Extraction Summary

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

Document Information

Type: Legal motion (unopposed motion for extension of time)
File Size: 124 KB
Summary

This document is an unopposed motion filed on March 23, 2010, in the United States District Court for the Southern District of Florida, requesting an extension of time for Jeffrey Epstein to respond to a complaint filed by Jane Doe No. 103. Epstein's legal team requests the deadline be moved from March 26 to April 5, 2010, citing workload from 'several other cases' filed in the same court in which Epstein is a defendant. The plaintiff's counsel agreed to this extension.

People (7)

Name Role Context
Jane Doe No. 103 Plaintiff
Plaintiff in Case No. 10-80309-CIV-Marra/Johnson
Jeffrey Epstein Defendant
Defendant in civil suit; requesting extension of time
Michael J. Pike Attorney
Counsel for Defendant Jeffrey Epstein; signed the motion
Robert D. Critton, Jr. Attorney
Counsel for Defendant Jeffrey Epstein
Robert C. Josefsberg Attorney
Counsel for Plaintiff
Katherine W. Ezell Attorney
Counsel for Plaintiff
Jack Alan Goldberger Attorney
Counsel for Defendant Jeffrey Epstein

Organizations (4)

Name Type Context
United States District Court Southern District of Florida
Court where the case is filed
Podhurst Orseck, P.A.
Law firm representing the Plaintiff
Atterbury Goldberger & Weiss, P.A.
Law firm representing the Defendant
Burman, Critton, Luttier & Coleman
Law firm representing the Defendant

Timeline (4 events)

2010-02-23
Plaintiff filed Complaint [DE 1]
Southern District of Florida
2010-03-23
Service of Motion for Extension of Time via CM/ECF
Electronic Filing
Michael J. Pike Robert D. Critton
2010-03-26
Original deadline for Defendant's response
Southern District of Florida
2010-04-05
Requested new deadline for Defendant's response
Southern District of Florida

Locations (2)

Location Context
Location of Plaintiff's counsel
Location of Defendant's counsel

Relationships (4)

Jane Doe No. 103 Legal Adversary Jeffrey Epstein
Plaintiff vs Defendant in Case No. 10-80309-CIV-Marra/Johnson
Michael J. Pike Legal Counsel Jeffrey Epstein
Signed motion as Counsel for Defendant
Robert D. Critton Legal Counsel Jeffrey Epstein
Listed as Attorney for Defendant
Jack Alan Goldberger Legal Counsel Jeffrey Epstein
Listed as Counsel for Defendant

Key Quotes (3)

"There are several other cases filed with this Court in which Jeffrey Epstein is named a Defendant."
Source
006.pdf
Quote #1
"In those cases, the undersigned has been preparing responses and replies to various motions, and handling other matters associated therewith."
Source
006.pdf
Quote #2
"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."
Source
006.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (3,177 characters)

Case 9:10-cv-80309-KAM Document 6 Entered on FLSD Docket 03/25/2010 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 10-80309-CIV-Marra/Johnson
JANE DOE No. 103,
Plaintiff,
vs.
JEFFERY EPSTEIN,
Defendant.
___________ /
DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION
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, February 23, 2010. Defendant seeks an extension until April 5, 2010,
to file his response. As good cause in support of granting the motion, Defendant states:
1. On February 23, 2010 Plaintiff filed a Complaint [DE 1]. Defendant's response
would be due on March 26, 2010.
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 and
replies to various motions, 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.
1
Case 9:10-cv-80309-KAM Document 6 Entered on FLSD Docket 03/25/2010 Page 2 of 3
WHEREFORE Defendant respectfully requests that this Court enter an order granting
an extension until April 5, 2010 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 April 5, 2010 for Defendant to respond to Plaintiff's Complaint.
/s/ Michael J. Pike
Robert D. Critton, Attorney for
Defendant Epstein
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 23rd day of March, 2010.
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: /s/ Michael J. Pike
ROBERT D. CRITTON, JR., ESQ.
Florida Bar No. 224162
rcrit@bclclaw.com
2
Case 9:10-cv-80309-KAM Document 6 Entered on FLSD Docket 03/25/2010 Page 3 of 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)
3

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