Ctafte:19±9vcRigatifitPP-IbtF [ERRUiftilitatt Troutman Sanders LLP 875 Third Avenue New York, New York 10022 troutman.com Bennet J. Moskowitz D: 212-704-6000 [email protected] June 19, 2020 VIA ELECTRONIC COURT FILING Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl Street New York, New York 10007 Re: PRXT ifcg 2 troutmar? sanders The proposed schedule is adopted, except that, as stated at the telephone conference held on 6/24/20, counsel are directed to work together in good faith to conserve resources, and may have until 8114/20 to complete the depositions contemplated by this schedule. The deadlines for the completion of expert discovery are extended as follows: Plaintiffs expert reports shall be served no later than August 14, 2020; Defendants' rebuttal reports shall be served no later than September 14, 202; expert discovery shall be completed no later than October 5, 2020. Dated: 6/24/2020 SO ORDERED ado( Jane Doe, 1:19-cv-8673 (KPF) (DC9 DEBRA FREEMAN United States Magistrate Judge Dear Judge Freeman: We write on behalf of both parties in the above-referenced action pursuant to the Court's Order dated June 15, 2020 (ECF No. 73). The parties have conferred and agreed on the following discovery schedule, without prejudice to their respective rights to object to or seek any and all discovery. • Substantial completion of document production: o July 3, 2020 • Proposed depositions to take place on the following dates: o o o o o o o o o o o • June 30, 2020 July 2, 2020 July 7, 2020 July 9, 2020 July 13, 2020 July 15, 2020 July 17, 2020 July 20, 2020 July 22, 2020 July 23, 2020 July 27, 2020 Plaintiff's Rule 35 examination to take place: o July 24, 2020 42545161v2 EFTA02751577