038.pdf
420 KB
Extraction Summary
8
People
3
Organizations
2
Locations
2
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal letter motion / court order
File Size:
420 KB
Summary
A letter motion filed by attorney Bennet J. Moskowitz on behalf of the Co-Executors of Jeffrey Epstein's estate (Indyke and Kahn) requesting a 30-day extension on various court deadlines due to the pandemic. The request applies to cases involving plaintiffs Jane Doe 15, Mary Doe, and Teala Davies. The motion was endorsed and ordered by Magistrate Judge Debra Freeman on April 14, 2020.
People (8)
| Name | Role | Context |
|---|---|---|
| Bennet J. Moskowitz | Attorney |
Partner at Troutman Sanders LLP representing the Co-Executors; author of the letter.
|
| Debra C. Freeman | Judge |
United States Magistrate Judge who endorsed the order.
|
| Darren K. Indyke | Defendant/Co-Executor |
Co-Executor of the Estate of Jeffrey E. Epstein.
|
| Richard D. Kahn | Defendant/Co-Executor |
Co-Executor of the Estate of Jeffrey E. Epstein.
|
| Jeffrey E. Epstein | Deceased |
His estate is the subject of the representation by Indyke and Kahn.
|
| 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.
|
|
| Estate of Jeffrey E. Epstein |
Legal entity represented by the Co-Executors.
|
|
| United States District Court |
Court handling the cases (Southern District of New York implied by address).
|
Timeline (2 events)
2020-04-13
Bennet J. Moskowitz filed a letter motion requesting deadline extensions.
New York, NY
2020-04-14
Magistrate Judge Debra Freeman endorsed the memorandum, granting the requested extension.
New York, NY
Locations (2)
| Location | Context |
|---|---|
|
Address of Troutman Sanders LLP.
|
|
|
Daniel Patrick Moynihan United States Courthouse.
|
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
Full Extracted Text
Complete text extracted from the document (2,240 characters)
Case 1:19-cv-10788-GHW-DCF Document 38 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 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 38 Filed 04/14/20 Page 2 of 2
April 13, 2020
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troutman sanders
April 13, 2020
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troutman sanders
• 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)
April 14, 2020
SO ORDERED
SO ORDERED
DEBRA FREEMAN
United States Magistrate Judge
United States Magistrate Judge
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