014.pdf
30.9 KB
Extraction Summary
15
People
7
Organizations
3
Locations
1
Events
4
Relationships
3
Quotes
Document Information
Type:
Legal filing (response to motion)
File Size:
30.9 KB
Summary
This document is a legal response filed on August 22, 2008, by Jeffrey Epstein's legal team in the case of Jane Doe vs. Jeffrey Epstein, Haley Robson, and Sarah Kellen. Epstein's lawyers state they have no opposition to the plaintiff's Motion to Preserve Evidence (DE 12). However, they dispute the plaintiff's certification of compliance, arguing that plaintiff's counsel filed the motion prematurely without properly conferring with the defense or waiting for a return call regarding Epstein's position.
People (15)
| Name | Role | Context |
|---|---|---|
| Jane Doe / Jane Doe #1 | Plaintiff |
Plaintiff in Case No. 08-80804-CIV-MARRA/JOHNSON
|
| Jeffrey Epstein | Defendant |
Primary defendant responding to the motion
|
| Haley Robson | Defendant |
Co-defendant listed in case caption
|
| Sarah Kellen | Defendant |
Co-defendant listed in case caption
|
| Kathryn Meyers | Attorney |
Defense counsel for Epstein (Lewis Tein law firm); received call from plaintiff's counsel
|
| Michael R. Tein | Attorney |
Defense counsel for Epstein; signer of the document
|
| Guy A. Lewis | Attorney |
Defense counsel for Epstein
|
| Jack A. Goldberger | Attorney |
Defense counsel for Epstein
|
| Theodore J. Leopold | Attorney |
Counsel for Plaintiff Jane Doe
|
| Spencer Kuvin | Attorney |
Counsel for Plaintiff Jane Doe
|
| Douglas M. McIntosh | Attorney |
Counsel for Defendant Haley Robson
|
| Jason A. McGrath | Attorney |
Counsel for Defendant Haley Robson
|
| Bruce E. Reinhart | Attorney |
Counsel for Defendant Sarah Kellen
|
| Robert D. Critton | Attorney |
Co-Counsel for Jeffrey Epstein
|
| Michael J. Pike | Attorney |
Co-Counsel for Jeffrey Epstein
|
Organizations (7)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of Florida |
Court where the case is filed
|
|
| Lewis Tein, P.L. |
Law firm representing Jeffrey Epstein
|
|
| Atterbury, Goldberger & Weiss, P.A. |
Law firm representing Jeffrey Epstein
|
|
| Ricci-Leopold, P.A. |
Law firm representing Plaintiff Jane Doe
|
|
| McIntosh, Sawran, Peltz & Cartaya, P.A. |
Law firm representing Haley Robson
|
|
| Bruce E. Reinhart, P.A. |
Law firm representing Sarah Kellen
|
|
| Burman, Critton, Luttier & Coleman, LLP |
Law firm representing Jeffrey Epstein
|
Timeline (1 events)
2008-08-22
Filing of Epstein's Response to Motion to Preserve Evidence
Southern District of Florida
Locations (3)
| Location | Context |
|---|---|
|
Address of Lewis Tein, P.L.
|
|
|
Address of various law firms involved
|
|
|
Address of Ricci-Leopold, P.A.
|
Relationships (4)
Plaintiff vs Defendant in case caption
Listed as defendants together
Listed as defendants together
Service list identifies Reinhart as 'Counsel for Defendant Sarah Kellen'
Key Quotes (3)
"In fact, Epstein has no opposition to the relief requested."Source
014.pdf
Quote #1
"That certification is inaccurate."Source
014.pdf
Quote #2
"Plaintiff’s counsel - - without waiting to hear back from us - - electronically filed the motion, incorrectly certifying that we had actually opposed it."Source
014.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (4,016 characters)
Case 9:08-cv-80804-KAM Document 14 Entered on FLSD Docket 08/22/2008 Page 1 of 4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-80804-CIV-MARRA/JOHNSON
JANE DOE, a/k/a
JANE DOE #1,
JANE DOE #1,
Plaintiff,
vs.
JEFFREY EPSTEIN, HALEY ROBSON,
and SARAH KELLEN,
and SARAH KELLEN,
Defendants.
_________________________________/
_________________________________/
EPSTEIN’S RESPONSE TO
MOTION TO PRESERVE EVIDENCE [DE 12]
MOTION TO PRESERVE EVIDENCE [DE 12]
Defendant Jeffrey Epstein hereby responds to the plaintiff Jane Doe’s motion to preserve
evidence, as follows:
evidence, as follows:
1. The Certificate of Compliance annexed to the plaintiff’s motion states that
plaintiff’s “counsel conferred with counsel for [Mr. Epstein] . . . and [Epstein’s] counsel advised
that [Epstein] oppose[s] this motion.” DE 12 at 2 (emphasis added). That certification is
inaccurate.
plaintiff’s “counsel conferred with counsel for [Mr. Epstein] . . . and [Epstein’s] counsel advised
that [Epstein] oppose[s] this motion.” DE 12 at 2 (emphasis added). That certification is
inaccurate.
2. On August 21, 2008, counsel for the plaintiff called Kathryn Meyers, Esq. of the
Lewis Tein law firm to elicit Epstein’s position on this motion. Ms. Meyers responded that she
would confer with Mr. Tein and call them back. Less than thirty minutes later, however,
plaintiff’s counsel - - without waiting to hear back from us - - electronically filed the motion,
incorrectly certifying that we had actually opposed it.
