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.IG S.D Fla As good cause for the requested extension Defendant states Brad Edwards Counsel for the Plaintiff was scheduled to return to the office after having a surgical procedure on Tuesday September However Mr Edwards will not return to his office in his full capacity until Monday 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 Mr Edwards 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 Pl inti ff by telephone and/or electronic mail and Counsel for Plaintiff is in agree nt ti equested extension I By MIC EL PI 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 th day of Se temb TD CR TON JR ESQ Flori a Bar No rcrit bclclaw.com MICHAEL PIKE ESQ Florida Bar mpike bclclaw.com Case Document Entered on FLSD Docket Page of BURMAN CRITTON LUTTIER COLEMAN Banyan Blvd 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 sexabuseattorney.com ahorowitz sexabuseattorney.com Counsel.for laintijfs In related Cases Nos Richard Horace Willits Esq Richard I-I Willits P.A th Avenue North Suite Lake Worth FL Fax Counsel for Plaintiff in Related Case No reelrhw hotmail.com Jack Scarola Esq Jack Hill Esq Searcy Denney Scarola Barnhart Shipley 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 cassellp a Jaw.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 Counsel for Plaintiff in Related Case No Case Document Entered on FLSD Docket Page of P.A Palm Beach Lakes Boulevard West Palm Beach FL Fax isx searcylaw.com jph searcylaw.com Counsel for Plaintiff 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 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 Plaintiffs in Related Cases Nos and Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax iagesg beHsouth.net Counsel for Defendant Jeffrey Epstein
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