Case 9:08-cv-80119-KAM Document 503 Entered on FLSD Docket 03/26/2010

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, 08-8081 I, 08-80893, 09-80469, 09-80591,09-80656,09-80802,09-81092 ______________ __:! DEFENDANT'S MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO PLAINTIFFS JANE DOE NOS. 2-8', APPEAL PURSUANT TO S.D.FLA.MAG.4 AND OBJECTIONS AS TO MAGISTRATE JUDGE'S ORDER ON NET WORTH DISCOVERY (493) Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his undersigned attorneys, respectfully moves this Court for an Extension of Time in which to Respond to Plaintiffs, Jane Doe Nos. 2-8', Appeal Pursuant to S.D.Fla. Mag.R.4. Defendant seeks an additional ten (JO) business days until April 12, 2010 to file his Response. As good cause in support of granting the motion, Defendant states: I. On March 4, 2010 this Court entered an Order granting in part and denying in part Plaintiffs Motion to Compel Net Worth Discovery (DE 480). 2. On March 18, 2010, 2010 both the Defendant and the Plaintiffs filed Motions for Reconsideration and/or Request for Rule 4 Review and Appeal (Des 488 and 493). Case 9:08-cv-80119-KAM Document 503 Entered on FLSD Docket 03/26/2010

Page 2 of 4 3. Defendant's Response to Plaintiffs Jane Doe Nos. 2-8' Appeal Pursuant to S.D.Fla.Mag.R.4 and Objections to Magistrate Judge's Order on Net Worth Discovery is currently due on March 29, 2010. 4. As the Court is well aware, counsel for the Defendant is inundated with discovery requests, responses and replies, and just finalized and filed his Reply to Plaintiff, Jane Doe's, Response in Opposition to Defendant's Request for Rule 4 Review and Appeal relating to a previous Order entered by this Court. Further, counsel for the Defendant has been in attendance of several full day depositions both is these case and other unrelated matters. 6. While this request is reasonable, counsel for the Defendant has spoken to counsel for the Plaintiff and counsel for the Plaintiff is in agreement with five ( 5) business day extension, but not a ten (10) business 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 in agreement with a five (5) business day extension, but not a ten (I 0) business day 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 503 Entered on FLSD Docket 03/26/2010

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 26h day of March, 2010. Respectfully submitted, By: Isl Michael J. 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 5611842-2820 Phone 5611515-3148 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 Plaintiffs In related Cases Nos. 08-80069, 08-80119, 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. Case 9:08-cv-80119-KAM Document 503 Entered on FLSD Docket 03/26/2010