011.pdf
146 KB
Extraction Summary
8
People
5
Organizations
3
Locations
4
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal motion (unopposed motion for extension of time)
File Size:
146 KB
Summary
This document is an unopposed motion filed on May 4, 2009, by Jeffrey Epstein's attorneys in the case of Jane Doe No. 101 v. Jeffrey Epstein (Case No. 09-80591) in the Southern District of Florida. Epstein's counsel requests an extension until May 26, 2009, to respond to the complaint filed on April 17, 2009. The reasons cited include the burden of other cases naming Epstein as a defendant and a conflicting state court trial scheduled for mid-May involving the defense counsel.
People (8)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Defendant |
Defendant in case 09-80591 requesting extension of time to respond to complaint.
|
| Jane Doe No. 101 | Plaintiff |
Plaintiff filing complaint against Epstein.
|
| Robert D. Critton, Jr. | Attorney |
Counsel for Defendant Jeffrey Epstein; filed the motion.
|
| Michael J. Pike | Attorney |
Counsel for Defendant Jeffrey Epstein.
|
| Robert C. Josefsberg | Attorney |
Counsel for Plaintiff.
|
| Katherine W. Ezell | Attorney |
Counsel for Plaintiff.
|
| Jack Alan Goldberger | Attorney |
Attorney listed on Service List (Atterbury Goldberger & Weiss, P.A.).
|
| Lewis, M.D. | Defendant (Unrelated Case) |
Defendant in a separate state court trial keeping Epstein's counsel busy.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of Florida |
Court where the case is filed.
|
|
| Burman, Critton, Luttier & Coleman |
Law firm representing Jeffrey Epstein.
|
|
| Podhurst Orseck, P.A. |
Law firm representing the Plaintiff.
|
|
| Atterbury Goldberger & Weiss, P.A. |
Law firm listed on service list.
|
|
| Cardiopulmonary & Primary Care Assoc. of Treasure Coast, P.A |
Plaintiff in an unrelated state court trial involving Epstein's counsel.
|
Timeline (4 events)
2009-05-11
2009-05-13
Start of state court trial (Cardiopulmonary vs Lewis) involving Defense counsel
State Court (Florida)
Robert D. Critton
Locations (3)
| Location | Context |
|---|---|
|
Jurisdiction of the court.
|
|
|
Location of Podhurst Orseck, P.A.
|
|
|
Location of Burman, Critton, Luttier & Coleman and Atterbury Goldberger & Weiss.
|
Relationships (2)
Motion states Critton is undersigned attorney for Epstein.
Plaintiff v. Defendant in Case No. 09-80591.
Key Quotes (3)
"Defendant seeks an extension until May 26, 2009, to file his response."Source
011.pdf
Quote #1
"There are several other cases filed with this Court in which Jeffrey Epstein is named a Defendant."Source
011.pdf
Quote #2
"Defendant's counsel is in the midst of preparing for a state court trial... specially set for trial beginning May 13 through 15, 2009)."Source
011.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (3,525 characters)
Case 9:09-cv-80591-KAM Document 11 Entered on FLSD Docket 05/04/2009 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-80591-MARRA/JOHNSON
JANE DOE No. 101,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant,
_____________/
_____________/
DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION
OF TIME IN WHICH TO RESPOND TO COMPLAINT
OF TIME IN WHICH TO RESPOND TO COMPLAINT
Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his undersigned
attorneys, respectfully moves this Court for an extension of time in which to respond to
Complaint dated, April 17, 2009. Defendant seeks an extension until May 26, 2009, to
file his response. As good cause in support of granting the motion, Defendant states:
attorneys, respectfully moves this Court for an extension of time in which to respond to
Complaint dated, April 17, 2009. Defendant seeks an extension until May 26, 2009, to
file his response. As good cause in support of granting the motion, Defendant states:
1. On April 17, 2009 Plaintiff filed a Complaint [DE 1]. Defendant's response would
be due on May 11, 2009.
be due on May 11, 2009.
2. There are several other cases filed with this Court in which Jeffrey Epstein is
named a Defendant. In those cases, the undersigned has been preparing responses to
Motions for Protective Order and handling other matters associated therewith.
named a Defendant. In those cases, the undersigned has been preparing responses to
Motions for Protective Order and handling other matters 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
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-80591-KAM Document 11 Entered on FLSD Docket 05/04/2009 Page 2 of 3
Doe 101 v. Epstein
Page 2
through 15, 2009). Discovery in that case is ongoing with several depositions set to
prepare for trial.
Doe 101 v. Epstein
Page 2
through 15, 2009). Discovery in that case is ongoing with several depositions set to
prepare for trial.
4. The requested extension is fair in reasonable under the circumstances as it will
provide time to allow the Defendant, EPSTEIN, to fully and adequately respond.
provide time to allow the Defendant, EPSTEIN, to fully and adequately respond.
5. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and
Plaintiff's counsel is in agreement with the requested extension.
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 26, 2009, to file a response to Plaintiff's Complaint.
granting an extension until May 26, 2009, to file a response to Plaintiff's Complaint.
Local Rule 7.1 Statement
Counsel for the movant conferred by telephone and correspondence with
counsel for the Plaintiff and Counsel for Plaintiff is in agreement with the requested
extension until May 26, 2009 for Defendant to respond to Plaintiff's Complaint.
counsel for the Plaintiff and Counsel for Plaintiff is in agreement with the requested
extension until May 26, 2009 for Defendant to respond to Plaintiff's Complaint.
Robert D. Critton, Esq.
Attorney for Defendant
Attorney for Defendant
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 by CM/ECF on this 4 day of May, 2009
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 by CM/ECF on this 4 day of May, 2009
Robert C. Josefsberg, Esq.
Katherine W. Ezell, Esq.
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800
Miami, FL 33130
305 358-2800
Fax: 305 358-2382
Katherine W. Ezell, Esq.
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800
Miami, FL 33130
305 358-2800
Fax: 305 358-2382
Jack Alan Goldberger, Esq.
Atterbury Goldberger & Weiss, P.A.
250 Australian Avenue South
Suite 1400
West Palm Beach, FL 33401-5012
561-659-8300
Fax: 561-835-8691
Atterbury Goldberger & Weiss, P.A.
250 Australian Avenue South
Suite 1400
West Palm Beach, FL 33401-5012
561-659-8300
Fax: 561-835-8691
Case 9:09-cv-80591-KAM Document 11 Entered on FLSD Docket 05/04/2009 Page 3 of 3
Doe 101 v. Epstein
Page 3
Doe 101 v. Epstein
Page 3
rjosefsberg@podhurst.com
kezell@podhurst.com
Counsel for Plaintiff
kezell@podhurst.com
Counsel for Plaintiff
jagesq@bellsouth.net
Counsel for Defendant Jeffrey Epstein
Counsel for Defendant Jeffrey Epstein
Respectfully submitted,
By: [Signature]
ROBERT D. CRITTON, JR., ESQ.
Florida Bar No. 224162
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 Phone
561/515-3148 Fax
(Counsel for Defendant Jeffrey Epstein)
ROBERT D. CRITTON, JR., ESQ.
Florida Bar No. 224162
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 Phone
561/515-3148 Fax
(Counsel for Defendant Jeffrey Epstein)
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