Court Records
Case 9:08-cv-80119-KAM Document 71 Entered on FLSD Docket 04/06/2009 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80119-MARRA
JANE DOE NO. 2,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
Defendant's Motion For Extension Of Time In Which To Respond To Plaintiffs
Motion For Protective Order And To Quash Subpoena For Deposition Of Jane Doe
No. 3, 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 Plaintiffs Motion For Protective Order And To Quash Subpoena For
Deposition Of Jane Doe No. 3, 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.
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Case 9:08-cv-80119-KAM Document 71 Entered on FLSD Docket 04/06/2009 Page 2 of 3
Jane Doe No. 2 v. Epstein
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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 extension until April 13, 2009 for
Defendant to respond to the Motion.
Rob
Attorney for
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
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Case 9:08-cv-80119-KAM Document 71 Entered on FLSD Docket 04/06/2009 Page 3 of 3
Jane Doe No. 2 v. Epstein
Page 3
served this day on all counsel of rei
manner specified by CM/ECF on this
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]
ssmasexabuseattorney.com
[Email Redacted]
Counsel for Plaintiff Jane Doe #2
rd identified on the following Service List in the
day of April, 2009:
Jack Alan Goldberger
Atterbury Goldberger & Weiss, P.A.
250 Australian Avenue South
Suite 1400
West Palm Beach, FL 33401-5012
[Phone Redacted]
Fax: [Phone Redacted]
jaaeseetellsouth.net
Co-Counsel for Defendant Jeffrey Epstein
Respe submitted,
By:
D. CRITTON, JR., ESQ.
Fl. ida Bar No. 224162
[Email Redacted]
MICHAEL J. PIKE, ESQ.
Florida Bar #617296
mpike 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
(Co-Counsel for Defendant Jeffrey Epstein)
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