Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page adequately respond to this and the other motions Defendant is in need of an extension until April In addition to the multiple motions good cause for the extension also includes that counsel has been attempting to resolve discovery issues in this and other cases against Defendant EPSTEIN an associate of Defendants undersigned counsel who works extensively on this case is currently out of the office and the undersigned was working on and has filed between motions and responses in the various cases during the time these motions were filed 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 to this and the other motions In addition this action is still at its early stages As certified below counsel for Defendant conferred with counsel for Plaintiff and Plaintiffs counsel is in agreement with the requested extension WHEREFORE Defendant requests that this Court enter an order granting an Defendant an extension until April in which to respond to the Above Motion Local Rule Statement Counsel for the movant conferred by telephone with counsel for the Plaintiff and Counsel for Plaintiff is in agreement with the requested extension until April for Defendant to respond to the Motion ITTON JR ESQ Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page 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 recor identified Uthe 243wing Service List in the manner specified by CM/ECF on this day of Stuart Mermelstein Esq Adam Horowitz Esq Mermelstein Horowitz P.A Biscayne Boulevard Suite Miami FL Fax ssm sexabuseattorney.com ahorowitz sexabuseattorney.com Counsel for Plaintiff Jane Doe Jack Alan Goldberger Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax iagesq bellsouth.net Co-Counsel for Defendant Jeffrey Epstein ROB CR TT UY./"C 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 Co-Counsel for Defendant Jeffrey Epstein
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