Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page2 through Discovery in that case is ongoing with several depositions set to prepare for trial The requested extension is fair and reasonable under the circumstances as it will provide time to allow the Defendant EPSTEIN to fully and adequately reply An extension until May is fair and reasonable under the circumstances The undersigned is in need of the additional time in order to fully and adequately prepare a response on behalf of EPSTEIN As certified below counsel for Defendant conferred with counsel by e-mail and Plaintiffs counsel is in agreement with the requested extension WHEREFORE Defendant respectfully requests that this Court enter an order granting an extension until May to file a Reply to Plaintiffs Response in Opposition to Defendants Motion to Stay Complaint Local Rule Statement Counsel for the movant conferred by e-mail with counsel for the Plaintiff and Counsel for Plaintiff is in agreement with the requested extens until May for Defendant to reply to Plaintiffs Response to Defendants Stay Complaint Robert Critton Jr Attorney for Defendant Epstein 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 5th day of May Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page3 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 Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax jaqesq bellsouth.net Co-Counsel for Defendant Jeffrey Epstein I Respectf ly sub ltted I By ROB IT Floridq Bar rcrit bclclaw.com MICKAEL 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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