Case 9:10-cv-81111-WPD

Document 25

Entered on FLSD Docket 11/29/2010

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# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

Case No. 9:10-cv-81111-WPD

M.J.,
Plaintiff,
vs.
JEFFREY EPSTEIN and SARAH KELLEN,
Defendant.

## DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S MOTION FOR A PROTECTIVE ORDER BARRING DIRECT OR INDIRECT CONTACT BY EPSTEIN AND MOTION FOR PRESERVATION OF EVIDENCE RELATING TO CORRESPONDENCE WITH U.S. ATTORNEY'S OFFICE

Defendant Jeffrey Epstein, by and through undersigned counsel, respectfully moves for a ten (I 0) - day enlargement of time in which to respond to Plaintiffs Motion for a Protective Order Barring Direct or Indirect Contact by Epstein (D.E. 16) and Motion for Preservation of Evidence Relating to Correspondence with U.S. Attorney's Office (D.E. 17) and states as follows:

1. On October 11, 2010, Plaintiff filed a Motion for a Protective Order Barring Direct or Indirect Contact by Epstein (D.E. 16) and a Motion for Preservation of Evidence Relating to Correspondence with U.S. Attorney's Office (D.E. 17). Defendant's response to the foregoing motions is presently due on November 29, 2010.

2. The parties have recently been engaging in discussions to resolve the foregoing pending motions.

Case 9:10-cv-81111-WPD

Document 25

Entered on FLSD Docket 11/29/2010

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Case No. 9:10-cv-81111-WPD

3. The parties require an additional ten (10) days in which to resolve all matters pertaining to the pending motions.

4. In order to facilitate the resolution ofthe foregoing motions, and to avoid unnecessary attorney's fees and utilization ofjudicial resources, Defendant respectfully requests that this Court grant a I 0-day enlargement of time for Defendant to respond to the above-listed motions.

5. Pursuant to Local Rule 7.1, counsel for Defendant has conferred with opposing counsel, Gary Farmer, who has graciously advised that Plaintiff has no objection to the extension requested herein.

6. This enlargement is sought for the reasons stated and will not prejudice any party. WHEREFORE, Defendant Jeffrey Epstein respectfully requests that a 10-day enlargement of time be granted and that the Court grant such other and further relief as deemed necessary and proper.

Respectfully submitted,

s/Lilly Ann Sanchez
Lilly Ann Sanchez
Fla. Bar No. 195677
las@fowler-white.com 
Christopher E. Knight
Fla. Bar No. 607363
cknight@fowler-white.com 
Helaine S. Goodner
Fla. Bar No. 462111
hgoodner@fowler-white.com 
FOWLER WHITE BURNETT P.A.
Espirito Santo Plaza, 14th Floor
1395 Brickell Avenue
Miami, Florida 33131-3302
Telephone: (305) 789-9200

Case 9:10-cv-81111-WPD Document 25 Entered on FLSD Docket 11/29/2010 Page 3 of 4

Case No. 9:10-cv-81111-WPD

Facsimile: (305) 789-9201

Counsel for Defendant Jeffrey Epstein

## CERTIFICATE OF SERVICE

I hereby certify that on November 29, 2010, I electronically filed the foregoing document

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 or pro se parties identified on the attached Service List in the manner specified, either via transmission ofNotices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing.

s/Lilly Ann Sanchez

Lilly Ann Sanchez
Fla. Bar No. 195677

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Case 9:10-cv-81111-WPD Document 25 Entered on FLSD Docket 11/29/2010 Page 4 of 4

Case No. 9:10-cv-81111-WPD

# SERVICE LIST
M.J. v. Epstein
Case No. 9:10-cv-81111-WPD
United States District Court, Southern District of Florida

Bradley J. Edwards
brad@pathtojustice.com
Farmer, Jaffe, Weissing, Edwards
Fistos & Lehrman, PL
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Telephone: (954) 524-2820
Facsimile: (954) 524-2822
Attorneys for Plaintiff M.J.
Served via CM/ECF

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documents/doj-2b34b2226a057214.pdf
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