Case 9:08-cv-80119-KAM Document 71 Entered on FLSD Docket 04/06/2009

Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, V. JEFFREY EPSTEIN, Defendant. ---------------'/ Defendant's Motion For Extension Of Time In Which To Respond To Plaintiff's Motion For Protective Order And To Quash Subpoena For Deposition Of Jane Doe No. 3. Motion To Consolidate Cases For Purposes Of Discovery. And Incorporated Memorandum Of Law 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 Plaintiff's Motion For Protective Order And To Quash Subpoena For Deposition Of Jane Doe No. 3, Motion To Consolidate Cases For Purposes Of Discovery, And Incorporated Memorandum Of Law ("Motion"). Local General Rule 7.1 A.1 and Rule 6, Fed. R. Civ. P. (2009). Defendant seeks an extension until April 13, 2009 to file his response. As good cause in support of granting the motion, Defendant states: 1. Defendant's response to the Motion is due on or about April 6, 2009. 2. Plaintiff's counsel also represents five (5) other Plaintiffs pursuing claims against Defendant, EPSTEIN, most of which have filed similar Motions. In order to fully and adequately respond to this and the other motions, Defendant is in need of an extension until April 13, 2009. Case 9:08-cv-80119-KAM Document 71 Entered on FLSD Docket 04/06/2009

Page 2 of 3 Jane Doe No. 2 v. Epstein Page2 3. In addition to the multiple motions, good cause for the extension also includes that counsel has been attempting to resolve discovery issues in this and other cases against Defendant, EPSTEIN; an associate of Defendant's undersigned counsel who works extensively on this case is currently out of the office and the undersigned was working on and has filed between 12-15 motions and responses in the various cases during the time these motions were filed. 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 to this and the other motions. In addition, this action is still at its early stages. 5. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and Plaintiff's counsel is in agreement with the requested extension. WHEREFORE, Defendant requests that this Court enter an order granting an Defendant an extension until April 13, 2009, in which to respond to the Above Motion. Local Rule 7.1 Statement Counsel for the movant conferred by telephone with counsel for the Plaintiff and Counsel for Plaintiff is in agreement with the requested extension until April 13, 2009 for Defendant to respond to the Motion. stein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being Case 9:08-cv-80119-KAM Document 71 Entered on FLSD Docket 04/06/2009