EFTA00286417.pdf

Case 1:17-cv-00616-JGK Document 48 Filed 06/15/17 Page 1 of 2 Case 1:1/-cv-0(1616-J6K Document 46 Filed 06/14/17 Page 1 of 2 Mchae. C V Mr 7'2 506 3955 mmitleresleGtoe cern :1'4 Avenue of Int AnlenCAS New Yoh, NY ICONS 213 506 3900 ma n vbw.11139(0• Car June 14. 2017 VIA ECF lion. John G. Kochi United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Jane Doc 43 v. Jeffrey Epstein, et al. Civil Action No. 17-ev-616 dfleicsou Dear Judge Kochi: VII/ 2 te '"P • ") • 1 am counsel to Defendants Jeffrey Epstein ("Epstein") and ("M'') in the above-referenced matter. I write to request that the briefing schedule for defendants' motion to dismiss be extended because I am presently engaged in a trial before Judge J. Paul °eaten in a matter captioned United States v. Block, 16 cr. 595 (JPO). The trial is scheduled through July 7, 2017. Pursuant to the Stipulation and Order of May 15, 2017, plaintiff filed the First Amended Complaint on June 5. 2017, and defendants have until June 26. 2017 to move to dismiss. We respectfully request that the date for filing of the motion to dismiss be extended to twn weeks after the completion of my trial, and that the briefing schedule be adjusted as follows: current schedule requested schedule Date for filing of motion June 26.2017 July 17, 2017 Date for filing of opposition July 26, 2017 August 17, 2017 Date for filing of reply August 9,2017 August 31, 2017 We also respectfully request on account of my trial schedule that the conference scheduled for July 6, 2017 be adjourned. EFTA00286417  Case 1:17-cv-00616-JGK Document 48 Filed 06/15/17 Page 2 of 2 Case 1:17-cv-00616-JGK Document 46 Filed 06/14/17 Page 2 of 2 lion. John G. Koch) Steptoe tulot • C-nt:. 1.6P June 14, 2017 Page 2 We arc advised that defendant joins in this request. Alter calling counsel for Plaintiff on June 12 and 13, we (-mailed him on Junc 13 with the above request and explanation for the request to sec if Plaintiff would consent. Plaintiff has not responded to our request. Given the fast approaching deadline, we are writing to the court at this time with our request. This is the first request for an extension of this briefing schedule. We previously made one request to adjourn the conference from May 22. 2017 because, as we explained in our May 18, 2017 letter to the court, it made practical sense to have the conference after Plaintiff has tiled the amended complaint. Respectfully submitted, Michael C. Miller _4xe.P Counselfor Defendants Jeffrey Epstein and EFTA00286418