Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 09-80656-MARRA/JOHNSON JANE DOE No Plaintiff JEFFREY EPSTEIN Defendant DEFENDANT JEFFREY EPSTEINS 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 DE Defendant seeks an extension until October to file his response As good cause in support of granting the motion Defendant states On May Plaintiff filed a Complaint DE Defendants response would be due on August as previously agreed upon The parties continue to work together to potentially resolve this case 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 As certified below counsel for Defendant conferred with counsel for Plaintiff and Plaintiffs counsel is in agreement with the requested extension Case Document Entered on FLSD Docket Page of Doe Epstein Page2 WHEREFORE Defendant respectfully requests that this Court enter an Order granting an extension until October to file a response to Plaintiffs Complaint Local Rule Statement Counsel for the movant conferred by telephone and correspondence with counsel for the Plaintiff and Counsel for Plaintiff is in areement with the requested extension until October for Defendant to r,apon to Plaintiffs Complaint I I i I Robert fittpn Jr Esq Attorney Erefen ant 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 ih day of August Robert Josefsberg Esq Katherine Ezell Esq Podhurst Orseck P.A West Flagler Street Suite Miami FL Fax rjosefsberg podhurst.com kezell podhurst.com Counsel for Plaintiff Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax jagesg bellsouth.net Counsel for Defendant Jeffrey Epstein Case Document Entered on FLSD Docket Page of Doe Epstein Page3 Respect II milted By ROBER CR!T JR ESQ Florida Bar No rcrit bclclaw.com MICHAEL PIKE ESQ Florida Bar mpike bclclaw.com BURMAN CRITTON LUTTIER COLEMAN Flagler Drive Suite West Palm Beach FL Phone Fax Counsel for Defendant Jeffrey Epstein
2,576 characters
