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Case 9:09-cv-80591-KAM Document 57 Entered on FLSD Docket 07/02/2009 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 FILE A REPLV TO PLAINTIFF JANE DOE 101 'S RESPONSE
         TO DEFENDANT'S MOTION TO DISMISS AMENDED COMPLAINT

       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

  Plaintiff, Jane Doe 101's Response to Defendant, Epstein's Motion to Dismiss Amended

  Complaint [DE 56] dated June 26, 2009. Defendant seeks an extension until August 21,

  2009, to file his reply. As good cause in support of granting the motion, Defendant

  states:

       1. On May 1, 2009, Plaintiff filed an Amended Complaint [DE 9].

       2. On May 26, 2009, Defendant filed a Motion to Dismiss Amended Complaint [DE

  29].

       3. On June 26, 2009, Plaintiff filed her Response to Defendant's Motion to Dismiss

  Amended Complaint [DE 56].
Case 9:09-cv-80591-KAM Document 57 Entered on FLSD Docket 07/02/2009 Page 2 of 3




  Doe 101 v. Epstein
  Page2

     4. Defendant's Reply to Plaintiff's Response to Defendant's Motion to Dismiss

  Amended Complaint is currently due on July 3, 2009.

      5. 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.

      6. The requested extension is fair and reasonable under the circumstances as it will

  provide time to allow the Defendant, EPSTEIN, to full

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