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Record

Draft: efta02751577

Bennet J. Moskowitz

D: 212-704-6000

bennet.moskowitz@troutman.com

June 19, 2020

VIA ELECTRONIC COURT FILING

Hon. Debra C. Freeman

Daniel Moynihan

United States Courthouse

500 Pearl Street

New York, New York 10007

Re: Jane Doe, 1:19-cv-8673 (KPF) (DC9

Dear Judge Freeman:

The proposed schedule is adopted, except that, as stated at the telephone conference held on 6/24/20, counsel are directed to work together in good faith to conserve resources, and may have until 8114/20 to complete the depositions contemplated by this schedule. The deadlines for the completion of expert discovery are extended as follows: Plaintiffs expert reports shall be served no later than August 14, 2020; Defendants' rebuttal reports shall be served no later than September 14, 202; expert discovery shall be completed no later than October 5, 2020.

Dated: 6/24/2020

SO ORDERED

ado( DEBRA FREEMAN United States Magistrate Judge

We write on behalf of both parties in the above-referenced action pursuant to the Court's Order dated June 15, 2020 (ECF No. 73). The parties have conferred and agreed on the following discovery schedule, without prejudice to their respective rights to object to or seek any and all discovery.

  • Substantial completion of document production: o July 3, 2020
  • Proposed depositions to take place on the following dates: o June 30, 2020 o July 2, 2020 o July 7, 2020 o July 9, 2020 o July 13, 2020 o July 15, 2020 o July 17, 2020 o July 20, 2020 o July 22, 2020 o July 23, 2020 o July 27, 2020
  • Plaintiff's Rule 35 examination to take place: o July 24, 2020

Respectfully submitted,

s/Bennet J. Moskowitz

Bennet J. Moskowitz

cc: Counsel of Record (via ECF)

Draft: efta02751577

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Prepared source

Bennet J. Moskowitz D: 212-704-6000 bennet.moskowitz@troutman.com June 19, 2020 VIA ELECTRONIC COURT FILING Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl Street New York, New York 10007 Re: Jane Doe, 1:19-cv-8673 (KPF) (DC9 Dear Judge Freeman: The proposed schedule is adopted, except that, as stated at the telephone conference held on 6/24/20, counsel are directed to work together in good faith to conserve resources, and may have until 8114/20 to complete the depositions contemplated by this schedule. The deadlines for the completion of expert discovery are extended …