Case 9:09-cv-80656-KAM

Document 34

Entered on FLSD Docket 06/18/2009

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# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 09-80656-MARRA/JOHNSON

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:

1. On May 1, 2009 Plaintiff filed a Complaint [DE 1 ]. Defendant's response would be due on June 22, 2009, as previously agreed upon.

2. 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.

3. 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.

4. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and Plaintiff's counsel is in agreement with the requested extension.

Case 9:09-cv-80656-KAM

Document 34

Entered on FLSD Docket 06/18/2009

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Doe 102 v. Epstein

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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 Plaintiff is in agreement with the requested extension until July 5, 2009 for Defendant to respond to Plaintiff's Complaint.

<signature>
Robert D. Critton, Esq.
Attorney for 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~ 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
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
jagesg@bellsouth.net 
Counsel for Defendant Jeffrey Epstein

Respectfully submitted,
By: <signature>
ROBERT D. CRITTON, JR., ESQ.
Florida Bar No. 224162
rcrit@bclclaw.com

Case 9:09-cv-80656-KAM

Document 34

Entered on FLSD Docket 06/18/2009

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Doe 102 v. Epstein

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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)
documents/doj-5aeefe601430d8f4.pdf
{}