Case 1:19-cv-08673-KPF-DCF Document 71 KAPLAN HECKER & FINK LLP Filed 06/11/20 350 FIFTH AVENUE Page 1 of 4 I SUITE 7110 NEW YORK, NEW YORK 10118 TEL (212) 763-0883 I FAX (212) 564-0883 WWW.KAPLANHECKER.COM DIRECT DIAL 929.294.2528 DIRECT EMAIL [email protected] June 11, 2020 VIA ECF Hon. Jullgthreeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007 Re: Doe v. Indyke el at, No. I 9-cv-8673-KPF (S.D.N.Y.) Dear Judge Freeman: We write in response to Defendants' Letter of June 9, 2020 ("Defendants' Letter") requesting a 30-day extension of all remaining deadlines in the above-referenced action (Doc. No. 70). Defendants' Letter blatantly mischaracterizes both the status of discovery in this matter and the discussions between the parties leading to the instant dispute. In fact, Defendants waited until June 8, 2020 (the "June 8 Email"), five weeks before the end of fact discovery, to inform Plaintiff that they plan to take nine previously-undisclosed non-party depositions and to demand that Plaintiff vastly expand her review of ESI by running 16 new search terms—and then informed Plaintiff that a blanket 30-day extension of all remaining case deadlines is necessary to allow the parties to complete this remaining work.' There is no cause for the extension Defendants now request, aside from their own egregious and deliberate delay. Accordingly, Plaintiff refused to consent to Defendants' blanket request. Plaintiff did, however, offer to discuss any specific scheduling issues with Defendants, including by scheduling a deposition outside of the fact discovery deadline if necessary, an offer to which Defendants did not even respond before seeking this Court's intervention. Background. As the Court is aware, discovery in this case commenced on January 20, 2020. (Doc. No. 16). In March, the parties exchanged initial interrogatories and requests for production of documents. Plaintiff also attempted to initiate discussions regarding E