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 AGREED MOTION FOR EXTENSION OF TIME TO FILE REPLY TO JANE DOE AND DOES MEMORANDUM RESPONSE TO DEFENDANTS RULE APPEAL DEs 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 Jane Does and Does Memorandum Response to Defendants Consolidated Rule Appeal dated May Defendant seeks an extension until June to file his Reply and Plaintiffs are in agreement with the requested extension As good cause in support of granting the motion Defendant states Defendant filed his Appeal of Magistrate Judge Decision on May DE Plaintiffs filed their Memorandum Response to Defendants Rule Appeal on May Des Case Document Entered on FLSD Docket Page of As this Court is aware the undersigned represents the Defendant in nine other related cases before this Court and three cases in State Court as well as a newly filed case before Judge Gold Defendant has filed numerous Motions Responses and Replies in all of these cases and has filed numerous pre-trial motions before this Court in order to comply with this Courts trial orders and deadlines Further Defendant has and continues to prepare for and take numerous depositions in each of these cases The undersigned will be out of town from June and will return to the office on June This is and has been a prearranged family vacation The requested extension is fair in reasonable under the circumstances as it will provide time to allow the Defendant EPSTEIN to fully and adequately Reply to the opposition motions Initially counsel for Does agreed to an extension up to June However counsel for Jane Doe objected Therefore counsel for Jane Doe agreed to an extension up to June I In good faith the undersigned agreed to file the consolidated Reply as to Jane Doe and Does on June I WHEREFORE Defendant requests that this Court enter an Order granting the Defendant an extension until June in which to Reply to Jane Doe and Does opposition motions Local Rule Certification Counsel for the movant conferred by electronic mail with counsel for the Plaintiffs and Counsel for the Plaintiffs is in agreement with the requested extension until June Isl Michael Pike Robert Critton Jr Michael Pike Case Document Entered on FLSD Docket Page of Attorneys for Defendant Epstein 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 rd day of June Respectfully submitted By Isl Michael Pike ROBERT CRITTON SQ Florida Bar No rcrit bclclaw.com MICHAEL PIKE ESQ Florida Bar mpike bclclaw.com BURMAN CRITTON LUTTIER COLEMAN LLP 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 Brad Edwards Esq Farmer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Avenue Suite Fort Lauderdale FL Case Document Entered on FLSD Docket Page of 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/or Defendant Jeffrey Epstein Fax brad pathtojustice.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 Plaint/ff 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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