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 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 December 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 find a resolution in this case and are close to a resolution In addition parties have agreed to numerous extensions while negotiating a resolution The implosion of the Rothstein Rosenfeldt Adler PA firm has raised certain questions for which defense counsel will request answers/information from Plaintiffs counsel regarding the Rothstein scheme/scandal prior to final resolution Case Document Entered on FLSD Docket Page of Doe Epstein Page 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 not agreement with the requested extension WHEREFORE Defendant respectfully requests that this Court enter an Order granting an extension until December to file a response to Plaintiffs Complaint Local Rule 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 for Defendant to respond to Plaintiffs Complaint Robert Critton Esq Attorney for Def ndant 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 nd day of December Robert Josefsberg Esq Katherine Ezell Esq Podhurst Orseck P.A West Flagler Street Suite Miami FL Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Case Document Entered on FLSD Docket Page of Doe Epstein Page Fax riosefsberg podhurst.com kezell podhurst.com Counsel for Plaintiff Fax iagesq bellsouth.net Counsel for Defendant Jeffrey Epstein By __ ROBERT CRITTON JR ESQ Florida 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
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