Draft: efta02739098

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶

CASE NO.: 09-80656-MARRall¶

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 [DE 1]. Defendant seeks an extension until November 27, 2009, to file his response. As good cause in support of granting the motion, Defendant states:¶

• 1. On May 1, 2009 Plaintiff filed a Complaint [DE 1]. Defendant's response would be due on August 20, 2009, as previously agreed upon.
• 2. The parties continue to work together to potentially resolve this case and are close to a resolution.
• 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 Plaintiffs 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 November 27, 2009, to file a response to Plaintiffs 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 November 27, 2009 for Defendant to respond to Plaintiffs Complaint.¶

Robert D ritton Jr., Esq. Attorney r Defendant¶

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¶

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 riosefsbercapodhurst.com kezellApodhurst.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 jaqesqabellsouth.net Counsel for Defendant Jeffrey Epstein¶

Doe 102 v. Epstein
Page 3¶

Respectfully submitted,¶

By: _____¶

ROBERT D. CRITTON, JR., ESQ.¶

Florida Bar No. 224162¶

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¶

(Counsel for Defendant Jeffrey Epstein)¶