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Case 9:09-cv-80656-KAM Document 62 Entered on FLSD Docket 12/02/2009 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-80656-MARRA/JOHNSON
JANE DOE No. 102,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant,
______________/
DEFENDANT JEFFREY EPSTEIN'S MOTION FOR EXTENSION
OF TIME IN WHICH SERVE RESPONSIVE PLEADING 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, May 1, 2009 [DE 1). Defendant seeks an extension until December
15, 2009, to file his response. As good cause in support of granting the motion,
Defendant states:
1. On May 1, 2009 Plaintiff filed a Complaint [DE 1). Defendant's response would
be due on August 20, 2009, as previously agreed upon.
2. The parties continue to work together to find a resolution in this case and are
close to a resolution. In addition, parties have agreed to numerous extensions while
negotiating a resolution.
3. The implosion of the Rothstein Rosenfeldt & Adler, PA firm has raised certain
questions for which defense counsel will request answers/information from Plaintiff's
counsel regarding the Rothstein scheme/scandal prior to final resolution.
Case 9:09-cv-80656-KAM Document 62 Entered on FLSD Docket 12/02/2009 Page 2 of 3
Doe 102 v. Epstein
Page 2
4. The requested extension is fair and 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
Plaintiff's counsel is in not agreement with the requested extension.
WHEREFORE Defenda
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