Court records
- Format
- Set
- Court Records
- Text
- Searchable
Text as released
Machine-read from the scan. Names, dates and numbers can be misread — check anything you rely on against the original page.
305 BROADWAY, SUITE 607
CUTI HECKER WANG LLP NEW YORK, NY 10007
MARIANN MEIER WANG
212.620.2603 TEL
212.620.2613 FAX
MWANG@CHWLLP.COM
May 11, 2020
By ECF
Hon. Debra Freeman
U.S. District Court for the Southern District of New York
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Re: Jane Doe 15 v. Indyke et al., 19-cv-10653 (PAE)(DCF)
Mary Doe v. Indyke et al., 19-cv-10758 (PAE)(DCF)
Davies v. Indyke et al., 19-cv-10788 (GHW)(DCF)
Your Honor:
We represent the plaintiffs in the three above-referenced cases. With
the consent of Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of
the Estate of Jeffrey E. Epstein (together, the “Co-Executors”), we write respectfully
to request that the Court extend the current discovery deadlines in these three
cases by ninety (90) days and the Co-Executors’ answer deadlines in the Jane Doe
15 and Mary Doe matters by thirty (30) days.
The COVID-19 pandemic continues to cause substantial difficulties for
all parties, and is inhibiting the parties’ ability to fully conduct discovery. In
addition, as Your Honor is aware, the parties are awaiting the approval by the
Superior Court of the Virgin Islands of a voluntary claims resolution program. If
that program is approved in the near future and quickly implemented, the plaintiffs
in these actions wish to participate in it, and the parties are hopeful that the
program might resolve the plaintiffs’ claims. As a result of this confluence of factors
– the substantial cha
[…]