Case 9:09-cv-80656-KAM

Document 48

Entered on FLSD Docket 08/07/2009

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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 [DE 1 ). Defendant seeks an extension until October 15, 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 August 20, 2009, as previously agreed upon.

2. The parties continue to work together to potentially resolve this case.

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-80656-KAM

Document 48

Entered on FLSD Docket 08/07/2009

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Doe 102 v. Epstein

Page 2

WHEREFORE Defendant respectfully requests that this Court enter an Order granting an extension until October 15, 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 areement with the requested extension until October 15, 2009 for Defendant to r,apon~ to Plaintiff's Complaint.

<signature>
Robert D. Critton Jr., 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 ih day of August, 2009

| Robert C. Josefsberg, Esq.        | Jack Alan Goldberger, Esq.            |
|-|-|
| Katherine W. Ezell, Esq.          | Atterbury Goldberger & Weiss, P.A.    |
| Podhurst Orseck, P.A.             | 250 Australian Avenue South           |
| 25 West Flagler Street, Suite 800 | Suite 1400                            |
| Miami, FL 33130                   | West Palm Beach, FL 33401-5012        |
| 305 358-2800                      | 561-659-8300                          |
| Fax: 305 358-2382                 | Fax: 561-835-8691                     |
| rjosefsberg@podhurst.com          | jagesg@bellsouth.net                  |
| kezell@podhurst.com               | Counsel for Defendant Jeffrey Epstein |
| Counsel for Plaintiff             |                                       |

Case 9:09-cv-80656-KAM

Document 48

Entered on FLSD Docket 08/07/2009

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Doe 1 02 v. Epstein

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Respectfully submitted,

By:
ROBERT D. CRITTON, JR., ESQ.
Florida Bar No. 224162
rcrit@bclclaw.com
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)
court-records/Doe No. 102 v. Epstein, No. 909-cv-80656 (S.D. Fla. 2009)/048.pdf
{"year":"2009","court":"S.D. Fla","people":["jeffrey epstein","robert d. critton","robert c. josefsberg","jack goldberger","katherine w. ezell","michael j. pike"]}