078.pdf

Case 9:09-cv-80591-KAM Document 78 Entered on FLSD Docket 10/29/2009 Page 1 of 3

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 REPLY 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 November
16, 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 78 Entered on FLSD Docket 10/29/2009 Page 2 of 3
Doe 101 v. Epstein
Page 2

4. Defendant’s Reply to Plaintiff’s Response to Defendant’s Motion to Dismiss
Amended Complaint is currently due on October 30, 2009.

5. The parties continue to work together to find a resolution in this case.

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 November 16, 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 is in agreement with the requested
extension until November 16, 2009 for Defendant to respond to Plaintiff’s Complaint.

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 29th day of November, 2009

Case 9:09-cv-80591-KAM Document 78 Entered on FLSD Docket 10/29/2009 Page 3 of 3
Doe 101 v. Epstein
Page 3

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
jagesq@bellsouth.net
Counsel for Defendant Jeffrey Epstein

Respectfully submitted,

By: ____________________
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)