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Case 9:09-cv-80591-KAM Document 70 Entered on FLSD Docket 08/07/2009 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 REPLY 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 October
15, 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 70 Entered on FLSD Docket 08/07/2009 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 August 21, 2009.
5. The parties continue to work together to find a resolution in this case.
6. 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.
7. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and
Plaintiff's counsel is in agreement with the requested extension.
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