062.pdf

Case 9:09-cv-80656-KAM Document 62 Entered on FLSD Docket 12/02/2009 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-80656-MARRA/JOHNSON JANE DOE No. 102, Plaintiff, v. JEFFREY EPSTEIN, Defendant, ______________ / DEFENDANT JEFFREY EPSTEIN'S 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 [DE 1 ). Defendant seeks an extension until December 15, 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 August 20, 2009, as previously agreed upon. 2. 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. 3. 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. Case 9:09-cv-80656-KAM Document 62 Entered on FLSD Docket 12/02/2009 Page 2 of 3 Doe 102 v. Epstein Page 2 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. 5. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and Plaintiff's counsel is in not agreement with the requested extension. WHEREFORE Defendant respectfully requests that this Court enter an Order granting an extension until December 15, 2009, to file a response to Plaintiff's 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 the requested extension until December 15, 2009 for Defendant to respond to Plaintiff's Complaint. Robert D. Critton r., Esq. Attorney for Def 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 2 nd 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 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Case 9:09-cv-80656-KAM Document 62 Entered on FLSD Docket 12/02/2009 Page 3 of 3 Doe 102 v. Epstein Page 3 305 358-2800 Fax: 305 358-2382 riosefsberg@podhurst.com kezell@podhurst.com Counsel for Plaintiff 561-659-8300 Fax: 561-835-8691 iagesq@bellsouth.net Counsel for Defendant Jeffrey Epstein By:---+-":::__ ____ _ ROBERT D CRITTON, JR., ESQ. Florida B No. 224162 rcrit@bclclaw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpike@bclclaw.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)