029.pdf
56.8 KB
Extraction Summary
5
People
2
Organizations
2
Locations
5
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal correspondence / letter motion
File Size:
56.8 KB
Summary
A legal letter dated March 16, 2020, from attorney Mariann Meier Wang to Judge Debra Freeman in the case Davies v. Indyke et al. The letter requests a one-week extension for briefing deadlines regarding a motion to dismiss, citing disruptions caused by COVID-19 response measures. Opposing counsel Bennet J. Moskowitz consented to the request.
People (5)
| Name | Role | Context |
|---|---|---|
| Mariann Meier Wang | Attorney |
Author of the letter, representing Plaintiff Teala Davies; partner at Cuti Hecker Wang LLP
|
| Debra Freeman | Judge |
Honorable Magistrate Judge, recipient of the letter
|
| Teala Davies | Plaintiff |
Client represented by Mariann Meier Wang in the case Davies v. Indyke et al.
|
| Indyke | Defendant |
Main named defendant in the case title (Darren Indyke, executor of Epstein estate)
|
| Bennet J. Moskowitz | Attorney |
Counsel for Defendants; consented to the extension request
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Cuti Hecker Wang LLP |
Law firm representing the Plaintiff
|
|
| U.S. District Court for the Southern District of New York |
Court where the case is being heard
|
Timeline (5 events)
2020-02-28
2020-03-20
Locations (2)
| Location | Context |
|---|---|
|
Address of Cuti Hecker Wang LLP
|
|
|
Address of the U.S. District Court (Daniel Patrick Moynihan United States Courthouse)
|
Relationships (3)
We represent Plaintiff Teala Davies.
Bennet J. Moskowitz, counsel for Defendants
We have conferred with Bennet J. Moskowitz... and he consents to this extension.
Key Quotes (3)
"We represent Plaintiff Teala Davies."Source
029.pdf
Quote #1
"This extension of time is needed due to challenges arising from COVID-19 response measures, including school and office closures."Source
029.pdf
Quote #2
"We have conferred with Bennet J. Moskowitz, counsel for Defendants, and he consents to this extension."Source
029.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (1,513 characters)
CUTI HECKER WANG LLP
305 BROADWAY, SUITE 607
NEW YORK, NY 10007
305 BROADWAY, SUITE 607
NEW YORK, NY 10007
MARIANN MEIER WANG
212.620.2603 TEL
212.620.2613 FAX
MWANG@CHWLLP.COM
212.620.2603 TEL
212.620.2613 FAX
MWANG@CHWLLP.COM
March 16, 2020
By ECF
Hon. Debra Freeman
U.S. District Court for the Southern District of New York
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Hon. Debra Freeman
U.S. District Court for the Southern District of New York
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Re: Davies v. Indyke et al., 19-cv-10788 (GHW)(DCF)
Your Honor:
We represent Plaintiff Teala Davies. With the consent of all parties,
we write respectfully to request a one-week extension of the briefing deadlines for
the Defendants’ pending motion to dismiss (ECF 26).
we write respectfully to request a one-week extension of the briefing deadlines for
the Defendants’ pending motion to dismiss (ECF 26).
Plaintiff’s opposition papers are currently due on March 20 and
Defendants’ reply papers are currently due on March 30. We request a one-week
extension of both of those deadlines, so that Plaintiff’s opposition papers would be
due on March 27 and Defendants’ reply papers would be due on April 7. This
extension of time is needed due to challenges arising from COVID-19 response
measures, including school and office closures.
Defendants’ reply papers are currently due on March 30. We request a one-week
extension of both of those deadlines, so that Plaintiff’s opposition papers would be
due on March 27 and Defendants’ reply papers would be due on April 7. This
extension of time is needed due to challenges arising from COVID-19 response
measures, including school and office closures.
We have conferred with Bennet J. Moskowitz, counsel for Defendants,
and he consents to this extension. This extension would not affect any other
deadlines in this case. No previous extension of time has been requested since Your
Honor entered the parties’ proposed briefing schedule on February 28, 2020 (ECF
25).
and he consents to this extension. This extension would not affect any other
deadlines in this case. No previous extension of time has been requested since Your
Honor entered the parties’ proposed briefing schedule on February 28, 2020 (ECF
25).
We appreciate Your Honor’s attention to this matter.
Very truly yours,
/s/ Mariann Meier Wang
Mariann Meier Wang
cc: Bennet J. Moskowitz, Counsel for Defendants (by ECF)
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