Case Document Entered on FLSD Docket Page of JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV-80119-MARRA/JOHNSON Related cases AMENDED JOINT MOTION FOR AN EXTENSION OF TIME TO Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page counsel is working on the scheduling of these depositions Additionally the deposition of Jeffrey Epstein has not been completed and Plaintiffs have additional depositions to take some of which are out of state 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 Additionally many of the witnesses retained their own counsel and the depositions need to be coordinated with those attorneys schedules Due to the fact that depositions are still being scheduled both Plaintiffs and Defendant are in agreement with extending the discovery cutoff in Jane Does an additional two weeks from April making the new discovery cutoff date April and extending the discovery cutoff in Jane Does to May Further the current scheduling order requires expert reports to be disclosed on July The parties have agreed to disclose the expert reports in Jane Does on May and in Jane Does on June WHEREFORE Plaintiffs and Defendant request that this Court enter an order granting the Motion for Extension of Time to Complete Discovery Deadline and Shorten Expert Disclosures CERTIFICATE OF COMPLIANCE WITH LOCAL RULE Counsel for the parties conferred via e-mail and are in agreement with moving the above dates Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page By Isl Robert Critton ROBERT CRITTON ESQ Florida Bar 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 CM/ECF on this th day of March Respectfully submitted By Isl Robert Critton 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 Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page4 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 sexabuseattomey.com ahorowitz sexabuseattorney.com Counsel for Plaintiffs In related Cases Nos Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach FL Fax jagesq bellsouth.net Counsel for Defendant Jeffrey Epstein 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 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 ProHac Vice South Room IOI 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 Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page
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