Case 1:15-cv-07433-LAP Document 446 Page 1 of 8 Filed 09/27/16 Courtesy ropy United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RW v. Ghislaine Maxwell, Defendant. PLAINTIFF MOTION FOR AN EXTENSION OF TIME TO GOW SERVE PROCESS UPON AND DEPOSE Plaintiff, hereby submits this Motion for Extension of Time to Serve Process upon and Depose M Gow. Even though Mr. Gow is Defendant's press agent — and is represented by one of Defendant's attorneys -- Defendant has refused to assist in making him available for a deposition. And, Mr. Gow has been attempting to thwart service of process in England, now necessitating the intervention of an English court. Accordingly, additional time from this Court for to serve him for a deposition. l <747 4 : e 71 44 . seeks : 7; 4‘ 0ii egya et7 tn fe n The parties have conferred about this request for an extension of time. Defendan a torney, take Mr. Ms. Menninger, has represented that she is willing to agree to a thirty-day c to Gow's deposition. That would extend the deadline until August 30, 2016. ow r, Defendant's other attorney, Mr. Barden, who now also represents Mr. Gow, has informe the undersigned that his "client is away on holiday and is not back in London until September." See July 19, 2016, letter from Philip Barden. See McCawley Decl. at Exhibit 9. Accordingly, it is clear that the allotted time for extension that Defendant's first attorney proposed will be insufficient because Defendant's second attorney has said Defendant's agent is unavailable during that time. Moreover, it is likely that the process to procure an order from and English court directing Mr. Gow to sit for his de sition will exceed thirty-days plus the six remaining days in this month. Accordingly, seeks an extension of time beyond thirncdays in order to take Mr. Gow's deposition. USDC SDNY 1 DOCUMENT VS'or i2-27/ 4" ELECTRONICALLY FILED DOC #: DATE FILED: EFTA02801058