Michael C 212 506 3955 mmiller©steptoe.com¶
1114 Avenue of the Americas New York, NY 10036 212 506 3900 main www.steptoe.com¶
May 18, 2017¶
VIA ECF¶
Hon. John G. Koehl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312¶
Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616
¶
Dear Judge Koeltl:¶
¶
We are counsel to Defendants Jeffrey Epstein ("Epstein") and Lesley Groff ("Groff') in the above-referenced matter. We write to request that the conference with the Court currently scheduled for June 2, 2017 be ad* m for the reasons set forth below. We have been advised by counsel for Defendant that she joins in this application.¶
By way of background, on May 15, 2017, Defendants Epstein and Groff served a letter on counsel for the Plaintiff identifying the many fundamental bases which exist for dismissing the Plaintiff's Complaint. On the same day, Defendant served a letter on counsel for the Plaintiff identifying additional grounds for dismissing the Complaint. These letters were served pursuant to the schedule set forth in the Court's May 15, 2017 Stipulation and Order ("Scheduling Order").¶
After receiving these letters, counsel for Plaintiff advised the undersigned that Plaintiff is likely to amend her Complaint, instead of standing on the Complaint. Pursuant to the Scheduling Order, Plaintiff will have until June 5, 2017 to file an amended complaint. Defendants will have until June 19, 2017 to move to dismiss the amended complaint, and briefing on the motions to dismiss will be completed by August 2, 2017.¶
In light of the Court's issuance of the Scheduling Order and Plaintiff's obligation to serve an amended complaint on or before June 5, 2017, we respectfully request that the conference Hon. John G. Koeltl May 18, 2017 Page 2¶
¶
scheduled for June 2, 2017 be adjourned until after Plaintiff has served her amended complaint and preferably until briefing on the motions to dismiss has been completed. We respectfully believe that adjourning the conference until such time would make practical sense.¶
Respectfully submitted,¶
Michael C. Counsel for Defendants Jeffrey Epstein and Lesley Groff¶