EPSTEIN
page 8 / 178 . OCR, unverified
associated therewith.
3. Additionally, Defendant's counsel is in the midst of preparing for a state court
trial, CARDIOPULMONARY & PRIMARY CARE ASSOC. OF TREASURE COAST, P.A
v. LEWIS, M.D., Case No. 562008CA001726, specially set for trial beginning May 13
Case 9:09-cv-80469-KAM Document 7 Entered on FLSD Docket 05/01/2009 Page 2 of 3
Jane Doe II v. Epstein, et al.
Page2
through 15, 2009). Discovery in that case is ongoing with several depositions set to
prepare for trial.
4. An extension until May 6, 2009, is fair and reasonable under the circumstances.
The undersigned is in need of the additional time in order to fully and adequately
prepare a response on behalf of EPSTEIN.
5. As certified below, counsel for Defendant conferred with Plaintiff's counsel
counsel by telephone, and Plaintiff's counsel is in agreement with the requested
extension.
WHEREFORE Defendant respectfully requests that this Court enter an order
granting an extension until May 6, 2009, to file a Response to Plaintiff's Complaint.
Local Rule 7.1 Statement
Counsel for the movant conferred by telephone with counsel for the Plaintiff and
Counsel for Plaintiff is in agreement with the requested extension until May 6, 2009 for
Defendant to file a Response to Plaintiff's Comp-la-i~JA_._{_(_J+----------,-
Robert D. ~tton, Jr. Attorney for
Defendant Epstein
Certificate of Service
I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
the Clerk of the Court using CM/ECF. 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 via transmission of Notices of Electronic Filing generated by CM/ECF
on this ~
day of ...Mfil!..., 2009:
Isidro M. Garcia, Esq.
Garcia Law Firm, P.A.
224 Datura Street, Suite 900
West Palm Beach, FL 33401
Jack Alan Goldberger, Esq.
Atterbury Goldberger & Weiss, P.A.
250 Australian Avenue South
Suite 1400
Case 9:09-cv-80469-KAM Document 7 Entered on FLSD Docket 05/01/2009 Page 3 of 3
Jane Doe II v. Epstein, et al.
Page3
561-832-7732
561-832-7137 F
isidrogarcia@bellsouth.net
Counsel for Plaintiff
West Palm Beach, FL 33401-5012
561-659-8300
561-835-8691 Fax
jagesg@bellsouth.net
Co-Counsel for Defendant Jeffrey Epstein
TTON, JR., ESQ.
Florida Bar No.
24162
rcrit@bclclaw.com
MICHAEL J. PIKE, ESQ.
Florida Bar #617296
mpike@bclclaw.com
BURMAN, CRITTON, LUTTIER & COLEMAN
515 N. Flagler Drive, Suite 400
West Palm Beach, FL 33401
561-842-2820
Fax: 561-515-3148
(Co-counsel for Defendant Jeffrey Epstein)
==================== END OF Court Records__Doe v. Epstein, No. 909-v-80469 (S.D. Fla. 2009)__007.txt ====================
==================== DOCUMENT: Court Records__Doe v. Epstein, No. 909-v-80469 (S.D. Fla. 2009)__009.txt ====================
METADATA_SOURCE: Court RecordsDoe v. Epstein, No. 909-v-80469 (S.D. Fla. 2009)
METADATA_FILENAME: 009.pdf
----------------------------------------
Case 9:09-cv-80469-KAM Document 9 Entered on FLSD Docket 05/04/2009 Page 1 of 5
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-CIV- 80469 - MARRA/JOHNSON
JANE DOE 11,
Plaintiff,
V.
JEFFREY EPSTEIN,
Defendant.
I
-------------
DEFENDANT EPSTEIN'S RESPONSE IN OPPOSITION TO THIS COURT'S ORDER TO
SHOW CAUSE AS WHY ALL CASES SHOULD NOT BE CONSOLIDATED FOR DISCOVERY
PURPOSES AND MOTION TO CLARIFY THE COURT'S ORDER DATED APRIL 28, 2009
Defendant, JEFFERY EPSTEIN, (EPSTEIN), by and through his undersigned
attorneys, hereby files his Response in Opposition to this Court's Order to Show Cause
as to Why All Cases Should Not be Consolidated for Purposes of Discovery and Motion
for Clarification of this Court's Order on general consolidation of discovery (DE 6), and
states:
I.
Response In Opposition
Defendant has no further objections to consolidating these cases for
purposes of depositions as outlined in this Court's April 28, 2009 Order.
However, to consolidate the cases for purposes of all "discovery" including, but
not limited to, motion practice and related orders thereto will, without question, confuse
many of the individual discovery issues raised not only by Epstein as to the individual
Plaintiffs that have brought separate lawsuits against him, but will also confuse the
individual discovery issues raised by those same individual Plaintiffs as to Epstein. This
Case 9:09-cv-80469-KAM Document 9 Entered on FLSD Docket 05/04/2009 Page 2 of 5
Page2
will undoubtedly lead to several motions to clarify certain orders which will seek
explanation from the court as to how those orders affect Epstein as to each individual
Plaintiff's discovery requests and vice versa (i.e., how those future orders affect the
individual Plaintiffs' discovery requests directed to Epstein).
It is important to note that each related Federal matter before this court has its
very own distinct set of facts and defenses thereto. As such, the discovery served and