Troutman Sanders LLP 875 Third Avenue New York, New York 10022¶
troutman.osm¶
¶
Bennet J. Moskowitz¶
bennetmoskowitz@troutrnan.com¶
January 23, 2020¶
ECF¶
Hon. Koeltl Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312¶
Re: Jane Doe v. Darren K. lndyke and Richard D. Kahn, in their 8aidacities as co-executors of the Estate of Jeffrey E. Epstein, and Ghislaine Maxwell, 1:20-cv-00484-JGK¶
Dear Judge Koeltl:¶
We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors") in the above-referenced action. We write to respectfully request the Court's approval of the parties' agreement described below.¶
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On January 22, 2020, subject to the Court's approval: (1) we agreed to accept service of Plaintiffs Complaint (ECF #9) on the Co-Executors' behalf; (2) Plaintiff consented to the Co-Executors having through Mondays March 23, 2020 to answer, move or otherwise respond to Plaintiffs Complaint and Motion to Proceed by Pseudonym (ECF #5); and (3) the parties agreed to adjoum the initial case conference in this matter to a mutually agreeable time after the Co-Executors' deadline to respond to the Complaint. There have been no previous requests for adjoumments or extensions of time in this action.¶
Respectfully submitted,¶
/s/ Bennet J. Moskowitz Bennet J. Moskowitz¶
tJSCC SDNY DOCUMENT ELECTRONICALLY FILED DOC# DATE FILED: _ • '020;0¶