Case 9:08-cv-80119-KAM Document 496 Entered on FLSD Docket 03/19/2010

Page 1 of 5 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON ------------------'/ 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 ------------------'/ AMENDED JOINT MOTION FOR AN EXTENSION OF TIME TO COMPLETE DISCOVERY DEADLINES AND SHORTEN EXPERT DISCLOSURES Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, and Plaintiffs, JANE DOES 2-7, by and through their 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: 1. These cases are currently set on a two week trial docket commencing on September 27, 2010. 2. The majority of the depositions of Plaintiffs have been taken but the majority have not been completed. A number of witness depositions have yet to occur. In fact, Defendant has over thirty (30) depositions that he believes are needed to complete discovery, dates for which Defendant's counsel requested from Plaintiffs' counsel on March 9, 2010. Plaintiffs Case 9:08-cv-80119-KAM Document 496 Entered on FLSD Docket 03/19/2010

Page 2 of 5 Jane Doe v. Epstein, et al. Page 2 counsel is working on the scheduling of these depositions. Additionally, the deposition of Jeffrey Epstein has not been completed, and Plaintiffs have additional depositions to take, some of which are out of state. 3. 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). Additionally, many of the witnesses retained their own counsel, and the depositions need to be coordinated with those attorneys' schedules. 5. Due to the fact that depositions are still being scheduled, both Plaintiffs and Defendant are in agreement with extending the discovery cutoff in Jane Does 2-4 an additional two (2) weeks from April 12, 2010, making the new discovery cutoff date April 30, 2010 and extending the discovery cutoff in Jane Does 5-7 to May 28, 2010. 6. Further, the current scheduling order requires expert reports to be disclosed on July 1, 2010. The parties have agreed to disclose the expert reports in Jane Does 2-4 on May 14, 2010 and in Jane Does 5-7 on June 7, 2010. WHEREFORE, Plaintiffs and Defendant request that this Court enter an order granting the Motion for Extension of Time to Complete Discovery Deadline and Shorten Expert Disclosures. CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1 Counsel for the parties conferred via e-mail and are in agreement with moving the above dates. Case 9:08-cv-80119-KAM Document 496 Entered on FLSD Docket 03/19/2010

Page 3 of 5 Jane Doe v. Epstein, et al. Page 3 By: Isl Robert D. Critton ROBERT D. CRITTON, ESQ. Florida Bar # 224162 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 CM/ECF on this 19th day of March, 2010. Respectfully submitted, By: Isl Robert D. Critton 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 5611842-2820 Phone 5611515-3148 Fax (Counsel for Defendant Jeffrey Epstein) Case 9:08-cv-80119-KAM Document 496 Entered on FLSD Docket 03/19/2010

Page 4 of 5 Jane Doe v. Epstein, et al. Page4 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 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian A venue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 [email protected] Counsel for Defendant Jeffrey Epstein Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 [email protected] [email protected] Counsel for Plaintiffs in Related Cases Nos. 09-80591 and 09-80656 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. ProHac Vice 332 South 1400 E, Room IOI Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F [email protected] Counsel for Plaintiff in Related Case No. 08- 80469 Case 9:08-cv-80119-KAM Document 496 Entered on FLSD Docket 03/19/2010