## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 09-80591-MARRa

JANE DOE No. 101,

Plaintiff,

v.

JEFFREY EPSTEIN,

Defendant,

## DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO FILE A REPLY TO PLAINTIFF JANE DOE 101'S RESPONSE TO DEFENDANT'S MOTION TO DISMISS AMENDED COMPLAINT

Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his undersigned attorneys, respectfully moves this Court for an extension of time in which to reply to Plaintiff, Jane Doe 101's Response to Defendant, Epstein's Motion to Dismiss Amended Complaint [DE 56] dated June 26, 2009. Defendant seeks an extension until November 27, 2009, to file his reply. As good cause in support of granting the motion, Defendant states:

- 1. On May 1, 2009, Plaintiff filed an Amended Complaint [DE 9].
- 2. On May 26, 2009, Defendant filed a Motion to Dismiss Amended Complaint [DE 29].
- 3. On June 26, 2009, Plaintiff filed her Response to Defendant's Motion to Dismiss Amended Complaint [DE 56].

Doe 101 v. Epstein Page 2

4. Defendant's Reply to Plaintiffs Response to Defendant's Motion to Dismiss Amended Complaint is currently due on November 16, 2009.

1. The parties continue to work together to find a resolution in this case and are close to a resolution.

1. 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.

1. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and Plaintiffs counsel is in agreement with the requested extension.

WHEREFORE Defendant respectfully requests that this Court enter an Order granting an extension until November 27, 2009, to file a Reply to Plaintiffs Response to Defendant's Motion to Dismiss Amended 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 agree ent with the requested extension until November 27, 2009 for Defendant to respon to Plaintiff's Complaint.

> Robert D. Critt n Jr., Esq. Attorney for D 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 16th day of November 2009

Doe 101 v. Epstein\
Page 3

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](mailto:rjosefsberg@podhurst.com)\
[kezell@podhurst.com](mailto: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](mailto:jagesq@bellsouth.net)\
*Counsel for Defendant Jeffrey Epstein*

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