037.pdf

Case 9:08-cv-80994-KAM Document 37 Entered on FLSD Docket 05/05/2009 Page 1 of 3 JANE DOE NO. 6, V. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80994-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. -------------' DEFENDANT EPSTEIN'S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE REPLY TO PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO STAY Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his undersigned attorneys, respectfully moves this Court for an extension of time in which to file his Reply to Plaintiff's Response in Opposition to Defendant's Motion to Stay Complaint. 1. On April 23, 2009 Plaintiff filed a Response [DE 30] in Opposition to Defendant's Motion to Stay [DE 22]. Defendant's reply would be due on May 5, 2009 (5 days to reply excluding weekends + mailing). Defendant is requesting a fifteen (15) day extension to May 20, 2009 to reply. 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 handling other matters associated therewith. 3. Additionally, Defendant's counsel is in the midst of preparing for a state court trial, CARDIOPULMONARY & PRIMARY CARE ASSOC. OF TREASURE COAST, P.A v. LEWIS, M.D., Case No. 562008CA001726, specially set for trial beginning May 13 Case 9:08-cv-80994-KAM Document 37 Entered on FLSD Docket 05/05/2009 Page 2 of 3 Jane Doe No. 6 v. Epstein Page 2 through 15, 2009). Discovery in that case is ongoing with several depositions set to prepare for trial. 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 reply. 5. An extension until May 20, 2009, is fair and reasonable under the circumstances. The undersigned is in need of the additional time in order to fully and adequately prepare a response on behalf of EPSTEIN. 6. As certified below, counsel for Defendant conferred with counsel by e-mail, and Plaintiff's counsel is in agreement with the requested extension. WHEREFORE Defendant respectfully requests that this Court enter an order granting an extension until May 20, 2009, to file a Reply to Plaintiff's Response in Opposition to Defendant's Motion to Stay Complaint. Local Rule 7.1 Statement Counsel for the movant conferred by e-mail with counsel for the Plaintiff and Counsel for Plaintiff is in agreement with the requested extension until May 20, 2009 for Defendant to reply to Plaintiff's Response to Defendant's Motion o Complaint. Robe r. 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 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 5th day of May , 2009: Case 9:08-cv-80994-KAM Document 37 Entered on FLSD Docket 05/05/2009 Page 3 of 3 Jane Doe No. 6 v. Epstein Page3 Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ssm@sexabuseattorney.com ahorowitz@sexabuseattorney.com Counsel for Plaintiff Jane Doe #6 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 Co-Counsel for Defendant Jeffrey Epstein By: ROB~E~R-=-~=----------- Florida Bar o. 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 (Co-Counsel for Defendant Jeffrey Epstein)