Lewis Tein law firm to elicit Epstein’s position on this motion. Ms. Meyers responded that she
would confer with Mr. Tein and call them back. Less than thirty minutes later, however,
plaintiff’s counsel - - without waiting to hear back from us - - electronically filed the motion,
incorrectly certifying that we had actually opposed it.
3. Upon receipt of the motion via CM/ECF, Ms. Meyers immediately notified
plaintiff’s counsel of their error. Plaintiff’s counsel did not notify the court of the incorrect
plaintiff’s counsel of their error. Plaintiff’s counsel did not notify the court of the incorrect
Case 9:08-cv-80804-KAM Document 14 Entered on FLSD Docket 08/22/2008 Page 2 of 4
certification, leaving the Court with the impression that Epstein opposed the motion and perhaps
prompting the Court to order an expedited response.
prompting the Court to order an expedited response.
4. In fact, Epstein has no opposition to the relief requested.
5. It is worth noting that the motion for return of property filed in the State criminal
matter has not been noticed for a hearing, has not been argued or ruled upon, and no property has
been returned.
matter has not been noticed for a hearing, has not been argued or ruled upon, and no property has
been returned.
Respectfully submitted,
LEWIS TEIN, P.L.
3059 Grand Avenue, Suite 340
Coconut Grove, Florida 33133
Tel: 305 442 1101
Fax: 305 442 6744
3059 Grand Avenue, Suite 340
Coconut Grove, Florida 33133
Tel: 305 442 1101
Fax: 305 442 6744
By: /s/ Michael R. Tein
GUY A. LEWIS
Fla. Bar No. 623740
lewis@lewistein.com
MICHAEL R. TEIN
Fla. Bar No. 993522
tein@lewistein.com
KATHRYN A. MEYERS
Fla. Bar No. 0711152
kmeyers@lewistein.com
GUY A. LEWIS
Fla. Bar No. 623740
lewis@lewistein.com
MICHAEL R. TEIN
Fla. Bar No. 993522
tein@lewistein.com
KATHRYN A. MEYERS
Fla. Bar No. 0711152
kmeyers@lewistein.com
ATTERBURY, GOLDBERGER & WEISS, P.A.
250 Australian Avenue South, Suite 1400
West Palm Beach, Florida 33401
Tel. 561 659 8300
Fax. 561 835 8691
250 Australian Avenue South, Suite 1400
West Palm Beach, Florida 33401
Tel. 561 659 8300
Fax. 561 835 8691
By: Jack A. Goldberger
Fla. Bar No. 262013
jgoldberger@agwpa.com
Fla. Bar No. 262013
jgoldberger@agwpa.com
Attorneys for Defendant Jeffrey Epstein
2
Case 9:08-cv-80804-KAM Document 14 Entered on FLSD Docket 08/22/2008 Page 3 of 4
3
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on August 22, 2008, I electronically filed the foregoing
document with the Clerk of Court using CM/ECF. I also certify that the foregoing document is
being served this day on all counsel of record identified on the attached Service List in the
manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF
or in some other authorized manner for those counsel or parties who are not authorized to receive
Notices of Electronic Filing.
document with the Clerk of Court using CM/ECF. I also certify that the foregoing document is
being served this day on all counsel of record identified on the attached Service List in the
manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF
or in some other authorized manner for those counsel or parties who are not authorized to receive
Notices of Electronic Filing.
/s/ Michael R. Tein
Michael R. Tein
Michael R. Tein
Case 9:08-cv-80804-KAM Document 14 Entered on FLSD Docket 08/22/2008 Page 4 of 4
4
Service List
Service List
Theodore J. Leopold, Esq.
Spencer Kuvin, Esq.
Ricci-Leopold, P.A.
2925 PGA Blvd., Suite 200
Palm Beach Gardens, FL 33410
Fax: 561 697 2383
Counsel for Plaintiff Jane Doe
Spencer Kuvin, Esq.
Ricci-Leopold, P.A.
2925 PGA Blvd., Suite 200
Palm Beach Gardens, FL 33410
Fax: 561 697 2383
Counsel for Plaintiff Jane Doe
Douglas M. McIntosh, Esq. (by fax and U.S. Mail)
Jason A. McGrath, Esq.
McIntosh, Sawran, Peltz & Cartaya, P.A.
Centurion Tower
1601 Forum Place, Suite 1110
West Palm Beach, Florida 33401
Fax. 561 682-3206
Counsel for Defendant Haley Robson
Jason A. McGrath, Esq.
McIntosh, Sawran, Peltz & Cartaya, P.A.
Centurion Tower
1601 Forum Place, Suite 1110
West Palm Beach, Florida 33401
Fax. 561 682-3206
Counsel for Defendant Haley Robson
Bruce E. Reinhart, Esq. (by fax and U.S. Mail)
Bruce E. Reinhart, P.A.
250 Australian Avenue South
Suite 1400
West Palm Beach, Florida 33401
Fax. 561 828 0983
Counsel for Defendant Sarah Kellen
Bruce E. Reinhart, P.A.
250 Australian Avenue South
Suite 1400
West Palm Beach, Florida 33401
Fax. 561 828 0983
Counsel for Defendant Sarah Kellen
Robert D. Critton, Esq. (by fax and U.S. Mail)
Michael J. Pike, Esq.
Burman, Critton, Luttier &
Coleman, LLP
515 N. Flagler Drive, Suite 400
West Palm Beach, Florida 33401
Fax. 561 515 3148
Co-Counsel for Jeffrey Epstein
Michael J. Pike, Esq.
Burman, Critton, Luttier &
Coleman, LLP
515 N. Flagler Drive, Suite 400
West Palm Beach, Florida 33401
Fax. 561 515 3148
Co-Counsel for Jeffrey Epstein
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