Bennet J. Moskowitz¶
D: 212-704-6000¶
bennet.moskowitz@troutman.com¶
April 21, 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) (DCF)¶
Dear Judge Freeman:¶
We represent Defendants in the above-referenced action. In light of the ongoing pandemic and the various difficulties it has presented, we write with Plaintiff's consent to request that the Court extend the remaining deadlines in the above-refenced action, as set by this Court's Order dated February 11, 2020, by thirty (30) days, as follows:¶
- the deadline for Plaintiff to file any motions to amend the pleadings or to join any additional parties be extended from April 30, 2020 to June 1, 2020;
- the deadline for the Parties to submit joint status reports to the Court, regarding discovery and the progress of settlement discussions, be extended from April 30, 2020 to June 1, 2020;
- the deadline for the completion of fact discovery be extended from June 10, 2020 to July 10, 2020;
- the deadline for service of Plaintiff's expert reports be extended from June 10, 2020 to July 10, 2020;
- the deadline for service of the Defendants' rebuttal reports be extended from July 10, 2020 to August 10, 2020; and
- the deadline for the completion of expert discovery be extended from July 31, 2020 to August 31, 2020.
This is the first request for an extension of these deadlines.¶
cc: Counsel of Record (via ECF)¶
Respectfully submitted,¶
s/Bennet J. Moskowitz Bennet J. Moskowitz¶