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 __ DEFENDANTS MOTION FOR AN EXTENSION OF TIME TO Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page attached hereto as Exhibit A Moreover the Independent Medical Examination of Jane Doe is set to occur between November and The scheduling of depositions in this matter has become much more difficult since the case was consolidated on May due to the number of attorneys involved and the fact that witnesses plaintiffs and the defendant may only be deposed once See Order Consolidating Cases for Purpose of Discovery and Procedural Motions That Relate to Multiple Cases Due the fact that depositions are still being scheduled there is technically not an operative compliant in this matter since same is subject to Motion to Dismiss it is premature to mediate complete all substantive pretrial motions by today October disclose expert and exchange expert reports and complete discovery by November In fact earlier this year Defendant filed an Unopposed Motion requesting that the court extend the deadlines for the above reasons Based upon these delays there may be a need to postpone the trial date if these delays continue The proposed new dates are as follows A New deadline to disclose experts and exchange expert reports New deadline to complete discovery New deadline to complete substantive pretrial motions New deadline to complete mediation WHEREFORE Plaintiff and Defendant request that this Court enter an order granting the Motion for Extension of Time to Complete Trial Deadlines Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page CERTIFICATE OF COMPLIANCE WITH LOCAL RULE Counsel for the movant conferred via telephone with counsel for the Defendant and counsel for the Defendant is in agreement with moving the above dates however counsel for the Defendant is in deposition and has not agreed to the specific dates outlined above The undersigned has a good faith belief that Mr Edwards will not object to the proposed dates and will ask Mr Edwards to file a Notice of Agreement regarding same By MICHAEL PIKE 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 October By RO ON JR ESQ 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 Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page4 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 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 Jack Hill Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL Fax 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 ProHac Vice South Room Salt Lake City UT Fax cassellp 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 Counsel for Plaintiff in Related Case No Robert Josefsberg Esq Katherine Ezell Esq Podhurst Orseck P.A West Flagler Street Suite Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page jsx 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/or Defendant Sarah Kellen Theodore Leopold Esq Spencer Kuvin Esq Leopold Kuvin P.A PGA Blvd Suite Palm Beach Gardens FL Fax Counsel for Plaintiff in Related Case No 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 A venue South Suite West Palm Beach FL Fax jagesg bellsouth.net Counsel for Defendant Jeffrey Epstein
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