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Case 1:19-cv-10577-LJL-DCF Document 53 Filed 05/14/20 Page 1 of 4
BSF
BOIES
SCH ILLER
FLEXNER
Sigrid S. McCawley
Telephone: (954) 377-4223
Email: smccawley@bsfllp.com
May 14, 2020
VIA ECF
The Honorable Debra Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Re: Jane Doe 1000 v. Darren K. Indyke & Richard D. Kahn, 19-10577-LJL-DCF
Dear Judge Freeman:
We submit on behalf of Plaintiff Jane Doe 1000 this reply in further support of her letter
motion for a conference to address Defendants’ failure to comply with their discovery obligations
(ECF No. 46), and in response to Defendants’ second letter in opposition, filed on May 13, 2020
(ECF No. 52). As an initial matter, the Court should disregard Defendants’ latest response as
untimely. Pursuant to Individual Rule 1.D., “[u]nless the Court orders otherwise, opposition to
any letter motion shall be filed within three (3) days of the moving letter.” Notwithstanding this
rule, Defendants filed an incomplete and non-substantive opposition on May 8, and requested
“permission to submit a response to the substantive issues raised in the Letters by May 13, 2020.”
ECF No. 47. Defendants’ letter did not comply with Individual Rule 1.B., which governs “requests
for adjournments or extensions of time.” In any event, the Court did not issue an order extending
Defendants’ time to respond, much less grant Defendants leave to file two oppositions as opposed
to one. But even if the Court were to consider Defendants’ untimely
[…]