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034_21

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          Case 1:19-cv-10476-PGG-DCF Document 34 Filed 04/15/20 Page 1 of 2
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
                                                                               troutmariP
troutman.com
                                                                                 sanders
Bennet J. Moskowitz
bennet.moskowitz@troutman.com




April 15, 2020

Via ECF

Hon. Debra C. Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007

Re:       Jane Doe 1000, 1:19-cv-10577-LJL-DCF; Teresa Helm, 1:19-cv-10476-PGG-DCF;
          Juliette Bryant, 1:19-cv-10479-ALC-DCF

Dear Judge Freeman:

We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of
Jeffrey E. Epstein (together, the “Co-Executors”), in the above-referenced actions commenced
by Jane Doe 1000, Teresa Helm and Juliette Bryant (together, “Plaintiffs”, and with the Co-
Executors, the “Parties”). In light of the ongoing pandemic and the various difficulties it has
presented for all parties, we write with the consent of Plaintiffs to request that the Court extend
the remaining deadlines in the above-referenced actions, as set by this Court’s Order dated
February 11, 2020, by thirty (30) days, as follows:

         the deadline for Plaintiffs to file any motions to amend the pleadings or to join any
          additional parties be extended from April 30, 2020 to June 1, 2020;

         the deadline for the Parties to submit joint status reports to the Court, regarding
          discovery and the progress of settlement discussions, be extended from April 30, 2020
          to June 1, 2020;

         the deadline for the completion of fact discovery be extended from June 10, 2020 to July
          10, 2020;

         the deadline for service of Plaintiffs’ expert reports be extended from June 10, 2020 to
          July 10, 2020;

         the deadline for service of the Defendants’ rebuttal reports be 

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