Court Records
Case 9:09-cv-80591-ICAM Document 87 Entered on FLSD Docket 12/02/2009 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-80591-MARRA/ JANE DOE No. 101, Plaintiff, v. JEFFREY EPSTEIN, Defendant, DEFENDANT JEFFREY EPSTEIN'S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE A REPLY TO PLAINTIFF JANE DOE 101'S RESPONSE TO DEFENDANT'S MOTION TO DISMISS AMENDED COMPLAINT Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his undersigned attorneys, respectfully moves this Court for an extension of time in which to reply to Plaintiff, Jane Doe 101's Response to Defendant, Epstein's Motion to Dismiss Amended Complaint [DE 56] dated June 26, 2009. Defendant seeks an extension until December 15, 2009, to file his reply. As good cause in support of granting the motion, Defendant states: 1. On May 1, 2009, Plaintiff filed an Amended Complaint [DE 9]. 2. On May 26, 2009, Defendant filed a Motion to Dismiss Amended Complaint [DE 29]. 3. On June 26, 2009, Plaintiff filed her Response to Defendant's Motion to Dismiss Amended Complaint [DE 56]. EFTA02738728 Case 9:09-cv-80591-KAM Document 87 Entered on FLSD Docket 12/02/2009 Page 2 of 3 Doe 101 v. Epstein Page 2 4. The parties continue to work together to find a resolution in this case and are close to a resolution. In addition, parties have agreed to numerous extensions while negotiating a resolution. 5. The implosion of the Rothstein Rosenfeldt & Adler, PA firm has raised certain questions for which defense counsel will request answers/information from Plaintiff's counsel regarding the Rothstein scheme/scandal prior to final resolution. 6. The requested extension is fair and reasonable under the circumstances as it will provide time to allow the Defendant, EPSTEIN, to fully and adequately respond. 7. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and Plaintiffs counsel is not in agreement with the requested extension at this time. WHEREFORE Defendant respectfully requests that this Court enter an Order granting an extension until December 15, 2009, to file a Reply to Plaintiffs Response to Defendant's Motion to Dismiss Amended Complaint. Local Rule 7.1 Statement Counsel for the movant conferred by correspondence with counsel for the Plaintiff and Counsel for Plaintiff is not in agreement with e requested extension until December 15, 2009 for Defendant to respond to Plaintiff nt. Robert D. Critt•n Jr., Esq. Attorney for D endant Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being EFTA02738729 Case 9:09-cv-80591-KAM Document 87 Entered on FLSD Docket 12/02/2009 Page 3 of 3 Doe 101 v. Epstein Page 3 served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 2nd day of December, 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 [Phone Redacted] Fax: [Phone Redacted] riosefsbergApodhurst.com kezellApodhurst.com Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 [Phone Redacted] Fax: [Phone Redacted] Laqescabellsouth.net Counsel for Defendant Jeffrey Epstein Respectfully subm' d, By: ROBERT D. ,CRITTON, JR., ESQ. Florida Bar o. 224162 rcrit(abcIclaw.corn MICHAEL J. PIKE, ESQ. Florida Bar No. 617296 mpike(a.bciclaw.com BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561/842-2820 Phone 561/515-3148 Fax (Counsel for Defendant Jeffrey Epstein) EFTA02738730