041.pdf

Case 9:09-cv-80591-KAM Document 41 Entered on FLSD Docket 06/04/2009 Page 1 of 8

FILING FEE
PAID 75.00
In Forma 725904
Pauperis Steven M. Larimore, Clerk

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

Case No. 9:09-CV-80591-KAM

Jane Doe 101,
Plaintiff,
vs.
Jeffrey Epstein,
Defendant.

FILED by D.C.
JUN - 4 2009
STEVEN M. LARIMORE
CLERK U.S. DIST. CT.
S.D. OF FLA. - W.P.B.

MOTION FOR LIMITED APPEARANCE, CONSENT TO
DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE
NOTICES OF ELECTRONIC FILINGS

In accordance with Local Rule 4.B of the Special Rules Governing the Admission and
Practice of Attorneys of the United States District Court for the Southern District of Florida, the
undersigned respectfully moves for the admission of Jay P. Lefkowitz, P.C., of the law firm of
Kirkland & Ellis LLP (Citigroup Center, 153 East 53rd Street, New York, New York 10022-
4611, Telephone: 212-446-4970), for purposes of limited appearance as co-counsel on behalf of
Defendant Jeffrey Epstein herein, in the above-styled case only, and pursuant to Rule 2B,
Southern District of Florida, CM/ECF Administrative Procedures, to permit Jay P. Lefkowitz,
P.C. to receive electronic filings in this case, and in support thereof states as follows:

1. Jay P. Lefkowitz is not admitted to practice in the Southern District of Florida and
is a member in good standing of the bars of the State of New York and District of Columbia, and
is admitted to practice before the United States Supreme Court, the United States Courts of
Appeals for the District of Columbia Circuit, Second Circuit, Fourth Circuit, Fifth Circuit,
Eighth Circuit, Ninth Circuit, and Eleventh Circuit, the United States District Courts for the

Case 9:09-cv-80591-KAM Document 41 Entered on FLSD Docket 06/04/2009 Page 2 of 8
District of Columbia, Southern District of New York, Eastern District of Michigan, Eastern
District of Wisconsin, and District of Colorado, and the United States Tax Court.

2. Movant, Robert D. Critton, Jr., Esquire, of the law firm of Burman Critton Luttier
& Coleman, P.A. (515 N. Flagler Drive, Suite 400, West Palm Beach, FL 33401, Telephone:
561-842-2820), is a member in good standing of The Florida Bar and the United States District
Court for the Southern District of Florida, maintains an office in this State for the practice of law,
and is authorized to file through the Court's electronic filing system. Movant consents to be
designated as a member of the Bar of this Court with whom the Court and opposing counsel may
readily communicate regarding the conduct of the case, upon whom filings shall be served, who
shall be required to electronically file all documents and things that may be filed electronically,
and who shall be responsible for filing documents in compliance with the CM/ECF
Administrative Procedures. See Section 2B of the CM/ECF Administrative Procedures.

3. In accordance with the local rules of this Court, Jay P. Lefkowitz, P.C. has made
payment of this Court's $75 admission fee. A certification in accordance with Rule 4B is
attached hereto.

4. Jay P. Lefkowitz, P.C., by and through designated counsel and pursuant to
Section 2B, Southern District of Florida, CM/ECF Administrative Procedures, hereby requests
the Court to provide Notice of Electronic Filings to Jay P. Lefkowitz, P.C. at email address:
jay.lefkowitz@kirkland.com.

WHEREFORE, Robert D. Critton, Jr. moves this Court to enter an Order permitting Jay
P. Lefkowitz, P.C. to appear before this Court on behalf of Jeffrey Epstein for all purposes
relating to the proceedings in the above-styled matter and directing the Clerk to provide notice of
electronic filings to Jay P. Lefkowitz, P.C.

