Case 1:19-cv-10475-LGS-DCF Document 33 Filed 03/04/20 Haddon, Page 1 of 2 and Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 rx 303.832.2628 www.hmflaw.com [email protected] HADDON N March 4, 2020 Via ECF Hon. Lorna G. Schofield United States District Judge Thurgood Marshall United States Courthouse 40 Foley Square New York, New York 10007 Re: 19-cv-10475 (LGS-DCF), Request for Extension of Time v. Darren K. lndyke, et at, Dear Judge Schofield: On behalf of defendant Ghislaine Maxwell, I write to request a thirty-day extension of time to answer or otherwise respond in the above-captioned case, from March 6, 2020 to April 6, 2020. There have been no previous requests for extension of time. Counsel for Plaintiff objects, as described below; counsel for the Executors of the Estate of Jeffrey Epstein consent to Ms. Maxwell's request. On February 12, 2020, Magistrate Judge Debra Freeman authorized alternative service on Ms. Maxwell by provision of a copy of the Summons and Complaint by email to undersigned counsel, who serves as counsel of record in v. Maxwell, 15-cv-7433 (LAP) (S.D.N.Y.), as well as to an outdated email address of our client.' (ECF # 27) Plaintiff's counsel thereafter sent the required documents by email to undersigned counsel. Magistrate Freeman ordered that Ms. Maxwell answer or respond by March 6, 2020. Undersigned counsel was retained today to represent Ms. Maxwell in this matter. Although involved on Ms. Maxwell's behalf in the case from its inception in 2015 until its settlement in 2017, counsel's recent role has been to handle I Undersigned counsel was not served with a copy of Plaintiff's request for the alternate service when it was filed on January 27, 2020, and therefore did not participate in any hearing on the topic. Had undersigned counsel participated, we could have corrected inaccurate statements made to the court respecting Ms. Maxwell. EFTA02777846