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      Case 1:19-cv-10788-GHW-DCF            Document 38       Filed 04/14/20     Page 1 of 2
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
                                                                              troutmariP
troutman.com
                                                                                sanders
Bennet J. Moskowitz
D: 212-704-6000
bennet.moskowitz@troutman.com                            MEMORANDUM ENDORSED


                                                             April 13, 2020

VIA ELECTRONIC COURT FILING

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

Re:       Jane Doe 15, 1:19-cv-10653-PAE-DCF; Mary Doe, 1:19-cv-10758-PAE-DCF; Teala
          Davies, 1:19-cv-10788-GHW-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 15, Mary Doe and Teala Davies (together, “Plaintiffs,” and together with the Co-
Executors, the “Parties”). In light of the ongoing pandemic and the various difficulties it has
presented, we write with Plaintiffs’ consent to request that the Court extend the remaining
deadlines in the above-refenced 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

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