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Case 9:09-cv-80469-KAM Document 7 Entered on FLSD Docket 05/01/2009 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-CIV- 80469 - MARRAIJOHNSON
JANE DOE II,
Plaintiff,
V.
JEFFREY EPSTEIN,
Defendant.
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DEFENDANT'S UNOPPOSED MOTION FOR EXTENSION TO FILE
A RESPONSE TO COMPLAINT
Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his
undersigned attorneys, respectfully moves this Court for an extension of time in which to
file his Response to Plaintiffs Complaint.
1. On March 25, 2009 Plaintiff filed a Complaint [DE 1] in the within matter. Plaintiff
and Defendant counsel agreed Defendant would file a response by May 1, 2008.
Defendant is requesting a five day extension to May 6, 2009 to respond.
2. There are several other cases filed with this Court in which Jeffrey Epstein is
named a Defendant. In those cases, the undersigned has been handling other matters
associated therewith.
3. Additionally, Defendant's counsel is in the midst of preparing for a state court
trial, CARDIOPULMONARY & PRIMARY CARE ASSOC. OF TREASURE COAST, P.A
v. LEWIS, M.D., Case No. 562008CA001726, specially set for trial beginning May 13
Case 9:09-cv-80469-KAM Document 7 Entered on FLSD Docket 05/01/2009 Page 2 of 3
Jane Doe II v. Epstein, et al.
Page2
through 15, 2009). Discovery in that case is ongoing with several depositions set to
prepare for trial.
4. An extension until May 6, 2009, is fair and reasonable under the circumstances.
The undersigned is in need of the additional time in order to fully and adequately
prepare a response on behalf of EPSTEIN.
5. As certified below, counsel for Defendant conferred with Plaintiff's counsel
counsel by telephone, and Plaintiff's c
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