016.pdf
40.3 KB
Extraction Summary
6
People
3
Organizations
2
Locations
2
Events
3
Relationships
2
Quotes
Document Information
Type:
Legal motion (unopposed motion for enlargement of time)
File Size:
40.3 KB
Summary
This document is a legal motion filed on May 15, 2009, in the Southern District of Florida, case number 09-80469-CIV-MARRA. Plaintiff Jane Doe II requests an extension until May 22, 2009, to file a reply to Defendant Jeffrey Epstein's Motion to Dismiss, citing complex issues and other business. Epstein's counsel, Robert Critton, was consulted and did not oppose the extension.
People (6)
| Name | Role | Context |
|---|---|---|
| Jane Doe II | Plaintiff |
Filing motion for enlargement of time
|
| Jeffrey Epstein | Defendant |
Defendant in case 09-80469-CIV-MARRA; has filed a Motion to Dismiss
|
| Sarah Kellen | Defendant |
Named as co-defendant in the case caption
|
| Isidro M. Garcia | Attorney |
Counsel for Plaintiff Jane Doe II; filer of the motion
|
| Robert D. Critton | Attorney |
Counsel for Jeffrey Epstein; consulted regarding the extension and did not oppose it
|
| Michael Pike | Attorney |
Recipient of service; associated with Burman Critton Luttier & Coleman
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of Florida |
Court where the case is filed
|
|
| Garcia Law Firm, P.A. |
Law firm representing the Plaintiff
|
|
| Burman Critton Luttier & Coleman |
Law firm representing the Defendants
|
Timeline (2 events)
2009-05-15
Filing of Plaintiff's Unopposed Motion for Enlargement of Time
US District Court Southern District of Florida
2009-05-22
Proposed new deadline for Plaintiff's Reply to Defendant's Motion to Dismiss
US District Court Southern District of Florida
Locations (2)
| Location | Context |
|---|---|
|
Address of Garcia Law Firm
|
|
|
Address of Burman Critton Luttier & Coleman
|
Relationships (3)
Isidro M. Garcia signs as counsel for Plaintiff
Identified as Counsel for Jeffrey Epstein in text
Listed together as Defendants in case caption
Key Quotes (2)
"Plaintiff's counsel has been unable to finish the reply to said motion which raises many complex issues that are typically not addressed on a motion to dismiss."Source
016.pdf
Quote #1
"Counsel for Jeffrey Epstein, and he does not oppose an enlargement of time until Friday May 22, 2009"Source
016.pdf
Quote #2
Full Extracted Text
Complete text extracted from the document (1,962 characters)
Case 9:09-cv-80469-KAM Document 16 Entered on FLSD Docket 05/15/2009 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
SOUTHERN DISTRICT OF FLORIDA
JANE DOE II )CASE NO.: 09-80469-CIV-MARRA
)
Plaintiff, )
)
vs. )
)
JEFFREY EPSTEIN, )
and SARAH KELLEN, )
)
Defendants. )
/
)
Plaintiff, )
)
vs. )
)
JEFFREY EPSTEIN, )
and SARAH KELLEN, )
)
Defendants. )
/
PLAINTIFF’S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO SERVE
REPLY TO DEFENDANT, JEFFREY EPSTEIN’S, MOTION TO DISMISS
REPLY TO DEFENDANT, JEFFREY EPSTEIN’S, MOTION TO DISMISS
Plaintiff, JANE DOE II, respectfully requests an enlargement of time to serve her
Reply to Defendant, JEFFREY EPSTEIN’S, Motion to Dismiss, and would show in support:
1. The Reply to Defendant, JEFFREY EPSTEIN’S, Motion to Dismiss is due May
15, 2009. Due to the press of other business, Plaintiff’s counsel has been unable to finish
the reply to said motion which raises many complex issues that are typically not addressed
on a motion to dismiss.
2. Counsel certifies that he has today consulted with Robert Critton, Esq.,
Counsel for Jeffrey Epstein, and he does not oppose an enlargement of time until Friday
May 22, 2009, for Plaintiff to serve her Reply to Defendant, JEFFREY EPSTEIN’S, Motion
to Dismiss.
WHEREFORE, Plaintiff respectfully requests that the Court grant an extension to
serve the Reply to Defendant, JEFFREY EPSTEIN’S, Motion to Dismiss up to and including
May 22, 2009.
Reply to Defendant, JEFFREY EPSTEIN’S, Motion to Dismiss, and would show in support:
1. The Reply to Defendant, JEFFREY EPSTEIN’S, Motion to Dismiss is due May
15, 2009. Due to the press of other business, Plaintiff’s counsel has been unable to finish
the reply to said motion which raises many complex issues that are typically not addressed
on a motion to dismiss.
2. Counsel certifies that he has today consulted with Robert Critton, Esq.,
Counsel for Jeffrey Epstein, and he does not oppose an enlargement of time until Friday
May 22, 2009, for Plaintiff to serve her Reply to Defendant, JEFFREY EPSTEIN’S, Motion
to Dismiss.
WHEREFORE, Plaintiff respectfully requests that the Court grant an extension to
serve the Reply to Defendant, JEFFREY EPSTEIN’S, Motion to Dismiss up to and including
May 22, 2009.
Case 9:09-cv-80469-KAM Document 16 Entered on FLSD Docket 05/15/2009 Page 2 of 2
2
Respectfully submitted,
BY: s/ Isidro M. Garcia
ISIDRO M. GARCIA
Florida Bar No. 437883
GARCIA LAW FIRM, P.A.
224 Datura Street, Suite 900
West Palm Beach, FL 33401
Telephone:(561) 832-7732
Telecopier: (561) 832-7137
e-mail: isidrogarcia@bellsouth.net
Respectfully submitted,
BY: s/ Isidro M. Garcia
ISIDRO M. GARCIA
Florida Bar No. 437883
GARCIA LAW FIRM, P.A.
224 Datura Street, Suite 900
West Palm Beach, FL 33401
Telephone:(561) 832-7732
Telecopier: (561) 832-7137
e-mail: isidrogarcia@bellsouth.net
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished VIA
ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN
CRITTON LUTTIER & COLEMAN, 515 N. Drive, Suite 400, West Palm Beach, Florida
33401 this 15th day of May, 2009.
ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN
CRITTON LUTTIER & COLEMAN, 515 N. Drive, Suite 400, West Palm Beach, Florida
33401 this 15th day of May, 2009.
BY:s/ Isidro M. Garcia
ISIDRO M. GARCIA
ISIDRO M. GARCIA
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