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Case 9:10-cv-81111-WPD Document 25 Entered on FLSD Docket 11/29/2010 Page 1 of 4




                               UNITED STATES DISTRICT COURT
                               SOUTHERN DISTRICT OF FLORIDA

                                    Case No. 9:10-cv-81111-WPD


   M.J.,

                  Plaintiff,

   vs.

   JEFFREY EPSTEIN and
   SARAH KELLEN,

                  Defendant.
                                               I


     DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION OF
      TIME TO RESPOND TO PLAINTIFF'S MOTION FOR A PROTECTIVE ORDER
      BARRING DIRECT OR INDIRECT CONTACT BY EPSTEIN AND MOTION FOR
     PRESERVATION OF EVIDENCE RELATING TO CORRESPONDENCE WITH U.S.
                            ATTORNEY'S OFFICE

           Defendant Jeffrey Epstein, by and through undersigned counsel, respectfully moves for a ten

   (I 0) - day enlargement of time in which to respond to Plaintiffs Motion for a Protective Order

   Barring Direct or Indirect Contact by Epstein (D.E. 16) and Motion for Preservation of Evidence

   Relating to Correspondence with U.S. Attorney's Office (D.E. 17) and states as follows:

           1.     On October 11, 2010, Plaintiff filed a Motion for a Protective Order Barring Direct

   or Indirect Contact by Epstein (D.E. 16) and a Motion for Preservation of Evidence Relating to

   Correspondence with U.S. Attorney's Office (D.E. 17). Defendant's response to the foregoing

   motions is presently due on November 29, 2010.

           2.     The parties have recently been engaging in discussions to resolve the foregoing

   pending motions.
Case 9:10-cv-81111-WPD Document 25 Entered on FLSD Docket 11/29/2010 Page 2 of 4




                                                                         Case No. 9:10-cv-81111-WPD


            3.     The parties require an additional ten (10) days in which to resolve all matters

  pertaining to the pending motions.

            4.     In order to facilitate the resolutio

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