Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV-80119-MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant __ Related cases __ JOINT UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO PLAINTIFF JANE DOES MOTIONS TO COMPEL RESPONSES TO REQUEST TO PRODUCE ANSWERS TO REQUEST FOR ADMISSIONS AND ANSWERS TO INTERROGATORIES Defendant JEFFREY EPSTEIN and Plaintiff JANE DOE by and through their undersigned counsel move this Court for an Extension of Time until September to file Responses to Plaintiff Jane Does Motions to Compel Responses to Request to Produce Answers to Request for Admissions and Answers to Interrogatories pursuant to Local Rule A.l S.D Fla As good cause for the requested extension Defendant states Brad Edwards Counsel for the Plaintiff is currently recovering from a surgical procedure Mr Edwards is scheduled to return to the office on Tuesday September Case Document Entered on FLSD Docket Page of Mr Edwards and the undersigned have agreed to review the above Motions in an effort to determine whether any of the issues therein are covered by the Courts Order on other th Amendment Privilege issues DE The undersigned counsel has spoken with Brad Edwards law partner William Berger and each party has agreed to the extension of time until September While the undersigned lawyers are attempting to resolve certain issues in the above motions to conserve on judicial resources no admissions are being made in this Motion and no arguments are being abandoned Rule Certification of Pre-Filing Conference Counsel for Defendant conferred with Counsel for Plaintiff by telephone and/or By U.l MICHAEL IKE ESQ Florida Bar 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 rd day of September By ROBER CR JON JR ESQ Florida Bar No I rcrit bclclaw.com MICHAEL PIKE ESQ Case Document Entered on FLSD Docket Page of Florida Bar mpike bclclaw.com BURMAN CRITTON LUTTIER COLEMAN Flagler Drive Suite West Palm Beach FL Phone Fax Counsel for Defendant Jeffrey Epstein Certificate of Service Jane Doe No Jeffrey Epstein Case No 08-CV-80119-MARRA/JOHNSON Stuart Mermelstein Esq Adam Horowitz Esq Mermelstein Horowitz P.A Biscayne Boulevard Suite Miami FL Fax ssm sexabuseattomey.com ahorowitz sexabuseattorney.com Counsel for Plaintiffs In related Cases Nos Richard Horace Willits Esq Richard Willits P.A th Avenue North Suite Lake Worth FL Fax Counsel for Plaintiff in Related Case No reelrhw hotmail.com Jack Scarola Esq Brad Edwards Esq Rothstein Rosenfeldt Adler East Las Olas Boulevard Suite Fort Lauderdale FL Phone Fax bedwards rra-law.com Counsel for Plaintiff in Related Case No Paul Cassell Esq Pro Hae Vice South Room Salt Lake City UT Fax casselJp law.utah.edu Co-counsel for Plaintiff Jane Doe Isidro Garcia Esq Garcia Law Firm P.A Datura Street Suite West Palm Beach FL isidrogarcia bellsouth.net Case Document Entered on FLSD Docket Page of Jack Hill Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL Fax isx searcylaw.com iph searcylaw.com Counsel for Plaint/ff C.MA Bruce Reinhart Esq Bruce Reinhart P.A Australian Avenue Suite West Palm Beach FL Fax ecf brucereinhartlaw.com Counsel for Defendant Sarah Kellen Counsel for Plaintiff in Related Case No Robert Josefsberg Esq Katherine Ezell Esq Podhurst Orseck P.A West Flagler Street Suite Miami FL Fax riosefsberg podhurst.com kezell podhurst.com Counsel for Plaintiffe in Related Cases Nos and Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax jagesg ro,bellsouth.net Counsel for Defendant Jeffrey Epstein
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