Case 9:09-cv-80591-KAM

Document 11

Entered on FLSD Docket 05/04/2009

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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 RESPOND 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, April 17, 2009. Defendant seeks an extension until May 26, 2009, to file his response. As good cause in support of granting the motion, Defendant states:

1. On April 17, 2009 Plaintiff filed a Complaint [DE 1 ]. Defendant's response would be due on May 11, 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. Additionally, Defendant's counsel is in the midst of preparing for a state court trial, CARDIOPULMONARY & PRIMARY CARE ASSOC. OF TREASURE COAST, P.A v. LEWIS, M.D., Case No. 562008CA001726, specially set for trial beginning May 13

Case 9:09-cv-80591-KAM

Document 11

Entered on FLSD Docket 05/04/2009

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Doe 101 v. Epstein

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through 15, 2009). Discovery in that case is ongoing with several depositions set to prepare for trial.

4. 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.

5. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and Plaintiffs counsel is in agreement with the requested extension.

WHEREFORE Defendant respectfully requests that this Court enter an order granting an extension until May 26, 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 May 26, 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 rec<Jd identified on the following Service List in the manner specified by CM/ECF on this t day of May, 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                  |

Case 9:09-cv-80591-KAM

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Entered on FLSD Docket 05/04/2009

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Doe 101 v. Epstein

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rjosefsberg@podhurst.com
kezell@podhurst.com
Counsel for Plaintiff

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 #: 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-8d64eb77139ca2e1.pdf
{}