059.pdf
380 KB
Extraction Summary
6
People
2
Organizations
2
Locations
5
Events
1
Relationships
2
Quotes
Document Information
Type:
Legal correspondence / court order
File Size:
380 KB
Summary
A legal letter from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Magistrate Judge Debra C. Freeman requesting a 30-day extension on various discovery and filing deadlines for multiple civil cases (including VE, Katlyn Doe, Priscilla Doe, etc.) due to the COVID-19 pandemic. The request was granted and 'So Ordered' by Judge Freeman on the same day, April 14, 2020.
People (6)
| Name | Role | Context |
|---|---|---|
| Bennet J. Moskowitz | Attorney |
Sender, representing Defendants (Troutman Sanders LLP)
|
| Debra C. Freeman | United States Magistrate Judge |
Recipient, endorsed the order
|
| Katlyn Doe | Plaintiff |
Named in case caption 1:19-cv-07771-PKC-DCF
|
| Priscilla Doe | Plaintiff |
Named in case caption 1:19-cv-07772-ALC-DCF
|
| Lisa Doe | Plaintiff |
Named in case caption 1:19-cv-07773-ER-DCF
|
| Anastasia Doe | Plaintiff |
Named in case caption 1:19-cv-11869-MKV-DCF
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Troutman Sanders LLP |
Law firm representing Defendants
|
|
| United States District Court |
Court handling the cases (implied by Judge Freeman's title and address)
|
Timeline (5 events)
2020-07-10
New deadline for completion of fact discovery and service of Plaintiffs' expert reports
Court
Locations (2)
| Location | Context |
|---|---|
|
Address of Troutman Sanders LLP
|
|
|
Address of Daniel Patrick Moynihan United States Courthouse
|
Relationships (1)
We represent Defendants in the above-referenced actions.
Full Extracted Text
Complete text extracted from the document (2,058 characters)
Case 1:19-cv-07625-AJN-DCF Document 59 Filed 04/14/20 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
MEMORANDUM ENDORSED
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 59 Filed 04/14/20 Page 2 of 2
April 14, 2020
Page 2
Page 2
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 14, 2020
SO ORDERED
DEBRA FREEMAN
United States Magistrate Judge
troutman
sanders
United States Magistrate Judge
troutman
sanders
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