Case 9:08-cv-80119-KAM Document 470 Entered on FLSD Docket 02/19/2010

Page 1 of 4 JANE DOE NO. 2, Plaintiff, vs. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON 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 MOTION FOR AN EXTENSION OF TIME TO COMPLETE DISCOVERY Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, and Plaintiff, JANE DOE, by and through her undersigned attorneys respectfully moves this Court for an extension of time to complete discovery deadlines, and as good cause in support of granting the motion, states as follows: I. This case is currently set on a two week trial docket commencing on July 19, 2010. 2. The Amended Complaint filed by the Plaintiff is still the subject of a Motion to Dismiss filed on June 12, 2009 (DE 87). Thus, an Answer has not yet been filed. 3. The majority of the deposition of Plaintiff has occurred; however, several witness depositions have yet to occur. Case 9:08-cv-80119-KAM Document 470 Entered on FLSD Docket 02/19/2010

Page 2 of 4 Jane Doe v. Epstein, et al. Page 2 4. The scheduling of depositions in this matter has become much more difficult since the case was consolidated on May 14, 2009, due to the number of attorneys involved and the fact that witnesses, plaintiffs and the defendant may only be deposed once. (See Order Consolidating Cases for Purpose of Discovery and Procedural Motions That Relate to Multiple Cases). 5. Due the fact that depositions are still being scheduled, both Plaintiff and Defendant are in agreement with extending the discovery cutoff an additional two (2) week from April 2, 2010, making the new discovery cutoff date April 16, 2010. WHEREFORE, Plaintiff and Defendant request that this Court enter an order granting the Motion for Extension of Time to Complete Discovery CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1 Counsel for the movant conferred via e-mail with counsel for the Plaintiff and counsel for the Plaintiff is in agreement with moving the above date. By: Isl Michael J. Pike MICHAEL J. PIKE, ESQ. Florida Bar #617296 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CMIECF. I also 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 CMIECF on this 19th day of February, 2010. Case 9:08-cv-80119-KAM Document 470 Entered on FLSD Docket 02/19/2010

Page 3 of 4 Jane Doe v. Epstein, et al. Page 3 Respectfully submitted, By: Isl Michael J. Pike ROBERT D. CRITTON, JR., ES 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 5611842-2820 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] Counsel for Plaint/ffe In related Cases Nos. 08-80069, 08-80119, 08- 80232, 08-8038~ 08-80381, 08-80993, 08- 80994 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 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 Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plaintiff Jane Doe Case 9:08-cv-80119-KAM Document 470 Entered on FLSD Docket 02/19/2010