Document DOJ-COURT-265 is a Defendant's Unopposed Motion for Extension filed in the United States District Court for the Southern District of Florida, related to the case of Jane Doe No. 2 vs. Jeffrey Epstein.
This legal document requests an extension of time for Jeffrey Epstein to file a Supplementary Response Brief regarding production requests in the case 08-CIV-80119-MARRA/JOHNSON. The motion cites the breadth of the 5th Amendment and logistical challenges of Epstein's attorneys as reasons for needing a 12-day extension, moving the due date to August 31, 2009. Several related cases are listed, suggesting this is part of a larger series of legal actions.

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Glenn M. Anderson, Lyle Cook, Jack Goldberger, et al., Appellants, v. Frank M. Jordan, as Secretary of State of the State of California. U.S. Supreme ... of Record with Supporting Pleadings
Case 9:08-cv-80119-KAM Document 265 Entered on FLSD Docket 08/13/2009
Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ______________ ___!/ Related cases: 08-80232,08-08380,08-80381,08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591,09-80656,09-80802,09-81092 I DEFENDANT'S, UNOPPOSED MOTION FOR EXTENSION DIRECTED TO THE COURT IN CONNECTION WITH TIDS COURT'S ORDER DATED AUGUST 4, 2009 {DE242) Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, and pursuant to the applicable rules as well as this court's discretion, respectfully moves this Court for an extension of time in which to serve his Supplementary Response Brief in connection with this Court's Order (DE 242) and production requests 10, 11, 18, 19, and 21. As good cause in support of granting the motion, Defendant states: 1. This court entered an order (DE 242) stating that Epstein may provide a Supplementary Response Brief relative to production requests numbers 10, 11, 18, 19, and 21. See DE 242. Accordingly, the Supplementary Response Brief is due August 19, 2009. Case 9:08-cv-80119-KAM Document 265 Entered on FLSD Docket 08/13/2009
Page 2 of 4 2. Defendant will be providing such a supplementary response brief. However, given the breadth of the 5th Amendment addressing the above requests, the Defendant respectfully requests an additional 12 days within which to file same. As such, Defendant requests that the due date effectively be moved to August 31, 2009. 3. The undersigned, Michael J. Pike, has a status conference in front of the Honorable Judge Huck in Miami, Florida on August 14, 2009. In addition, the undersigned, Robert D. Critton, Jr., Esq., is out-of-town. Moreover, the undersigned attorneys are moving their entire office and staff to a new location/address. 4. This request is not made to delay and will not prejudice any of the parties. 5. While this request is within the sound discretion of the court pursuant to Rule 4, the undersigned has consulted with opposing counsel and he has agreed. Wherefore, the undersigned respectfully requests the relief sought herein, and for such other and further relief as this court deems just and proper. Local Rule 7.1 Statement Counsel for Plaintiff is in agreement with the requeste Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed wifu fue Cl~k ofnre O,w, relog CM/ECF. I ,I,o ~he foregolog dornm~t is being served this day on all counsel of re/~rd identi \ , following Service List in the manner specified by CM/ECF on this day of II , 2009. Respectfully submitted, Case 9:08-cv-80119-KAM Document 265 Entered on FLSD Docket 08/13/2009
Page 3 of 4 N, JR., ESQ. Florida B o. 224162 rcrit bclclaw.com MICH~ L J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561/842-2820 Phone 561/515-3148 Fax (Counsel/or Defendant Jeffrey Epstein) Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 [email protected] [email protected] Counsel for Plaintiffs In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone:954-522-3456 Fax: 954-527-8663 [email protected] Counsel for Plaintiff in Related Case No. 08-80893 Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room IOI Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel/or Plaintiff Jane Doe Fax: 561-588-8819 Isidro M. Garcia, Esq. Counsel for Plaint/ff in Related Case No. Garcia Law Firm, P.A. Case 9:08-cv-80119-KAM Document 265 Entered on FLSD Docket 08/13/2009