Case 9:09-cv-80591-KAM Document 41 Entered on FLSD Docket 06/04/2009 Page 3 of 8
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for Limited
Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic
Filings 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 21st 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
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
jagesq@bellsouth.net
Counsel for Defendant Jeffrey Epstein

Respectfully submitted,

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)

Case 9:09-cv-80591-KAM Document 41 Entered on FLSD Docket 06/04/2009 Page 4 of 8
Jane Doe 101,
Plaintiff,
vs.
Jeffrey Epstein,
Defendant.

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 9:09-CV-80591-KAM

CERTIFICATION OF JAY P. LEFKOWITZ

Jay P. Lefkowitz, P.C., Esquire, pursuant to Rule 4B of the Special Rules Governing the
Admission and Practice of Attorneys, hereby certifies that (1) I have studied the Local Rules of
the United States District Court for the Southern District of Florida; and (2) I am a member in
good standing of the bars of the State of New York and District of Columbia, and am admitted to
practice before the United States Supreme Court, the United States Courts of Appeals for the
District of Columbia Circuit, Second Circuit, Fourth Circuit, Fifth Circuit, Eighth Circuit, Ninth
Circuit, and Eleventh Circuit, the United States District Courts for the District of Columbia,
Southern District of New York, Eastern District of Michigan, Eastern District of Wisconsin, and
District of Colorado, and the United States Tax Court.

Jay P. Lefkowitz, P.C.

Case 9:09-cv-80591-KAM Document 41 Entered on FLSD Docket 06/04/2009 Page 5 of 8
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for Limited
Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic
Filings 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 21st 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
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
jagesq@bellsouth.net
Counsel for Defendant Jeffrey Epstein

Respectfully submitted,
By:
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)

Case 9:09-cv-80591-KAM Document 41 Entered on FLSD Docket 06/04/2009 Page 6 of 8
United States District Court
for the District of Columbia
CLERK'S OFFICE
333 Constitution Avenue, NW
Washington, DC 20001

I, NANCY M. MAYER-WHITTINGTON, Clerk of the United States
District Court for the District of Columbia, do hereby certify that:

JAY P. LEFKOWITZ

was, on the 2nd day of December A.D. 1996 admitted to practice as an Attorney
at Law at the Bar of this Court, and is, according to the records of this Court, a
member of said Bar in good standing.

In Testimony Whereof, I hereunto subscribe my name and affix the seal of said Court
in the City of Washington this 27th day of May A.D. 2009.

NANCY M. MAYER-WHITTINGTON, CLERK
By: Sheryl Horn Deputy Clerk

Case 9:09-cv-80591-KAM Document 41 Entered on FLSD Docket 06/04/2009 Page 7 of 8
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 9:09-CV-80591-KAM

Jane Doe 101,
Plaintiff,
vs.
Jeffrey Epstein,
Defendant.

ORDER GRANTING MOTION FOR LIMITED APPEARANCE OF
JAY P. LEFKOWITZ, P.C.,
CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY
RECEIVE NOTICES OF ELECTRONIC FILINGS

THIS CAUSE having come before the Court on the Motion for Limited Appearance of
Jay P. Lefkowitz, P.C. and Consent to Designation, requesting, pursuant to Rule 4B of the
Special Rules Governing the Admission and Practice of Attorneys in the United States District
Court for the Southern District of Florida, permission for a limited appearance of Jay P.
Lefkowitz, P.C. in this matter and request to electronically receive notice of electronic filings.
This Court having considered the motion and all other relevant factors, it is hereby
ORDERED and ADJUDGED that:
The Motion for Limited Appearance, Consent to Designation and Request to
Electronically Receive Notices of Electronic Filings is GRANTED. Jay P. Lefkowitz, P.C. is
granted to appear and participate in this action on behalf of Jeffrey Epstein. The Clerk shall
provide electronic notification of all electronic filings to Jay P. Lefkowitz, P.C. at
jay.lefkowitz@kirkland.com.

Case 9:09-cv-80591-KAM Document 41 Entered on FLSD Docket 06/04/2009 Page 8 of 8
Case No. 9:09-CV-80591-KAM

DONE AND ORDERED in Chambers at ___________, Florida this ________
day of ___________ _

United States District Judge
Copies furnished to:
All Counsel of Record