EFTA01112262.pdf

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800)CCXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO DISCOVERY Plaintiff/Counter-Defendant JEFFREY EPSTEIN ("Epstein"), by and through undersigned counsel and pursuant to the Florida Rules of Civil Procedure, hereby moves for an enlargement of time to respond to the discovery requests propounded by Defendant/Counter-PlztintiffBRADLEY J. EDWARDS on October 28, 2011. The grounds for this Motion are as follows: 1. On October 28, 2011, the Defendant/Counter-Plaintiff BRADLEY J. EDWARDS served by facsimile and U.S. Mail the following discovery requests on counsel for Epstein: a) Request to Produce to Jeffrey Epstein b) Interrogatories to Plaintiff 2. The deadline for responding to the discovery requests is November 28, 2011. 3. Due to the intervening holiday and the press of other business, Plaintiff requests an extension of fourteen (14) days within which to serve responses to the discovery requests. EFTA01112262  Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG 4. In addition, counsel for the Plaintiff understood all discovery was stayed pending all pleadings being at issue. On or about November 17, 2011, the Court ruled discovery will not be postponed until Edwards' Counterclaim withstands a Motion to Dismiss. 5. The Defendant/Counter-Plaintiff will not sustain any prejudice as a result of a short extension being granted to Plaintiff to respond to these discovery requests. 6. Undersigned counsel certifies that this request is made in good faith and not for the purpose of delay. The undersigned counsel further certifies that he has and will continue to make an effort to resolve this matter without the need of a hearing. WHEREFORE, the Plaintiff/Counter-Defendant Jeffrey Epstein respectfully requests that this Court grant an extension of fourteen (14) days, up to and including December 12, 2011, in which to serve his responses to the discovery requests. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via U.S. Mail on this 28'h day of November, 2011 to: Jack Scarola, Esq., Searcy Denney Scarola et al., 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401- 5012; and Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301. Respectfully submitted, 144 I. oselJh L. Ackerman, Jr. Florida Bar No. 235954 FOWLER WHITE BURNETT, P.A. -2 - EFTA01112263  Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: Facsimile: Attorneys for Plaintiff, Jeffrey Epstein and Christopher E. Knight Florida Bar. No. 607363 FOWLER WHITE BURNETT, P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131 Telephone: Facsimile: Attorneys for Plaintiff, Jeffrey Epstein -3- EFTA01112264