Case 1:19-cv-08673-KPF-DCF Document 70 Troutman Sanders LLP 875 Third Avenue New York, New York 10022 troutman.com Filed 06/10/20 Page 1 of 3 troutmai? sanders Bennet J. Moskowitz D: 212-704-6000 [email protected] June 10, 2020 VIA ELECTRONIC COURT FILING Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl Street New York, New York 10007 Re: Jane Doe. 1:19-cv-8673 (KPF) (DCF) Dear Judge Freeman: We represent Defendants in the above-referenced action. We write to request that the Court extend the remaining deadlines in the above-refenced action, as set by this Court's Order dated April 21, 2020, by thirty (30) days, as follows: • the deadline for completion of fact discovery be extended from July 10, 2020 to August 10, 2020; • the deadline for service of Plaintiff's expert report(s) be extended from July 10, 2020 to August 10, 2020; • the deadline for service of Defendants' rebuttal report[sj be extended from August 10, 2020 to September 10, 2020; and • the deadline for completion of expert discovery be extended from August 31, 2020 to September 30, 2020. This is the second request for an extension of these deadlines. The prior requested extension of these deadlines was made on consent and So Ordered by the Court on April 21, 2020 (ECF Doc. 69). Plaintiff's counsel has summarily rejected the instant request, stating, erroneously: "Your failure to appropriately pursue the discovery you now apparently believe you need is no basis for requesting another 30-day extension." EFTA02751346