a deadline would not affect either side However at this time it is evident that both the back-to back hurricanes and the competing demands of Epsteins two solo practicing civil attorneys have rendered it impossible for Epstein to comply with this Courts ruling Accordingly for the reasons set forth below Epstein seeks an enlargement of time within which to respond to Edwards Motions and to continue the hearing date set for October ARGUMENT On September undersigned who is a solo practitioner in Broward County was still without power internet and telephones both at home and at her office The Governor had declared a statewide emergency all Federal Courts and schools in the tri-county area were closed and the State Courts in Miami-Dade and Broward remained closed until September After the hearing on September Chief Justice Jorge Labarga entered an Order regarding time parameters deadlines and the impact of the hurricane on court cases in Palm Beach County and other Counties affected a true and correct copy of which is attached hereto as Exhibit A Undersigned was evacuated from her home as of September at noon and did not regain power or internet at work or at home until late Monday September As of the date of filing this Motion undersigned is still without telephone service at her office Likewise Plaintiff/Counter-Defendant Epstein resides on an island in the United States Virgin Islands and his home was destroyed by hurricane Irma Hurricane Maria came immediate I thereafter and Epstein suffered another direct hit from that storm as well As a result of these hurricanes the entirety of the United States Virgin Islands has been declared a federal disaster area The hurricanes devastated the infrastructure throughout the United States Virgin Islands and particularly at Epsteins home Impassible debris from numerous fallen buildings and trees throughout his home make it uninhabitable Power outage and food and water shortages Tonja Haddad P.A SE th Street Fort Lauderdale FL throughout the Virgin Islands have created widely reported health safety and security concerns including at Epsteins home Epsteins home is without power and his computer servers have been and continue to be inoperable and inaccessible so that Epstein has no access to his litigation files Moreover Epstein has been completely occupied with massive post-hurricane clean-up efforts at his home and most importantly providing desperately needed shelter and supplies for his employees ravaged by the storms Consequently the undersigned has had little to no communication with him As such Epstein has been completely unable to participate in any way regarding these critical Motions as well as other discovery and motion practice which are essential to the proper defense of his case Epsteins participation in the defense of his case is not only his right but it is also absolutely necessary given the long history of this case and the matters out of which it arose It is also noteworthy to mention that Rosh Hashanah also fell during the ten days provided by this Court and that both Mr Epstein and one of his counsel are of the Jewish faith and were unavailable as a result for two of those days om Kippur falls on September to September further impeding their participation for those days which are only a short time prior to the scheduled hearing Epstein has four attorneys who have filed Notices of Appearance in this matter each of whom is a solo practitioner undersigned who is lead counsel and responsible for drafting all pleadings and documents and who also serves as an arbitrator Chester Brewer who serves as local counsel in an advisory capacity and to assist in court with hearings and motions Jack Goldberger who is a criminal defense attorney who is involved in this case solely to advise and address the various criminal elements/issues raised by Edwardss desire to litigate this matter as a criminal prosecution and/or to impermissibly raise criminal allegations herein and finally Fred Tonja Haddad P.A SE th Street Fort Lauderdale FL Haddad who is solely in this case to act as trial co-counsel Mr Haddad resides in Islamorada and his home was also destroyed by hurricane Irma Conversely Edwardss lead counsel is a firm with over thirty attorneys Searcy Denney et al and Edwards is also listed as his own co-counsel through his firm which employs over ten attorneys and Monday at the close of business a new firm filed in as co-counsel in this matter and contemporaneously with its Notice of Appearance filed a Motion containing over pages directed at Epsteins Motion for Summary Judgment Epstein timely filed his four additional Motions as contemplated by this Court on September to wit his Omnibus Motion in Limine a Motion to Compel discovery related to Edwardss Privilege Log a Motion to Compel responses to Discovery and a Motion to Compel answers to questions posed to Edwards in his depositions Edwards filed the following motions on September to which undersigned cannot possibly respond in three days with a mediation multiple depositions court hearings other deadlines and client matters already scheduled in those three days not to mention the backlog from ten days out of the office and with Mr Brewer as this Court was notified out of town and unavailable this entire week four deposition notices and subpoenas duces tecum to Epsteins criminal defense counsels three motions directed to Epsteins Motion for Summary Judgment objections to every single one of Epsteins damages Interrogatories to Edwards four bare-bones Motions to Compel responses to four sets of unidentified discovery responses some predating undersigneds involvement in this case and a Motion in Limine Forcing Epstein to research these issues draft file and argue proper responses to all of these items as well as prepare for hearing on his motions motions which include a request to compel answers to four separate sets of Interrogatories and Requests to Produce especially when Tonja Haddad P.A SE th Street Fort Lauderdale FL Epstein is unable to assist with the same is improper Moreover in light of the time constraints created by previously scheduled depositions mediations and hearings the undersigned cannot possibly perform this daunting task properly and effectively forcing her to choose between compliance with this Courts directive and providing effective assistance of counsel Accordingly an enlargement of time is necessary WHEREFORE Jeffrey Epstein respectfully requests that this Court enter an Order enlarging the time limitations within which Epstein must respond to the Motions filed by Edwards and continue the hearing date set for October on said Motions and such other and further relief as this Court deems just and proper WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below via Electronic Service this September Isl Tonja Haddad Coleman Tonja Haddad Coleman Esq Fla Bar No LAW OFFICE OF TONJA HADDAD PA SE th Street Suite Fort Lauderdale Florida facsimile Efiling tonjahaddad.com Tonj a tonjahaddad.com Tonja Haddad P.A SE th Street Fort Lauderdale FL SERVICE LIST CASE NO Jack Scarola Esq sx searcylaw.com mep searcylaw.com Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach FL Jack Goldberger Esq jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss PA Australian Ave South Suite West Palm Beach FL Marc Nurik Esq East Broward Blvd Suite Fort Lauderdale FL Bradley Edwards Esq brad pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman Andrews A venue Suite Fort Lauderdale Florida Fred Haddad Esq Dee FredHaddadLaw.com SE 7th Street Suite Fort Lauderdale FL Tonja Haddad Coleman Esquire Tonj a tonjahaddad.com efiling tonjahaddad.com Law Offices of Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Attorneys for Jeffrey Epstein Chester Brewer Jr One Clearlake Center Suite Australian A venue South West Palm Beach Florida wcblaw aol.com wcbcg aol.com Tonja Haddad P.A 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