Case Document Entered on FLSD Docket Page of JANE DOE NO Plaintiff vs UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV-80119-MARRA/JOHNSON JEFFREY EPSTEIN Defendant Related cases JOINT MOTION FOR AN EXTENSION OF TIME TO Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page 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 both Plaintiff and Defendant are in agreement with extending the discovery cutoff an additional two week from April making the new discovery cutoff date April WHEREFORE Plaintiff and Defendant request that this Court enter an order granting the Motion for Extension of Time to Complete Discovery CERTIFICATE OF COMPLIANCE WITH LOCAL RULE Counsel for the movant conferred via e-mail with counsel for the Plaintiff and counsel for the Plaintiff is in agreement with moving the above date By Isl Michael Pike MICHAEL PIKE 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 CMIECF 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 CMIECF on this th day of February Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page Respectfully submitted By Isl Michael Pike ROBERT CRITTON JR ES Florida Bar 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 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 Plaint/ffe In related Cases Nos Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL 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 Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page4 Fax jagesg bellsouth.net Counsel for Defendant Jeffrey Estein 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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