006.pdf

Case 9:09-cv-80802-KAM Document 6 Entered on FLSD Docket 07/07/2009 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CV-80802-MARRA-JOHNSON JANE DOE NO. 8 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 28, 2009 [DE0J.]. Defendant seeks an extension until July 14, 2009, to file his response. As good cause in support of granting the motion, Defendant states: 1. On May 28, 2009 Plaintiff filed a Complaint [DE 1]. Defendant's response wonld be due on July 7, 2009. 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 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-80802-KAM Document 6 Entered on FLSD Docket 07/07/2009 Page 2 of 3 Jane Doe No. 8 v. Epstein Page2 WHEREFORE Defendant respectfully requests that this Court enter an Order granting an extension until July 14, 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 Coun5el for Plaintiff is in agreement wi e requested extension until July 14, RQ on, Esq. At orney efendant 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 7 th day of July. 2009: Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. 18205 Biscayne Boulevard Suite 2218 Miami,FL33160 0 305-931-2200 Fax:305-931-0877 ahorowi tz@hermanlaw.com lrivera@hermanlaw.com Counsel for Plaint/ff Jane Doe #8 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian A venue 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-80802-KAM Document 6 Entered on FLSD Docket 07/07/2009 Page 3 of 3 Jane Doe No. 8 v. Epstein Page3 Respectfully submitted, BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 515 N. Flagler Drive, Suite 400 West Palm Beach FL 33401 (561) 842-2 20 Michael J. Pike Florida Bar #617296 Counsel for Defendant Jeffrey Epstein rcrit@bclclaw.com mpike@bclclaw.com