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Case 9:10-cv-80309-KAM Document 6 Entered on FLSD Docket 03/25/2010 Page 1 of 3 JANE DOE No. 103, vs. JEFFERY EPSTEIN, UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 10-80309-CIV-Marra/Johnson Plaintiff, Defendant. ___________ / DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND 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, February 23, 2010. Defendant seeks an extension until April 5, 2010, to file his response. As good cause in support of granting the motion, Defendant states: 1. On February 23, 2010 Plaintiff filed a Complaint [DE l]. Defendant's response would be due on March 26, 2010. 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 and replies to various motions, and handling other matters associated therewith. 3. The requested extension is fair in 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 Plaintiffs counsel is in agreement with the requested extension. 1 Case 9:10-cv-80309-KAM Document 6 Entered on FLSD Docket 03/25/2010 Page 2 of 3 WHEREFORE Defendant respectfully requests that this Court enter an order granting an extension until April 5, 2010 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 April 5, 2010 for Defendant to respond to Plaintiff's Complaint. Isl Michael J. Pike Robert D. Critton, Attorney for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CMIECF. 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 CMIECF on this 23 rd day of March, 2010. 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 A venue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jagesg@bellsouth.net Counsel/or Defendant Jeffrey Epstein Respectfully submitted, By: Isl Michael J. Pike ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 rcrit@bclclaw.com 2 Case 9:10-cv-80309-KAM Document 6 Entered on FLSD Docket 03/25/2010 Page 3 of 3 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) 3