Bennet J. Moskowitz bennelmoskowitz©troutman.com¶
September 10, 2021¶
VIA ECF¶
Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007¶
Re: Jane Doe v. Darren'. Indyke and Richard D. Kahn, in their capacities as the Executors of the Estate of Jeffrey E. Epstein, 1:20-cv-02365-LJL-DCF¶
Dear Judge Freeman:¶
We represent Defendants Darren Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, in the referenced action. We write jointly with Plaintiff to report that the parties are attempting to resolve this matter extrajudicially. Accordingly, to preserve the parties' resources and in the interest of judicial economy, the parties respectfully request that the Court enter a sixty-day stay of this action, through November 9, 2021. Should the parties resolve Plaintiffs claims through settlement, they will thereafter promptly discontinue this action with prejudice.¶
Respectfully submitted,¶
/s/ Bennet J. Moskowitz¶
Bennet J. Moskowitz¶
cc: Counsel of Record (via ECF)¶