UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092, ____________________________________/ PLAINTIFFS’ JANE DOE NOS. 2-7 AND JEFFREY EPSTEIN’S JOINT MOTION FOR AN EXTENSION OF TIME TO COMPLETE TRIAL DEADLINES Plaintiffs, Jane Doe Nos. 2-7, and Defendant Jeffrey Epstein, by and through their undersigned attorneys, jointly move this Court for an extension of time to complete trial deadlines, and as good cause in support of granting the motion, state as follows: 1. These cases are currently set on a two week trial docket commencing on June 1, 2010. The discovery cutoff is presently December 11, 2009. 2. Despite the cooperative efforts of counsel, discovery has proceeded slowly in these cases for various reasons. The depositions of the Plaintiffs Jane Does 2-7 have been the subject of motion practice. Presently, one partial deposition of a Plaintiff has been taken, that of Jane Doe No. 4. The depositions of Jane Does Nos. 2, 3, 5, 6, and 7 have not yet been scheduled. Plaintiffs and Defendant have stipulated to the Rule 35 examinations of the Plaintiffs, and thus far only two of the Plaintiffs’ examinations have been completed. Case 9:08-cv-80119-KAM Document 415 Entered on FLSD Docket 11/18/2009

Page 1 of 3 2 3. There are pending discovery disputes, including Plaintiffs’ appeal of Magistrate Johnson’s Order dated September 9, 2009 on Plaintiffs’ Motion to Compel, and Plaintiffs’ Motion to Compel Net Worth Discovery. The scheduling of nonparty depositions has been difficult because many of the depositions are out-of-state and these depositions need to be coordinated with all Plaintiffs’ counsel in these cases, which are consolidated for purposes of discovery. Additionally, a substantial majority of the nonparties subpoenaed by Plaintiffs have retained separate counsel, requiring that their depositions be coordinated with the witness’s attorney. As a result, a significant number of nonparty depositions remain to be taken. Additionally, witness’s attorneys have raised various issues which have delayed these depositions. 4. Based on the foregoing, the parties jointly move for an extension of the pretrial deadlines, which the parties believe is necessary despite their best efforts to complete discovery in a timely manner. The parties propose the following revised schedule: A. Date to complete mediation April 7, 2010 B. Date to complete discovery April 12, 2010 C. Date to complete substantive pretrial motions May 7, 2010 D. Date to disclose experts and Exchange expert reports: July 1, 2010 E. Proposed Pre-trial conference August, 2010 F. Proposed Trial September, 2010 WHEREFORE, Plaintiffs Jane Doe Nos. 2-7 and Defendant, Jeffrey Epstein, jointly request that this Court enter an Order granting this Motion for Extension of Time to Complete Trial Deadlines, in accordance with the revised schedule set forth above. Case 9:08-cv-80119-KAM Document 415 Entered on FLSD Docket 11/18/2009

Page 2 of 3 3 Dated: November 18, 2009. Respectfully submitted, By: /s/ Adam D. Horowitz MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs Jane Doe 2-7 Stuart S. Mermelstein [email protected] Adam D. Horowitz [email protected] 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: (305) 931-2200 By: /s/ Michael J. Pike BURMAN, CRITTION, LUTTIER et al. Attorneys for Defendant Epstein Robert D. Critton, Jr. [email protected] Michael J. Pike [email protected] 515 N. Flagler Drive Suite 400 West Palm Beach, FL 33401 Case 9:08-cv-80119-KAM Document 415 Entered on FLSD Docket 11/18/2009