Case 9:08-cv-80119-KAM Document 316 Entered on FLSD Docket 09/18/2009

Page 1 of 5 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 -------------~/ JOINT NOTICE OF AGREEMENT RELATIVE TO PLAINTIFF JANE DOE'S MOTIONS TO COMPEL RESPONSES TO ANSWERS TO INTERROGATORIES, REQUEST TO PRODUCE AND RESPONSES TO REQUEST FOR ADMISSIONS, AND UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO REMAINING PORTIONS STILL AT ISSUE Defendant, JEFFREY EPSTEIN, and Plaintiff, JANE DOE, by and through their undersigned counsel hereby file this JOINT NOTICE OF AGREEMENT RELATIVE TO PLAINTIFF JANE DOE'S MOTIONS TO COMPEL RESPONSES TO ANSWERS TO INTERROGATORIES, REQUEST TO PRODUCE AND RESPONSES TO REQUEST FOR ADMISSIONS, AND UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO REMAINING PORTIONS STILL AT ISSUE, and thns move this Court for an Extension of Time until October 6, 2009, to file Responses to Plaintiff Jane Doe's Motions to Compel Responses to Request to Produce, Responses to Request for Admissions, and Answers to Interrogatories, pursuant to Local Rule 7.1 A. 1 G)(S.D. Fla. 2008). As good cause for the requested extension, Defendant states: Case 9:08-cv-80119-KAM Document 316 Entered on FLSD Docket 09/18/2009

Page 2 of 5 1. Brad Edwards, Counsel for the Plaintiff, is scheduled to return to his office after having a surgical procedure on September 20, 2009. 2. Nonetheless, in a diligent effort to conserve on Judicial resources, attorney resources and in light of the court's order addressing the 5th Amendment issues at (DE 242 and 293) Mr. Edwards and the undersigned have been able to resolve via telephone several discovery requests, thereby relieving the court from having to address certain requests in the above Motions to Compel and any responses/replies thereto. Mr. Edwards does not waive his right to address those requests for which an agreement has been made. The Court has already ruled on certain discovery matters. Therefore, that is the binding law of the case, and Plaintiff maintains her objections to said discovery requests for purposes of any appeal. 3. In sum, the requests delineated below are simply moot for purposes of the court having to rule on same at this time. The Interrogatories 4. Initially, Plaintiffs Motion to Compel Answers to Interrogatories (DE 196) addressed interrogatories 1-23. 5. The undersigned attorneys have agreed that this court is relieved from having to currently rule on interrogatory numbers 1, 8, 9, 10, 11, 16, 18, 19, 20, 21 and 22. 6. Therefore, the remaining interrogatories in dispute are interrogatory numbers 2, 3, 4, 5, 6, 7, 12, 13, 14, 15, 17, and 23. The Requests for Production 7. Initially, Plaintiffs Motion to Compel Responses to Requests for Production (DE 210) addressed requests numbers 1-16. Case 9:08-cv-80119-KAM Document 316 Entered on FLSD Docket 09/18/2009

Page 3 of 5 8. The undersigned attorneys have agreed that this court is relieved from having to currently rule on request numbers 1, 2, 3, 4 and 6. 9. Therefore, the remaining requests in dispute are request numbers 5, 7, 8, 9, 10, 11, 12, 13, 14, 15 and 16. The Requests for Admissions 10. Initially, Plaintiffs Motion to Compel Responses to Requests for Admissions (DE 195) addressed requests numbers 1-23. 11. The undersigned attorneys have agreed that this court is relieved from having to currently rule on request for admission numbers 10, 11, 12, 13, 14, 15, 16, 17, 18, 19 and 20. 12. Therefore, the remaining requests for admissions in dispute are request numbers 1, 2, 3, 4, 5, 6, 7, 8, 9, 21, 22, and 23. 13. While the undersigned lawyers have resolved certain issues in the above motions to conserve on judicial resources, no admissions or waivers of objections have been made and no arguments are being abandoned. 14. Therefore, the undersigned attorneys have agreed that Defendant shall file his Response Motions to the above Motions to Compel relative to the requests at issue on or before October 2, 2009. Rule 7.1 A.3 Certification of Pre-Filing Conference Counsel for Defendant conferred with Counsel for Plaintiff by telephone and/or electronic mail, and Counsel for Plaintiff is in agreement 'th th Flori Case 9:08-cv-80119-KAM Document 316 Entered on FLSD Docket 09/18/2009

Page 4 of 5 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 served this day on all counsel of recqi;!;l identified on the following Service List in the manner specified by CM/ECF on this/~Tday of September, 2009 By: -4---,1-___::...._~:..._ __ ROBER . CRITTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 303 Banyan Blvd., Suite 400 West Palm Beach, FL 33401 561/842-2820 Phone 561/515-3148 Fax (Counsel for 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] 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 Case 9:08-cv-80119-KAM Document 316 Entered on FLSD Docket 09/18/2009