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Case 9:09-cv-80591-KAM Document 11 Entered on FLSD Docket 05/04/2009 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-80591-MARRA/JOHNSON
JANE DOE No. 101,
Plaintiff,
V.
JEFFREY EPSTEIN,
Defendant,
______________,/
DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION
OF TIME IN WHICH TO RESPOND 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 respond to
Complaint dated, April 17, 2009. Defendant seeks an extension until May 26, 2009, to
file his response. As good cause in support of granting the motion, Defendant states:
1. On April 17, 2009 Plaintiff filed a Complaint [DE 1]. Defendant's response would
be due on May 11, 2009.
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 preparing responses to
Motions for Protective Order and 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-80591-KAM Document 11 Entered on FLSD Docket 05/04/2009 Page 2 of 3
Doe 101 v. Epstein
Page2
through 15, 2009). Discovery in that case is ongoing with several depositions set to
prepare for trial.
4. The requested extension is fair in reasonable under the circumstances as it will
provide time to allow the Defendant, EPSTEIN, to fully and adequately respond.
5. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and
Plaint
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