051.pdf

Case 9:09-cv-80656-KAM Document 51 Entered on FLSD Docket 10/15/2009 Page 1 of 3
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 30,
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 51 Entered on FLSD Docket 10/15/2009 Page 2 of 3
Doe 102 v. Epstein
Page 2
WHEREFORE Defendant respectfully requests that this Court enter an Order
granting an extension until October 30, 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 October 30, 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 15th day of October, 2009

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

Case 9:09-cv-80656-KAM Document 51 Entered on FLSD Docket 10/15/2009 Page 3 of 3
Doe 102 v. Epstein
Page 3
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)