Extraction Summary

7
People
4
Organizations
3
Locations
2
Events
3
Relationships
3
Quotes

Document Information

Type: Legal motion (unopposed motion for extension of time)
File Size: 140 KB
Summary

This document is an unopposed motion filed on June 18, 2009, in the US District Court for the Southern District of Florida (Case No. 09-80656) by Jeffrey Epstein's legal team. Epstein requests an extension until July 5, 2009, to respond to a complaint filed by Jane Doe No. 102, citing the workload from multiple concurrent cases where he is a defendant. The document confirms that Plaintiff's counsel agreed to this extension and lists the legal representatives for both parties.

People (7)

Name Role Context
Jeffrey Epstein Defendant
Seeking extension of time to respond to complaint.
Jane Doe No. 102 Plaintiff
Plaintiff in civil suit against Epstein.
Robert D. Critton, Jr. Attorney
Counsel for Defendant Jeffrey Epstein; submitting attorney.
Robert C. Josefsberg Attorney
Counsel for Plaintiff.
Katherine W. Ezell Attorney
Counsel for Plaintiff.
Jack Alan Goldberger Attorney
Counsel for Defendant Jeffrey Epstein.
Michael J. Pike Attorney
Counsel for Defendant Jeffrey Epstein.

Organizations (4)

Name Type Context
United States District Court Southern District of Florida
Venue of the lawsuit.
Podhurst Orseck, P.A.
Firm representing the Plaintiff.
Atterbury Goldberger & Weiss, P.A.
Firm representing the Defendant.
Burman, Critton, Luttier & Coleman
Firm representing the Defendant.

Timeline (2 events)

2009-05-01
Plaintiff filed Complaint [DE 1]
Southern District of Florida
2009-06-18
Filing of Motion for Extension of Time
Southern District of Florida
Jeffrey Epstein Robert D. Critton

Locations (3)

Location Context
Address for Podhurst Orseck, P.A.
Address for Atterbury Goldberger & Weiss, P.A.
Address for Burman, Critton, Luttier & Coleman.

Relationships (3)

Jeffrey Epstein Attorney-Client Robert D. Critton, Jr.
Listed as Counsel for Defendant Jeffrey Epstein
Jeffrey Epstein Attorney-Client Jack Alan Goldberger
Listed as Counsel for Defendant Jeffrey Epstein
Jane Doe No. 102 Legal Adversary Jeffrey Epstein
Plaintiff vs Defendant in Case 09-80656

Key Quotes (3)

"Defendant seeks an extension until July 5, 2009, to file his response."
Source
034.pdf
Quote #1
"There are several other cases filed with this Court in which Jeffrey Epstein is named a Defendant."
Source
034.pdf
Quote #2
"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"
Source
034.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (3,218 characters)

Case 9:09-cv-80656-KAM Document 34 Entered on FLSD Docket 06/18/2009 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-80656-MARRA/JOHNSON
JANE DOE No. 102,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant,
DEFENDANT JEFFREY EPSTEIN’S UNOPPOSED MOTION FOR EXTENSION
OF TIME IN WHICH SERVE RESPONSIVE PLEADING 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, May 1, 2009. Defendant seeks an extension until July 5, 2009, to file
his response. As good cause in support of granting the motion, Defendant states:
1. On May 1, 2009 Plaintiff filed a Complaint [DE 1]. Defendant’s response would
be due on June 22, 2009, as previously agreed upon.
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.
3. 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.
4. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and
Plaintiff’s counsel is in agreement with the requested extension.
Case 9:09-cv-80656-KAM Document 34 Entered on FLSD Docket 06/18/2009 Page 2 of 3
Doe 102 v. Epstein
Page 2
WHEREFORE Defendant respectfully requests that this Court enter an order
granting an extension until July 5, 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 July 5, 2009 for Defendant to respond to Plaintiff’s Complaint.
Robert D. Critton, Esq.
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 18th day of June, 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
rjosefsberg@podhurst.com
kezell@podhurst.com
Counsel for Plaintiff
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
jagesg@bellsouth.net
Counsel for Defendant Jeffrey Epstein
Respectfully submitted,
By: __________________
ROBERT D. CRITTON, JR., ESQ.
Florida Bar No. 224162
rcrit@bclclaw.com
Case 9:09-cv-80656-KAM Document 34 Entered on FLSD Docket 06/18/2009 Page 3 of 3
Doe 102 v. Epstein
Page 3
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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