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Case 9:10-cv-80447-KAM Document 6 Entered on FLSD Docket 05/11/2010 Page 1 of 3
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
CASE NO 10-80447 -CV-MARRA/JOHNSON

C. L.,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
________________________________________/

UNOPPOSED MOTION FOR EXTENTION OF TIME TO RESPOND TO
DEFENDANT'S EPSTEIN'S MOTION FOR MORE DEFINITE STATEMENT AND TO
STRIKE AND TO DISMISS DIRECTED TO COUNT III OF PLAINTIFF
C.L'S COMPLAINT DATED 3/31/10

Pursuant to Fed. R. Civ. P. and S.O. Fla.L.R.7.1, Plaintiff, C.L., hereby files this
Unopposed Motion For Extension Of Time To Respond To Defendants' Motion for More
Definite Statement and to Strike and to Dismiss Count III of Complaint. Plaintiffs have good
cause for this extension given that lead counsel for Plaintiff begins trial on Tuesday, May 11,
2010 in Palm Beach Civil Circuit Court before the Honorable Edward A. Garrison, Circuit Case
No.: 50 2009 CA 028195 XXXX MB AI. Defendants have agreed to give Plaintiffs a ten (10)
day extension of time to respond so that Plaintiffs must file a response to Defendants' Motion
May 28, 2010.

RELIEF REQUESTED
The undersigned respectfully requests that the Court grant Plaintiffs' Unopposed Motion
For Extension Of Time To Respond To Defendants' Motion for More Definite Statement,
Motion to Strike and to Dismiss Count III Of Complaint. Plaintiff has attached a proposed order.

Case 9:10-cv-80447-KAM Document 6 Entered on FLSD Docket 05/11/2010 Page 2 of 3
CERTIFICATE OF SERVICE

I hereby certify that on May 11, 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 of Notices 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.

Robert D. Critton, Jr., Esq.
rcrit@bclclaw.com
Michael J. Pike, Esq.
mpike@bclclaw.com
Burman Critton Luttier & Coleman
303 Banyon Boulevard
Suite 400
West Palm Beach, FL 33401
561-842-2820
Counsel for Defendant Jeffrey Epstein

Jack Alan Goldberger, Esq.
jagesq@bellsouth.net
Atterbury Goldberger & Weiss, P.A.
250 Australian Ave South, Ste 1400
West Palm Beach, FL 33401
561-659-8300

Respectfully submitted,
By: s/SPENCER T. KUVIN, ESQ.
(Florida Bar No.: 089737)
Email: skuvin@leopoldkuvin.com

Leopold-Kuvin, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400
Facsimile: (561) 515-1401
Attorneys for Plaintiff
Page 2 of 2

Case 9:10-cv-80447-KAM Document 6 Entered on FLSD Docket 05/11/2010 Page 3 of 3
UNITED STATES DISTRICT COURT FOR THE
SOUTHERN DISTRICT OF FLORIDA
CASE NO: 10-80447 -CV-MARRA/JOHNSON

C. L.,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
________________________________________/

[PROPOSED] ORDER ON MOTION FOR EXTENSTION OF TIME TO RESPOND TO
DEFENDANT EPSTEIN'S MOTION FOR MORE DEFINITE STATEMENT AND TO
STRIKE AND TO DISMISS DIRECTED TO COUNT III OF PLAINTIFF C.L'S
COMPLAINT DATED 3/31/10

Upon PLAINTIFF'S unopposed Motion for Extension of Time to Respond pursuant to
Local Rule 7.1 of the United States District Court of Southern District of Florida, it is hereby:
ORDERED AND ADJUDGED that Plaintiff has until and including May 28, 2010, to
respond to Defendant's Motion for More Definite Statement & to Strike & to Dismiss Directed to
County III of Plaintiff C.L.'s Complaint dated March 31, 2010.
DONE AND ORDERED in Chambers at Miami, Florida this _____ day of May, 2010.

______________________________
The Honorable Kenneth A. Marra
Federal Court Judge

Copies furnished to:
Spencer T. Kuvin, Esq., Leopold-Kuvin, PA, 2925 PGA Blvd, Suite 200, Palm Beach Gardens, FL
Robert D. Critton, Esq., Jr., Burman Critton, 303 Banyon Blvd, Suite 400, West Palm Beach, FL
Jack Alan Goldberger, Esq., Atterbury Goldberger, 250 Australian Ave S., Ste 1400, WPB, FL