EFTA00597906.pdf

ctithilifV6VEVkik B8E6VerCitz6 48TbRkiaitPpagf & 9' 2 114 Avail°e of the Americas New York NY 10036 main www.steptoe can VIA ECF Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 Dear Judge Koeltl: Steptoc . • ••••• •••-- II US% SONY il l DOCUMENT ELECTRONICALLY. PLED to , I DOC e: TiAT-: ..CATA12/i May 18, 2017 ADj(poitfte GD rft v04 an; C tvt7 nr Lt.; 30,0-1, So on-,9(0, ,/(17 Re: Jane Doc 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 We are counsel to Defendants Jeffrey Epstein ("Epstein) and "Groff") in the above-referenced matter. We write to request that the conference we t e ourt currently scheduled for June 2, 2017 be ad' owned for the reasons set forth below. We have been advised by counsel for Defendant that she joins in this application. By way of background, on May 15, 2017, Defendants Epstein and Groff served a letter on counsel for the Plaintiff identifying the many fundamental bases which exist for dismissing the Plaintiffs Complaint. On the same day. Defendant r served a letter on counsel for the Plainti ti identifying additional grounds for dismissing the Complaint. These letters were served pursuant to the schedule set forth in the Court's May 15, 2017 Stipulation and Order ("Scheduling Order). After receiving these letters, counsel for Plaintiff advised the undersigned that Plaintiff is likely to amend her Complaint, instead of standing on the Complaint. Pursuant to the Scheduling Order. Plaintiff will have until June 5, 2017 to tile an amended complaint. Defendants will have until June 19, 2017 to move to dismiss the amended complaint, and briefing on the motions to dismiss will be completed by August 2. 2017. In light of the Court's issuance of the Scheduling Order and Plaintiff's obligation to serve an amended complaint on or before June 5. 2017. we respectfully request that the conference EFTA00597906 lion. John G. Kock] May IR, 2017 Page 2 ctirsilifaWidk B8EURRtt.6 MW4API4/112-7PNO & 9f 2 Steptoe scheduled for June 2, 2017 be adjourned until after Plaintiff has served her amended complaint and preferably until briefing on the motions to dismiss has been completed. We respectfully believe that adjourning the conference until such time would make practical sense. Respectfully submitted, Michael C. Miller Counsel for Defendants Jeffrey Epstein and EFTA00597907