EFTA00028472.pdf

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Source set: data-set-8

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Case 1:19-cv-08673-KPF Document 21 Filed 11/06/19 Page 1 of 2
KAPLAN HECKER & FINK LLP
VIA ECF
The Honorable Katherine Polk Failla
United States District Court
Southern District of New York
Thurgood Marshall United States Courthouse
40 Foley Square
New York, NY 10007
350 FIFTH AVENUE I SUITE 7110
NEW YORK, NEW YORK 10118
TEL
I FAX
WWW.KAPLANHECKER,COM
November 6, 2019
Re: Doe v. lndyke et al., No. 19-cv-08673 (S.D.N.Y.) (KPF)
Dear Judge Failla:
We represent Jane Doe in the above-captioned action. We write in response to Defendants'
two letters filed yesterday regarding: (1) related case status (ECF 19); and (2) document
preservation (ECF 20).
Since we do not see any conceivable basis under Rule 13 of the Rules for the Division of
Business Among District Judges in the Southern District to oppose designating these cases with
overlapping defendants, legal issues, and factual allegations as related, we oppose Defendants'
request for 30 days to respond. See Local Rule for the Division of Business Among District Judges
in the Southern District 13(a); see also Poindexter v. Cash Money Records, No. 13-cv-5882, 2014
WL 1383781, at *2 (S.D.N.Y. Apr. 8, 2014); Pace v. Quintanilla, No. 13-cv-91, 2013 WL
5405563, at *5 (S.D.N.Y. Sept. 23, 2013). Our client was understandably shocked by the suicide
of Jeffrey Epstein in federal custody, and is eager to obtain a modicum of justice as soon as
possible. All we have seen from Defendants, however, are efforts at delay. We very much want
to push this case forward to trial as soon as possible, and it is essential to have a judge assigned
who will preside over the entire progress of the case in order to do so. I
Notably, contrary to the suggestion in Defendants' letter, Plaintiff is not seeking consolidation at this time.
We further note that the cases that Plaintiff has proposed as related have now all been reassigned to the same
magistrate judge, including: VE v. Nine East 71st Street et al., No. 19-cv-…

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