QaaTaairiiks ?RarRigittl% F§Wacbc54991t6 pagf di (4f 4 United States District Co Southern District of New Plaintiff, Case No.: 15-cv-07433-RWS USDC SDNY DOCUMENT ET .ECTRONICAT TY FILED DOC #: DATE FILED: (.0 (O Ho v. Ghislainc Maxwell, Defendant. MOTION FOR EXTENSION OF TIME TO RESPOND TO 24-PAGE MOTION ON ATTORNEY-CLIENT WAIVER ISSUES Plaintiff by and through her undersigned counsel, hereby files this Motion for Extension of Time, and hereby states as follows: On the evening of Thursday. May 26, 2016, Defendant filed a "Motion to Compel All Attorney-Client Communications and Attorney Work Product Placed at Issue by Plaintiff and Her Attorneys." The motion was 24 pages long and raises a host of issues regarding alleged waivers of attorney-client communications and work-product protections in those areas. One of counsel (Mr. Cassell) will be drafting the response to the motion, because most of the factual allegations in the motion relate to his actions as an attorney. Mr. Cassell has longstanding travel plans over the Memorial Day weekend, which will take him away from his office from Saturday, May 28, 2016, to Tuesday, May 31, 2016. On Wednesday, June 1, 2016, Mr. Cassell will fly from Utah to this Court for oral argument on several motions in this case. On Thursday, June 2, 2016, Mr. Cassell will argue those motions and then fly home to his office in Utah. Under the local rules, it appears that the response to the motion is due the next day, 1 0---1.doci_e-? cr EFTA02797981