Court Records
Case 9:09-cv-80656-KAM Document 34 Entered on FLSD Docket 06/18/2009 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-80656-MARRa JANE DOE No. 102, Plaintiff, v. JEFFREY EPSTEIN, Defendant, DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH SERVE RESPONSIVE PLEADING TO COMPLAINT Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his undersigned attorneys, respectfully moves this Court for an extension of time in which to respond to Complaint dated, May 1, 2009. Defendant seeks an extension until July 5, 2009, to file his response. As good cause in support of granting the motion, Defendant states: 1. On May 1, 2009 Plaintiff filed a Complaint [DE 1]. Defendant's response would be due on June 22, 2009, as previously agreed upon. 2. There are several other cases filed with this Court in which Jeffrey Epstein is named a Defendant. In those cases, the undersigned has been preparing responses to Motions for Protective Order and handling other matters associated therewith. 3. The requested extension is fair in reasonable under the circumstances as it will provide time to allow the Defendant, EPSTEIN, to fully and adequately respond. 4. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and Plaintiff's counsel is in agreement with the requested extension. EFTA02738976 Case 9:09-cv-80656-KAM Document 34 Entered on FLSD Docket 06/18/2009 Page 2 of 3 Doe 102 v. Epstein Page 2 WHEREFORE Defendant respectfully requests that this Court enter an order granting an extension until July 5, 2009, to file a response to Plaintiff's Complaint. Local Rule 7.1 Statement Counsel for the movant conferred by telephone and correspondence with counsel for the Plaintiff and Counsel for Plai ieement with the requested extension until July 5, 2009 for Defendant to re. 'ntiff's Complaint. Rob A Esq. ndant 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 served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this ja day of June, 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] [Email Redacted] [Email Redacted] 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] [Email Redacted] Counsel for Defendant Jeffrey Epstein Respec !tted, By: ROBE Florida Bar No. 2 rcrit bciclaw.com ON, JR., ESQ. 162 EFTA02738977 Case 9:09-cv-80656-KAM Document 34 Entered on FLSD Docket 06/18/2009 Page 3 of 3 Doe 102 v. Epstein Page 3 MICHAEL J. PIKE, ESQ. Florida Bar #617296 [Email Redacted] 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) EFTA02738978