Court Records
Case 9:08-cv-80380-KAM Document 78 Entered on FLSD Docket 04/06/2009 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80380-MARRA
JANE DOE NO. 4,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
Defendant's Motion For Extension Of Time In Which To Respond To Plaintiffs
Motion For Protective Against Piecemeal Depositions Of Jane Doe. No.4, Motion
To Consolidate Cases For Purposes Of Discovery And Incorporated
Memorandum Of Law
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 Plaintiff's Motion For Protective Against Piecemeal Depositions Of Jane
Doe. No.4, Motion To Consolidate Cases For Purposes Of Discovery And Incorporated
Memorandum Of Law("Motion"). Local General Rule 7.1 A.1 and Rule 6, Fed. R. Civ. P.
(2009). Defendant seeks an extension until April 13, 2009 to file his response. As good
cause in support of granting the motion, Defendant states:
1. Defendant's response to the Motion is due on or about April 6, 2009.
2. Plaintiff's counsel also represents five (5) other Plaintiffs pursuing claims against
Defendant, EPSTEIN, most of which have filed similar Motions. In order to fully and
adequately respond to this and the other motions, Defendant is in need of an extension
until April 13, 2009.
EFTA02740905
Case 9:08-cv-80380-KAM Document 78 Entered on FLSD Docket 04/06/2009 Page 2 of 3
Jane Doe No. 4 v. Epstein
Page 2
3. In addition to the multiple motions, good cause for the extension also includes
that counsel has been attempting to resolve discovery issues in this and other cases
against Defendant, EPSTEIN; an associate of Defendant's undersigned counsel who
works extensively on this case is currently out of the office and the undersigned was
working on and has filed between 12-15 motions and responses in the various cases
during the time these motions were filed.
4. 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 to this
and the other motions. In addition, this action is still at its early stages.
5. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and
Plaintiffs counsel is in agreement with the requested extension.
WHEREFORE, Defendant requests that this Court enter an order granting an
Defendant an extension until April 13, 2009, in which to respond to the Above Motion.
Local Rule 7.1 Statement
Counsel for the movant conferred by telephone with counsel for the Plaintiff and
Counsel for Plaintiff is in agreement with the requested nsion until April 13, 2009 for
Defendant to respond to the Motion.
B
Certificate of Service
JR., ESQ.
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 die folio g Service List in the
manner specified by CM/ECF on this day of 2009:
EFTA02740906
Case 9:08-cv-80380-KAM Document 78 Entered on FLSD Docket 04/06/2009 Page 3 of 3
Jane Doe No. 4 v. Epstein
Page 3
Stuart S. Mermelstein, Esq.
Adam D. Horowitz, Esq.
Mermelstein & Horowitz, P.A.
18205 Biscayne Boulevard
Suite 2218
Miami, FL 33160
[Phone Redacted]
Fax: [Phone Redacted]
ssmasexabuseattornev.com
ahorowitze/sexabuseattornev.com
Counsel for Plaintiff Jane Doe #4
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]
jaqesqAbellsouth.net
Co-Counsel for Defendant Jeffrey Epstein
Respectfully ub
B
ROB ., ESQ.
Florida Bar No. 224 2
[Email Redacted]
MICHAEL J. PIKE, ESQ.
Florida Bar #617296
mpikeAbciclaw.com
BURMAN, CRITTON, LUTTIER & COLEMAN
515 N. Flagler Drive, Suite 400
West Palm Beach, FL 33401
561/842-2820 Phone
561/515-3148 Fax
(Co-Counsel for Defendant Jeffrey Epstein)
EFTA02740907