
troutman
sanders
April 14, 2020
Page 2
troutman
sanders
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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