UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO 2750CASE NO 08-CV-80119-MARRA/JOHNSON Pl-3ai-3nt-3i-3ff vs JEFFREY EPSTEIN Defendant JANE DOE NO 2750CASE NO 08-CV-80232-MARRA/JOHNSON Pl-3ai-3nt-3i-3ff vs JEFFREY EPSTEIN Defendant JANE DOE NO 2750CASE NO 08-CV-80380-MARRA/JOHNSON Pl-3ai-3nt-3i-3ff vs JEFFREY EPSTEIN Defendant JANE DOE NO 2750CASE NO 08-CV-80381-MARRA/JOHNSON Pl-3ai-3nt-3i-3ff vs JEFFREY EPSTEIN Defendant PLAINTIFFS UNOPPOSED MOTI ON FOR ENLARGEMENT OF TIME TO RESPOND TO DEFENDANT 2S MOTIONS TO DISMISS AND FOR MORE DEFINITE STATEMENT Case Document Entered on FLSD Docket Page of 2785Plaintiffs Jane Doe Jane Doe Jane Doe and Jane Doe by and through undersigned counsel file this Motion for Enlargem8ent of Tim8e to Respond to Defendant 2s Motions to Dism8iss and for More Definite Statem9ent and state as follows Defendant Jeffrey Epstein filed a sim8ila Motion to Dism9iss and Motion for More Definite Statem9ent the 223Motions to Dism9iss in each of the above-captioned cases on October Plaintiffs response to the Motions to Di sm9iss under Local Rule is presently due on October Plaintiffs seek an enlargem9ent of tim9e of five business days until October to file their response to the Motions to Dism iss This enlargem9en of tim9e will synchronize the response date to the Motions to Dism9iss in th above-captioned cases with the response date to the sim9ilar Motions to Dism9iss f4iled in Jane Doe Nos Epstein case nos and 80993-CIV-Marra which is October Additionally this request f4o1r enlargem9ent of4 tim9e is necessitated by Plaintif4f4s counsel 2s prior com9m9itm9ents and the dem9ands of other cases and m9atters including upcom9ing discovery cutoffs in Jane Doe School Board of Broward County and Scav ella case no CIV-SEITZ U.S District Cour Southern District Court of Florida and Doe Faerber case no U.S District Court Middle District of Florida This Motion seeks a brief enlargem8ent of tim8e and is not brought for purposes of delay Pl-7a-6i-7ntiff has conferred with Defendant 2s couns el Robert Critton regarding this request for enlargem9ent of tim9e and he has no objection to this request 2835WHEREFORE Plaintiff respectfully requests an Or der granting an enlargem9ent of tim9e of five business days until October to file the Plaintiffs respon se to the Motions to Dism9iss Case Document Entered on FLSD Docket Page of Dated October 2750Respectfully subm8itted By Jeffrey Herm8an Jeffrey Herm8an FL Bar No jherm9an herm9anlaw.com Stuart Merm8elstein FL Bar No ssm8 herm8a-1nlaw.com Adam8 Horowitz FL Bar No ahorowitz herm8a-1nlaw.com HERMAN MERMELSTEIN P.A Attorneys for Plaintiffs Jane Doe Biscayne Blvd Suite Miam9i Florida Tel Fax CERTIFICATE OF SERVICE I hereby certify that on October I electr onically filed the foregoing docum8ent w7ith the Clerk of the Court using CM/ECF I also certify foregoing docum9ent is being served this day to all parties on the attached Service List in the m9anner specified either via transm9ission of Notices of Electronic Filing generated by CM/ECF or in som9e other authorized m9anner for those parties who are not authorized to receive electronically Notices of Elec tronic Filing Case Document Entered on FLSD Docket Page of SERVICE LIST DOE vs JEFFREY EPSTEIN United States District Court 2Southern District of Florida Jack Alan Goldberger Esq jgoldberger agwpa.com Michael Tein Esq tein lewistein.com Robert Critton Esq rcritton bclclaw.com Michael Pike Esq m9p1ike bclclaw.com Jeffrey Herm8an Case Document Entered on FLSD Docket Page of
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