037.pdf
240 KB
Extraction Summary
8
People
3
Organizations
2
Locations
2
Events
3
Relationships
2
Quotes
Document Information
Type:
Legal correspondence / court filing
File Size:
240 KB
Summary
A letter dated April 13, 2020, from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Debra C. Freeman. The letter represents the Co-Executors of the Estate of Jeffrey E. Epstein (Indyke and Kahn) in lawsuits brought by Jane Doe 15, Mary Doe, and Teala Davies. It requests a 30-day extension for various discovery and filing deadlines due to the COVID-19 pandemic, noting that the Plaintiffs have consented to this request.
People (8)
| Name | Role | Context |
|---|---|---|
| Bennet J. Moskowitz | Attorney |
Author of the letter, representing Defendants (Co-Executors) from Troutman Sanders LLP.
|
| Debra C. Freeman | Judge |
Honorable Judge addressed in the letter.
|
| 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 executed.
|
| Jane Doe 15 | Plaintiff |
Plaintiff in case 1:19-cv-10653-PAE-DCF.
|
| Mary Doe | Plaintiff |
Plaintiff in case 1:19-cv-10758-PAE-DCF.
|
| Teala Davies | Plaintiff |
Plaintiff in case 1:19-cv-10788-GHW-DCF.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Troutman Sanders LLP |
Law firm representing the Defendants.
|
|
| United States Courthouse |
Court location at 500 Pearl Street.
|
|
| Estate of Jeffrey E. Epstein |
Legal entity represented by the Co-Executors.
|
Timeline (2 events)
2020-02-11
Previous Court Order setting deadlines.
New York
Locations (2)
| Location | Context |
|---|---|
|
Address of the United States Courthouse.
|
|
|
Address of Troutman Sanders LLP.
|
Relationships (3)
Co-Executors of the Estate of Jeffrey E. Epstein
Co-Executors of the Estate of Jeffrey E. Epstein
We represent Defendants Darren K. Indyke and Richard D. Kahn
Key Quotes (2)
"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... by thirty (30) days"Source
037.pdf
Quote #1
"the deadline for the completion of fact discovery be extended from June 10, 2020 to July 10, 2020"Source
037.pdf
Quote #2
Full Extracted Text
Complete text extracted from the document (2,146 characters)
Case 1:19-cv-10788-GHW-DCF Document 37 Filed 04/13/20 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
D: 212-704-6000
bennet.moskowitz@troutman.com
D: 212-704-6000
bennet.moskowitz@troutman.com
April 13, 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: Jane Doe 15, 1:19-cv-10653-PAE-DCF; Mary Doe, 1:19-cv-10758-PAE-DCF; Teala Davies, 1:19-cv-10788-GHW-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 15, Mary Doe and Teala Davies (together, “Plaintiffs,” and together with the Co-Executors, the “Parties”). 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:
• 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 Co-Executors’ rebuttal reports be extended from July 10, 2020 to August 10, 2020; and
Case 1:19-cv-10788-GHW-DCF Document 37 Filed 04/13/20 Page 2 of 2
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• 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)
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