Document DOJ-COURT-553 is a legal motion filed in the United States District Court for the Southern District of Florida.
This document is an unopposed motion for an enlargement of time filed by the plaintiffs, Jane Does 2-7, to respond to Jeffrey Epstein's motions for summary judgment. The plaintiffs requested an additional 21 days to file their responses due to the volume of briefs and demands on their counsel, citing other ongoing cases. The motion was filed on June 1, 2010.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092, ____________________________________/ PLAINTIFFS JANE DOES 2-7’ UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE RESPONSES TO DEFENDANT’S MOTIONS FOR SUMMARY JUDGMENT (JANE DOE 2, DE 539; JANE DOE 3, DE 141; JANE DOE 4, DE 157; JANE DOE 5, DE 139; JANE DOE 6, DE 91; JANE DOE 7, DE 107) Plaintiffs, Jane Does 2-7, by and through undersigned counsel, file this Unopposed Motion for Enlargement of Time to File Response to Defendant’s Motions for Summary Judgment, (Jane Doe 2, DE 539; Jane Doe 3, DE 141; Jane Doe 4, DE 157; Jane Doe 5, DE 139; Jane Doe 6, DE 91; Jane Doe 7, DE 107), and state as follows: 1. Defendant Epstein filed separate Motions for Summary Judgment as to Jane Does 2-7 on May 6, 2010. 2. The Motions for Summary Judgment were each over thirty (30) pages, plus exhibits. There are over two hundred (200) pages of briefs to which Plaintiffs must respond. Plaintiffs request an enlargement of time of twenty-one (21) days, until and including June 22, Case 9:08-cv-80119-KAM Document 553 Entered on FLSD Docket 06/01/2010
Page 1 of 4 2010, to file their Responses. 3. Plaintiffs’ counsel requires an enlargement of time due to the sheer volume of the briefs and the demands on Plaintiffs’ counsel in this and other cases and matters, including Doe v. Discovery Day Care, Inc., case no. 09-64351 CA 30, Miami-Dade County Circuit Court; and Doe v. Waterford Kids Academy, Inc., case no. 09-CA-10377, Orange County Circuit Court; and Jane Doe No. 2 v. Archdiocese of Denver 4. Plaintiffs bring this Motion in good faith and not for purposes of undue delay. , case no. 2009 CV 4886, Denver County District Court. 5. Pursuant to S.D.Fla.L.R. 7.1(A), Plaintiffs’ counsel has conferred with counsel for Defendant regarding the relief sought in this Motion, who has advised Plaintiffs’ counsel that Defendant has no objection to the enlargement of time requested. WHEREFORE, Plaintiffs respectfully request an enlargement of time of twenty-one (21) days, until and including June 22, 2010, to file their Responses to Defendant’s Motions for Summary Judgment. Dated: June 1, 2010. Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: (305) 931-2200 Fax: (305) 931-0877 Case 9:08-cv-80119-KAM Document 553 Entered on FLSD Docket 06/01/2010
Page 2 of 4 CERTIFICATE OF SERVICE I hereby certify that on June 1, 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day to all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing. /s/ Adam D. Horowitz Case 9:08-cv-80119-KAM Document 553 Entered on FLSD Docket 06/01/2010
Page 3 of 4 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Bradley James Edwards [email protected] Isidro Manuel Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected] Richard Horace Willits [email protected] Robert C. Josefsberg [email protected] Case 9:08-cv-80119-KAM Document 553 Entered on FLSD Docket 06/01/2010



