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Florida Office¶
J. "Os Seth M. Lehrman tt Brittany N. Matthew D. Weissing¶
FILED VIA ECF¶
Magistrate Judge Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl St., New York, NY 10007 POTTINGER LLC__¶
425 North Andrews Avenue Suite 2 Fon Lauderdale, FL 33301¶
Telephone (954)524-2820 Fax (954)524-2822¶
January 10, 2020¶
Re: VE v. Nine East 71815treet et al., No. 19-cv-07625 (S.D.N.Y.) (Nathan, J.) Katlyn Doe v. Darren K Indyke et al., No. 19-cv-07771 (S.D.N.Y.) (Castel, J.) Pricilla Doe v. Darren K. Indyke et aL., No. 19-cv-07772 (S.D.N.Y.) (Carter, J.) Lisa Doe v. Darren K. Indyke et aL, No. 19-cv-07773 (S.D.N.Y.) (Ramos, J.) Anastasia Doe v. Darren K. Indyke, et at, No. 19-cv-11869 (S.D.N.Y.) (Nathan, J.)¶
Dear Judge Freeman:¶
New York Office J. Stanley Pottinger¶
Admitted in California 0 Admitted in Dome of Columbia • Admitted in Clinida 4 Admitted in New Vork Board Cvnifird Cavil Trial layer¶
We represent the five Plaintiffs referenced above whose cases have all been assigned to Your Honor. While we agree with Defendants' assertion that our discussions with the designers and administrator of the Epstein Victims' Compensation Program have been positive and productive, in our view, it remains important to every aspect of the process that our cases are not stayed and that they proceed accordingly.¶
As we explained during the Case Management Conference that was held on November 21, 2019, our clients have varying views of the process, and while each will maintain an open mind about potential alternative resolution, those who have filed lawsuits do not wish to delay the expeditious litigation of their claims.¶
We have and will continue to work with Mr. Moskowitz to ensure that we arrive at as many agreements as possible. Consequently, we agree with the following discovery schedule as proposed in his report: Plaintiffs and the Estate will make initial disclosures by January 23, 2020; the Parties will exchange proposed discovery plans by January 30, 2020; and the Parties will jointly submit to Your Honor a proposed discovery plan by February 6, 2020.¶
Respectfully Submitted,¶
J.¶