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) (DCFI

Dear Judge Freeman:

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)