Bennet J. Moskowitz bennet.moskowitz@troutman.com¶
September 18, 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 at, 1:19-cv-07625 (MN)¶
Dear Judge Nathan:¶
We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (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 the Court's approval of the parties' agreement described below.¶
On September 10, 2019, subject to the Court's approval: (1) we agreed to accept service of Plaintiff's First Amended Complaint (ECF #3) on Defendants' behalf; and (2) Plaintiff consented to Defendants having through November 15, 2019 to answer, move or otherwise respond to Plaintiff's First Amended Complaint. There have been no previous requests for adjournments or extensions of time in this action.¶
Thank you for your attention to this matter.¶
Respectfully submitted,¶
s/Bennet J Moskowitz Bennet J. Moskowitz¶