087.pdf

Case 9:09-cv-80591-KAM Document 87 Entered on FLSD Docket 12/02/2009 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 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 December
15, 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 87 Entered on FLSD Docket 12/02/2009 Page 2 of 3
Doe 101 v. Epstein
Page 2
4. The parties continue to work together to find a resolution in this case and are
close to a resolution. In addition, parties have agreed to numerous extensions while
negotiating a resolution.
5. The implosion of the Rothstein Rosenfeldt & Adler, PA firm has raised certain
questions for which defense counsel will request answers/information from Plaintiff's
counsel regarding the Rothstein scheme/scandal prior to final resolution.
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 not in agreement with the requested extension at this time.
WHEREFORE Defendant respectfully requests that this Court enter an Order
granting an extension until December 15, 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 correspondence with counsel for the
Plaintiff and Counsel for Plaintiff is not in agreement with the requested extension until
December 15, 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

Case 9:09-cv-80591-KAM Document 87 Entered on FLSD Docket 12/02/2009 Page 3 of 3
Doe 101 v. Epstein
Page 3
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 December, 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
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)