053.pdf

Case 9:09-cv-80656-KAM Document 53 Entered on FLSD Docket 10/29/2009 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 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 [DE 1 ]. Defendant seeks an extension until November 16, 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 potentially resolve this case. 3. 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. 4. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and Plaintiff's counsel is in agreement with the requested extension. Case 9:09-cv-80656-KAM Document 53 Entered on FLSD Docket 10/29/2009 Page 2 of 3 Doe 102 v. Epstein Page 2 WHEREFORE Defendant respectfully requests that this Court enter an Order granting an extension until November 16, 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 Plaintiff is in agreement with the requested extension until November 16, 2009 for Defendant tor pond to Plaintiff's Complaint. n Jr., Esq. fendant 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 29 th day of October, 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsberg@podhurst.com kezell@podhurst.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 561-659-8300 Fax: 561-835-8691 jagesq@bellsouth.net Counsel for Defendant Jeffrey Epstein Case 9:09-cv-80656-KAM Document 53 Entered on FLSD Docket 10/29/2009 Page 3 of 3 Doe 102 v. Epstein Page 3 Respe ull submitted, T . CRITTON, JR., ESQ. Flori a ar o. 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)