027.pdf
26.1 KB
Extraction Summary
6
People
6
Organizations
3
Locations
3
Events
4
Relationships
3
Quotes
Document Information
Type:
Legal correspondence / court filing
File Size:
26.1 KB
Summary
A letter from attorney Bennet J. Moskowitz to Judge Alison J. Nathan dated November 12, 2019, requesting a two-week extension for the Defendants (Executors of Epstein's Estate and related entities) to respond to the Plaintiff's complaint in the case VE v. Nine East 71st Street, et al. The letter notes that Plaintiff's counsel refused to consent to the extension.
People (6)
| Name | Role | Context |
|---|---|---|
| Bennet J. Moskowitz | Attorney |
Attorney at Troutman Sanders LLP representing the Defendants, author of the letter.
|
| Alison J. Nathan | Judge |
Honorable Judge addressed in the letter regarding Case 1:19-cv-07625.
|
| Darren K. Indyke | Defendant / Co-Executor |
Co-Executor of the Estate of Jeffrey E. Epstein, represented by Moskowitz.
|
| Richard D. Kahn | Defendant / Co-Executor |
Co-Executor of the Estate of Jeffrey E. Epstein, represented by Moskowitz.
|
| Jeffrey E. Epstein | Deceased |
Mentioned as the deceased whose estate is being represented.
|
| VE | Plaintiff |
Plaintiff in the case VE v. Nine East 71st Street, et al.
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| Troutman Sanders LLP |
Law firm representing the Defendants.
|
|
| Estate of Jeffrey E. Epstein |
Legal entity represented by the Co-Executors Indyke and Kahn.
|
|
| Nine East 71st Street, Corporation |
Defendant company represented by Moskowitz.
|
|
| Financial Trust Company, Inc. |
Defendant company represented by Moskowitz.
|
|
| NES, LLC |
Defendant company represented by Moskowitz.
|
|
| United States District Court |
Implied by the address (Thurgood Marshall United States Courthouse).
|
Locations (3)
| Location | Context |
|---|---|
|
Address of Troutman Sanders LLP.
|
|
|
Court location.
|
|
|
Address of the Courthouse.
|
Relationships (4)
We represent Darren K. Indyke...
We represent... Richard D. Kahn...
Co-Executors of the Estate of Jeffrey E. Epstein
Co-Executors of the Estate of Jeffrey E. Epstein
Key Quotes (3)
"We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein"Source
027.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
027.pdf
Quote #2
"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."Source
027.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (1,742 characters)
Case 1:19-cv-07625-AJN-DCF Document 27 Filed 11/12/19 Page 1 of 1
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutman.com
troutman
sanders
Bennet J. Moskowitz
bennet.moskowitz@troutman.com
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. 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
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutman.com
troutman
sanders
Bennet J. Moskowitz
bennet.moskowitz@troutman.com
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. 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
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