Case 1:19-cv-11869-MKV-DCF Document 25 Filed 04/14/20 Page 1 of 2 troutmar? sanders Troutman Sanders LLP 875 Third Avenue New York, New York 10022 troutman.com Bennet J. Moskowitz D: 212-704-6000 bennet.moskowitz©iroutman.com April 14, 2020 VIA ELECTRONIC COURT FILING Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl Street New York, New York 10007 Re: VE, 1:19-cv-07625-AJN-DCF; Katlyn Doe, 1:19-cv-07771-PKC-DCF; Priscilla Doe, 1:19-cv-07772-ALC-DCF; Lisa Doe, 1:19-cv-07773-ER-DCF; Anastasia Doe, 1:19-cv11869-MKV-DCF Dear Judge Freeman: We represent Defendants in the above-referenced actions. In light of the ongoing pandemic and the various difficulties it has presented, we write with Plaintiffs' consent to request that the Court extend the remaining deadlines in the above-refenced actions, as set by this Court's Order dated February 11, 2020, by thirty (30) days, as follows: • the deadline for Plaintiffs to file any motions to amend the pleadings or to join any additional parties be extended from April 30, 2020 to June 1, 2020; • the deadline for the Parties to submit joint status reports to the Court, regarding discovery and the progress of settlement discussions, be extended from April 30, 2020 to June 1, 2020; • the deadline for the completion of fact discovery be extended from June 10, 2020 to July 10, 2020; • the deadline for service of Plaintiffs' expert reports be extended from June 10, 2020 to July 10, 2020; • the deadline for service of the Defendants' rebuttal reports be extended from July 10, 2020 to August 10, 2020; and • the deadline for the completion of expert discovery be extended from July 31, 2020 to August 31, 2020. EFTA02751794