Case 9:09-cv-80802-KAM

Document 6

Entered on FLSD Docket 07/07/2009

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# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

# CASE NO.: 09-CV-80802-MARRA-JOHNSON

JANE DOE NO. 8
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 28, 2009 [DE0J.]. Defendant seeks an extension until July 14, 2009, to file his response. As good cause in support of granting the motion, Defendant states:

1. On May 28, 2009 Plaintiff filed a Complaint [DE 1]. Defendant's response wonld be due on July 7, 2009.

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 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 Plaintiff's counsel is in agreement with the requested extension.

Case 9:09-cv-80802-KAM

Document 6

Entered on FLSD Docket 07/07/2009

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Jane Doe No. 8 v. Epstein

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WHEREFORE Defendant respectfully requests that this Court enter an Order granting an extension until July 14, 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 14, 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 7th day of July. 2009:

| Stuart S. Mermelstein, Esq.       | Jack Alan Goldberger, Esq.            |
|-|-|
| Adam D. Horowitz, Esq.            | Atterbury Goldberger & Weiss, P.A.    |
| 18205 Biscayne Boulevard          | 250 Australian Avenue South           |
| Suite 2218                        | Suite 1400                            |
| Miami,FL33160 <br />0             | West Palm Beach, FL 33401-5012        |
| 305-931-2200                      | 561-659-8300                          |
| Fax:305-931-0877                  | Fax: 561-835-8691                     |
| ahorowi tz@hermanlaw.com          | jagesq@bellsouth.net                  |
| lrivera@hermanlaw.com             | Counsel for Defendant Jeffrey Epstein |
| Counsel for Plaint/ff Jane Doe #8 |                                       |

Case 9:09-cv-80802-KAM

Document 6

Entered on FLSD Docket 07/07/2009

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Jane Doe No. 8 v. Epstein

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Respectfully submitted,
BURMAN, CRITTON, LUTTIER
& COLEMAN, LLP
515 N. Flagler Drive, Suite 400
West Palm Beach, FL 33401
(561) 842-2820
By: <signature>
Robert D. Critton, Jr.
Florida Bar #224162
Michael J. Pike
Florida Bar #617296
Counsel for Defendant Jeffrey Epstein
rcrit@bcclaw.com
mpike@bcclaw.com
documents/doj-f5919869488248f2.pdf
{}