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 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 December 15, 2009, to file his reply. As good cause in support of granting the motion, Defendant states:¶
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- On May 1, 2009, Plaintiff filed an Amended Complaint [DE 9].
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- On May 26, 2009, Defendant filed a Motion to Dismiss Amended Complaint [DE 29].
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- On June 26, 2009, Plaintiff filed her Response to Defendant's Motion to Dismiss Amended Complaint [DE 56].
Doe 101 v. Epstein Page 2¶
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The parties continue to work together to find a resolution in this case and are close to a resolution. In addition, parties have agreed to numerous extensions while negotiating a resolution.
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The implosion of the Rothstein Rosenfeldt & Adler, PA firm has raised certain questions for which defense counsel will request answers/information from Plaintiff's counsel regarding the Rothstein scheme/scandal prior to final resolution.
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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.
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As certified below, counsel for Defendant conferred with counsel for Plaintiff, and Plaintiffs counsel is not in agreement with the requested extension at this time.
WHEREFORE Defendant respectfully requests that this Court enter an Order granting an extension until December 15, 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 correspondence with counsel for the Plaintiff and Counsel for Plaintiff is not in agreement with e requested extension until December 15, 2009 for Defendant to respond to Plaintiff nt.¶
Robert D. Critt•n Jr., Esq. Attorney for D endant
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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¶
Doe 101 v. Epstein
Page 3¶
served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 2nd day of December, 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
rjosefsberg@podhurst.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
jagesq@bellsouth.net
Counsel for Defendant Jeffrey Epstein¶
Respectfully submitted,¶