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)¶