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 I DEFENDANTS AMENDED UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY TO PLAINTIFF JANE DOES RESPONSE IN OPPOSITION TO DEFENDANTS MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE REVIEW AND APPEAL Defendant Jeffrey Epstein hereinafter Epstein by and through his undersigned attorneys respectfully moves this Court for an Extension of Time in which to Reply to Plaintiff Jane Does Response in Opposition to Defendants Motion for Reconsideration and/or Request for Rule Review and Appeal Defendant seeks an additional four day extension until Friday March to file his Reply As good cause in support of granting the motion Defendant states On February IO this Court entered an Omnibus Order granting in part and denying in part Plaintiffs Motions to Compel Responses to Requests for Production DE On February Defendant filed his Motion for Reconsideration and/or Request for Rule Review and Appeal DE Case Document Entered on FLSD Docket Page of On March Plaintiff filed her Response in Opposition to Defendants Motion for Reconsideration and/or Request for Rule Review and Appeal DE Defendants Reply to Plaintiffs Response in Opposition is currently due on March Robert Critton counsel for the Defendant is currently out of town and Michael Pike counsel for the Defendant has attended three depositions in related matters this week and therefore needs a simple four days extension to file Defendants Reply While this request is reasonable counsel for the Defendant has spoken to counsel for the Plaintiff and counsel is in agreement with the requested four day extension Wherefore the undersigned respectfully requests the relief sought herein and for such other and further relief as this court deems just and proper Local Rnle Statement Counsel for the movant conferred by e-mail with counsel for the Plaintiff and Counsel for Plaintiff is in agreement with the requested extension By Isl Michael Pike ROBERT CRITTON JR Florida Bar MICHAEL PIKE ESQ Florida Bar Case Document Entered on FLSD Docket Page of 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 th day of March Respectfully submitted By Michael Pike ROBERT CRITTON JR ESQ 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 Plaintiffe In related Cases Nos Farmer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Avenue Suite Fort Lauderdale FL Phone Fax brad pathtoiustice.com Counsel for Plaintiff in Related Case No Paul Cassell Esq Pro Hae Vice South Room Case Document Entered on FLSD Docket Page of Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach FL Fax iagesg bellsouth.net Counsel/or Defendant Jeffrey Epstein Robert Josefsberg Esq Katherine Ezell Esq Podhurst Orseck P.A West Flagler Street Suite Miami FL Fax rjosefsberg podhurst.com kezell podhurst.com Counsel for Plaintiffs in Related Cases Nos and 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
3,826 characters
