Case Document Entered on FLSD Docket Page of date of said order Federal Rule allows for an appeal to be filed within days of said order Based upon the timing of the order to produce documents and the day time period allowed for the filing of an Appeal there remains a conflict as to the timing of both Defendant needs an extension of time as a result of said timing conflict and for additional the reasons set forth below Defendant seeks to appeal pursuant to Rule those portions of the order which specifically address the above requests for production Given the breadth of the th Amendment addressing the above requests and the fact that the order does not address various issues in the Response including relevance the Defendant respectfully requests an additional days from February within which to file with the Clerk of the Court and serve of all parties written objections which shall specifically set forth the order or part thereof appealed from and a concise statement of the alleged error in the ruling and statutory rule or case authority in support of defendants position As such Defendant requests that the due date effectively be moved to August The undersigned Michael Pike has a special set hearing in front of the Honorable Elizabeth Metzgen in Stuart Florida on February In addition the undersigned Robert Critton Jr Esq is scheduled for various depositions in these related matters This request is not made to delay and will not prejudice any of the parties While this request is within the sound discretion of the court pursuant to Rule the undersigned has consulted with opposing counsel and he has not agreed Case Document Entered on FLSD Docket Page of Wherefore the undersigned respectfully requests the relief sought herein and for such other and further relief as this court deems just and proper Local Rule Statement Counsel for the movant conferred by telephone with counsel or the Plaintiff and Counsel for Plaintiff is not in agreement with the requested By __ ROBERT TON JR Florida MICHAEL PIKE ESQ Florida Bar Certificate of Service I HEREBY 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 electronic mail e-mail on this day of February Respectfully JR ESQ Florida No rcrit bclclaw.com MICHAEL PIKE ESQ Florida Bar mpike bclclaw.com BURMAN CRITTON LUTTIER COLEMAN Banyan Blvd Suite West Palm Beach FL Phone Fax Counsel/or Defendant Jeffrey Epstein Certificate of Service Jane Doe No Jeffrey Epstein Case No 08-CV-80119-MARRA/JOHNSON Case Document Entered on FLSD Docket Page 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 Plaintiffs In related Cases Nos Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax jagesg bellsouth.net Counsel for Defendant Jeffrey Estein Farmer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Avenue Suite Fort Lauderdale FL Phone Fax brad pathtojustice.com Counsel for Plaintiff in Related Case No Paul Cassell Esq Pro Hae 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
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