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Case 1:19-cv-07625-AJN-DCF Document 27 Filed 11/12/19 Page 1 of 1
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutmariP
troutman.com
sanders
Bennet J. Moskowitz
bennet.moskowitz@troutman.com
November 12, 2019
ECF
Hon. Alison J. Nathan
Thurgood Marshall
United States Courthouse
40 Foley Square
New York, NY 10007
Re: VE v. Nine East 71st Street, et al., 1:19-cv-07625 (AJN)
Dear Judge Nathan:
We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of
Jeffrey E. Epstein (incorrectly named herein as “Joint Personal Representatives” of the Estate of
Jeffrey E. Epstein), Nine East 71st Street, Corporation, Financial Trust Company, Inc., and
NES, LLC (together, “Defendants”) in the referenced action. We write to respectfully request a
two week extension of Defendants’ time to answer, move or otherwise respond to Plaintiff’s
Complaint, from November 15, 2019 to November 29, 2019. The Initial Pretrial Conference is
scheduled for December 6, 2019. The requested extension would not affect any other
scheduled dates in this action.
This is the first request for an extension of this deadline. The Court previously So
Ordered the parties’ agreement whereby we accepted service of Plaintiff’s Complaint and
setting the November 15 response deadline (ECF #21).
Plaintiff’s counsel does not consent to this request, stating: “I cannot agree to extend
your time to respond any further and cannot agree to postpone the conference.” However, as
explained above, this is the first request to extend the November 15 deadline; and we do not
request an adjournment of the Initial Pretrial Conference.
Thank you for your attention to this matter.
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