Draft: efta02749693

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶

CASE NO.: 08-CIV-80119-MARRa¶

JANE DOE NO. 2,¶

Plaintiff,¶

vs.¶

JEFFREY EPSTEIN,¶

Defendant.¶

Related cases:¶

08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80893, 09-80469, 09-80802, 09-81092¶

DEFENDANT'S AGREED MOTION FOR EXTENSION OF TIME TO FILE REPLY TO JANE DOE AND DOES 2 -8 MEMORANDUM RESPONSE TO DEFENDANT'S RULE 4 APPEAL (DEs 551 & 552)¶

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 Jane Doe's and Does 2-8' Memorandum Response to Defendant's Consolidated Rule 4 Appeal dated May 28, 2010. Defendant seeks an extension until June 14, 2010, to file his Reply and Plaintiffs' are in agreement with the requested extension. As goo^d cause in support of granting the motion, Defendant states:¶

• I. Defendant filed his Appeal of Magistrate Judge Decision on May 12, 2010 (DE 545).
• 2. Plaintiffs filed their Memorandum Response to Defendant's Rule 4 Appeal on May 28, 2010 (Des 551 & 552).

3. As this Court is aware, the undersigned represents the Defendant in nine (9) other related cases before this Court and three (3) cases in State Court, as well as ^anewly filed case before Judge Gold. Defendant has filed numerous Motions, Responses and Replies in all of these cases, and has filed numerous pre-trial motions before this Court in order to comply with this Court's trial orders and deadlines. Further, Defendant has and continues to prepare for and take numerous depositions in each of these cases.

4. The undersigned will be out of town from June 4, 2010 and will return to the office on June 8, 2010. This is and has been a prearranged family vacation.

5. The requested extension is fair in reasonable under the circumstances as it will provide time to allow the Defendant, EPSTEIN, to fully and adequately Reply to the opposition motions.

6. Initially, counsel for Does 2-8 agreed to an extension up to June 17, 2010. However, counsel for Jane Doe objected. Therefore, counsel for Jane Doe agreed to an extension up to June 14, 2010. In good faith, the undersigned agreed to file the consolidated Reply as to Jane Doe and Does 2-8 on June 14, 2010.

WHEREFORE, Defendant requests that this Court enter an Order granting the Defendant an extension until June 14, 2010 in which to Reply to Jane Doe and Does 2-8' opposition motions.¶

Local Rule 7.1 Certification¶

Counsel for the movant conferred by electronic mail with counsel for the Plaintiffs and Counsel for the Plaintiffs is in agreement with the requested extension until June 14, 2010.¶

/s/ Michael J. Pike 12/1 I¶

Robert D. Critton, Jr.¶

Michael J. Pike¶

Attorneys 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 3^rd day of June, 2009¶

Respectfully submitted,¶

Florida Bar No. 224162¶

rcrit@bclclaw.com¶

MICHAEL J. PIKE, ESQ.¶

Florida Bar #617296¶

mpike@bclclaw.com¶

BURMAN, CRITTON, LUTTIER &¶

COLEMAN, LLP¶

303 Banyan Blvd., Suite 400¶

West Palm Beach, FL 33401¶

561/842-2820 Phone¶

561/515-3148 Fax¶

(Counsel for Defendant Jeffrey Epstein)¶

Certificate of Service¶

Jane Doe No. 2 v. Jeffrey Epstein¶

Stuart S. Mermelstein, Esq.¶

Adam D. Horowitz, Esq.¶

Mermelstein & Horowitz, P.A.¶

18205 Biscayne Boulevard¶

Suite 2218¶

Miami, FL 33160¶

305-931-2200¶

& Lehrman, PL¶

425 N. Andrews Avenue¶

Suite 2¶

Fort Lauderdale, FL 33301¶

Phone: 954-524-2820¶

Fax: 305-931-0877¶

ssm@sexabuseattorney.com¶

ahorowitz@sexabuseattorney.com¶

Counsel for Plaintiffs¶

In related Cases Nos. 08-80069, 08-80119,
08-80232, 08-80380, 08-80381, 08-80993,
08-80994¶

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¶

Counsel for Defendant Jeffrey Epstein¶

Fax: 954-524-2822¶

brad@pathtojustice.com¶

Counsel for Plaintiff in Related Case No.¶

08-80893¶

Paul G. Cassell, Esq.¶

Pro Hac Vice¶

332 South 1400 E, Room 101¶

Salt Lake City, UT 84112¶

801-585-5202¶

801-585-6833 Fax¶

cassellp@law.utah.edu¶

Co-counsel for Plaintiff Jane Doe¶

Isidro M. [REDACTED], Esq.¶

[REDACTED] Law Firm, P.A.¶

224 Datura Street, Suite 900¶

West Palm Beach, FL 33401¶

561-832-7732¶

561-832-7137 F¶

isidrogarcia@bellsouth.net¶

Counsel for Plaintiff in Related Case No.¶

08-80469¶