Case 9:08-cv-80119-KAM Document 466 Entered on FLSD Docket 02/10/2010

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 ______________ __:! REPLY TO PLAINTIFF JANE DOE'S OBJECTION TO EXTENSION OF TIME TO FILE APPEAL AND, IN THE ALTERNATIVE, REQUEST FOR DIRECTION TO EPSTEIN TO BEGIN ASSEMBLING MATERIALS Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned attorneys, hereby files his Reply to Plaintiff, Jane Doe's Objection to Extension of Time to File Appeal and, in the Alternative, Request for Direction to Epstein to Begin Assembling Materials [DE 465], and states: 1. Bradley J. Edwards ("Edwards"), formerly of Rothstein Rosenfeldt & Adler, P.A. ("RRA"), requested that a stay be entered during the time he was in the process of assembling and forming his new law practice. 2. Edwards formally made his request for a stay in the two state court matters in which he is counsel for the plaintiffs. Judge Hafele granted his request, entered a stay, and the cases were removed from the trial docket. Case 9:08-cv-80119-KAM Document 466 Entered on FLSD Docket 02/10/2010

Page 2 of 4 3. Subsequent to the implosion of RRA, Edwards contacted the undersigned law firm and advised that he had been locked out of his office, had no access to his computer or files (including the instant Federal case), and therefore had no way to litigate matters. 4. In turn, the undersigned, as a courtesy, did not schedule depositions, IMEs, and the like relative to Edwards' client while Edwards was organizing his new law practice and regaining access to his files. As a result, this case was delayed at Edwards' request not the Defendant's. 5. Now that Edwards has established his new law firm, Edwards wishes to push this matter by ignoring, or simply forgetting that the undersigned law finn has in excess often (10) related cases. 6. The extension requested by the Defendant is not designed to delay this matter; it is simply to provide an adequate amount of time to address what are serious 5th Amendment issues. WHEREFORE, Defendant Epstein requests that the Court grant Epstein's Motion for an Extension of Time to File a Rule 4 Appeal allowing the Epstein an additional fifteen (I 5) days to file his Appeal making it due on or before ch 5, 2010. By: __,e,_ ______ _ Robert D. Critton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 Case 9:08-cv-80119-KAM Document 466 Entered on FLSD Docket 02/10/2010

Page 3 of 4 Certificate of Service I HEREBY CERTIFY that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by electronic mail (e-mail) on this 10th day of February, 2010. Florida Bar No. [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/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 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 [email protected] Counsel for Plaintiff in Related Case No. 08-80893 Case 9:08-cv-80119-KAM Document 466 Entered on FLSD Docket 02/10/2010