UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶
CASE NO.: 09-80656-MARRa¶
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. Defendant seeks an extension until July 5, 2009, to file his response. As good cause in support of granting the motion, Defendant states:¶
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- On May 1, 2009 Plaintiff filed a Complaint [DE 1]. Defendant's response would be due on June 22, 2009, as previously agreed upon.
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- 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.
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- 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.
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- As certified below, counsel for Defendant conferred with counsel for Plaintiff, and Plaintiff's counsel is in agreement with the requested extension.
Doe 102 v. Epstein Page 2¶
WHEREFORE Defendant respectfully requests that this Court enter an order granting an extension until July 5, 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 Plai ieement with the requested extension until July 5, 2009 for Defendant to re. 'ntiff's Complaint.¶
Rob A Esq. ndant
¶
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 ja day of June, 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 riosefsbera@oodhurst.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 jauesq@bellsouth.net Counsel for Defendant Jeffrey Epstein¶
Respec !tted,¶
By: ROBE Florida Bar No. 2 rcrit bciclaw.com ON, JR., ESQ. 162¶
Doe 102 v. Epstein
Page 3¶
MICHAEL J. PIKE, ESQ.¶
Florida Bar #617296¶
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)¶