Case 1:15-cv-07433-LAP Document 199 Filed 06/10/16 Page 1 of 8 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S MOTION TO EXTEND THE DEADLINE TO COMPLETE DEPOSITIONS Plaintiff by and through her undersigned counsel, hereby files this motion for a brief extension of time to complete pending depositions. has been actively working to complete discovery in this case. However, due to a number of circumstances beyond her control, she is unable to complete the necessary depositions by the close of discovery on June 30, 2016, and, therefore, requests an additional four (4) weeks to complete these depositions. She requests the deposition deadline be extended to July 30, 2016. The requested relief would not disturb the trial date. BACKGROUND As the Court knows, this case was filed in September 2015. The Court's original scheduling order set the completion of fact discovery for July 1, 2016. (See D.E. 13.) However, after the filing of the complaint, the Defendant moved to stay any discovery in the matter. Therefore, discovery did not commence until the Court directed Defendant to respond to discovery by February 2, 2016. Defendant did not respond to first requests for discovery until February 8, 2016, and only produced two documents. Defendant did not produce 1 EFTA02798071