Case 9:09-cv-80591-KAM

Document 57

Entered on FLSD Docket 07/02/2009

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 09-80591-MARRA/JOHNSON

JANE DOE No. 101,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant,

DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO FILE A REPLV 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 August 21, 2009, to file his reply. As good cause in support of granting the motion, Defendant states:

1. On May 1, 2009, Plaintiff filed an Amended Complaint [DE 9].

2. On May 26, 2009, Defendant filed a Motion to Dismiss Amended Complaint [DE 29].

3. On June 26, 2009, Plaintiff filed her Response to Defendant's Motion to Dismiss Amended Complaint [DE 56].

Case 9:09-cv-80591-KAM

Document 57

Entered on FLSD Docket 07/02/2009

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Doe 101 v. Epstein

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4. Defendant's Reply to Plaintiff's Response to Defendant's Motion to Dismiss Amended Complaint is currently due on July 3, 2009.

5. 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.

6. 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.

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

WHEREFORE Defendant respectfully requests that this Court enter an Order granting an extension until August 21, 2009, to file a Reply to Plaintiff's Response to Defendant's Motion to Dismiss Amended Complaint.

Local Rule 7.1 Statement

Counsel for the movant conferred by telephone and correspondence with counsel for the Plaintiff and Counsel for Plaintiff s in greement with the requested extension until August 21, 2009 for Defendant to to Plaintiff's Complaint.

<signature>
Robert D. Criton, 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 2nd day of July, 2009

Case 9:09-cv-80591-KAM

Document 57

Entered on FLSD Docket 07/02/2009

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Doe 101 v. Epstein

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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
MICHAEL J. PIKE, ESQ.
Florida Bar No.: 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. 101 v. Epstein, No. 909-cv-80591 (S.D. Fla. 2009)/057.pdf
{"year":"2009","court":"S.D. Fla","people":["jeffrey epstein","robert d. critton","robert c. josefsberg","katherine w. ezell","jack goldberger","michael j. pike"]}