Case 9:08-cv-80119-KAM Document 491 Entered on FLSD Docket 03/18/2010

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 --------------~/ DEFENDANT'S MOTION FOR EXTENSION OF TIME TO FILE REPLY TO PLAINTIFF, JANE DOE'S, RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL (485) Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his undersigned attorneys, respectfully moves this Court for an Extension of Time in which to Reply to Plaintiff, Jane Doe's, Response in Opposition to Defendant's Motion for Reconsideration and/or Request for Rule 4 Review and Appeal. Defendant seeks an additional four (4) day extension until March 26, 2010 to file his Reply. As good cause in support of granting the motion, Defendant states: !. On February 4, 2010 this Court entered an Omnibus Order granting in part and denying in part Plaintiffs Motions to Compel Responses to Requests for Production (DE 462). 2. On February 26, 2010 Defendant filed his Motion for Reconsideration and/or Request for Rule 4 Review and Appeal (DE 477). Case 9:08-cv-80119-KAM Document 491 Entered on FLSD Docket 03/18/2010

Page 2 of 4 3. On March 10, 2010 Plaintiff filed her Response in Opposition to Defendant's Motion for Reconsideration and/or Request for Rule 4 Review and Appeal (DE 485). 4. Defendant's Reply to Plaintiffs Response in Opposition is currently due on March 22, 2010. 5. Robert D. Critton, counsel for the Defendant, is currently out of town and Michael J. Pike, counsel for the Defendant, has attended three (3) depositions in related matters this week and therefore needs a simple four ( 4) days extension to file Defendant's Reply. 6. While this request is reasonable, counsel for the Defendant has spoken to counsel for the Plaintiff and he is not in agreement with the requested four (4) day extension. 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 the movant conferred by e-mail with counsel for the Plaintiff and Counsel for Plaintiff is not in agreement with the requested extension. By: Isl Michael J. Pike \\ ~ ROBERT D. CRITTON, JR. ~ Florida Bar #224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 Case 9:08-cv-80119-KAM Document 491 Entered on FLSD Docket 03/18/2010

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 18th day of March, 2010. Respectfully submitted, By: /s/ Micha . Pike ROBERT D. 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] Counsel for Plaint/ffe 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 Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room 101 Case 9:08-cv-80119-KAM Document 491 Entered on FLSD Docket 03/18/2010