022.pdf
31.9 KB
Extraction Summary
6
People
2
Organizations
1
Locations
3
Events
3
Relationships
2
Quotes
Document Information
Type:
Legal motion (unopposed motion for enlargement of time)
File Size:
31.9 KB
Summary
This document is an unopposed motion filed on December 3, 2009, by Plaintiff Jane Doe No. 8 in the Southern District of Florida, requesting an extension of time until December 14, 2009, to file an Amended Complaint against Jeffrey Epstein. The request cites obligations of the plaintiff's counsel, Stuart Mermelstein and Adam Horowitz, in other matters, including other Epstein cases. The defendant's counsel, identified in the service list as Jack Alan Goldberger and Robert D. Critton, did not object to the extension.
People (6)
| Name | Role | Context |
|---|---|---|
| Jane Doe No. 8 | Plaintiff |
Party filing the motion for extension of time
|
| Jeffrey Epstein | Defendant |
Defendant in the civil case
|
| Stuart S. Mermelstein | Attorney |
Attorney for Plaintiff, Mermelstein & Horowitz, P.A., signing the motion
|
| Adam D. Horowitz | Attorney |
Attorney for Plaintiff, Mermelstein & Horowitz, P.A.
|
| Jack Alan Goldberger | Attorney |
Counsel for Defendant (Epstein), listed on Service List
|
| Robert D. Critton | Attorney |
Counsel for Defendant (Epstein), listed on Service List
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of Florida |
Court where the case is filed
|
|
| Mermelstein & Horowitz, P.A. |
Law firm representing the Plaintiff
|
Timeline (3 events)
2009-11-18
Court entered Opinion and Order on Defendant Epstein's Motion to Dismiss (DE 18), dismissing Count III of Plaintiff's Complaint without prejudice.
United States District Court, Southern District of Florida
2009-12-03
Plaintiff filed Unopposed Motion for Enlargement of Time to File Amended Complaint.
United States District Court, Southern District of Florida
Jane Doe No. 8
Stuart Mermelstein
Locations (1)
| Location | Context |
|---|---|
|
Location of Mermelstein & Horowitz, P.A. office
|
Relationships (3)
Stuart Mermelstein files motion on behalf of Plaintiff Jane Doe No. 8
Listed on Service List as counsel receiving service for the case against Epstein
Listed on Service List as counsel receiving service for the case against Epstein
Key Quotes (2)
"Plaintiffs’ counsel has conferred with Defendant’s counsel regarding this request for enlargement of time, and there are no objections to Plaintiff’s request."Source
022.pdf
Quote #1
"Plaintiff requests this extension of time due to obligations of Plaintiff’s counsel in other cases and matters, including other Epstein cases."Source
022.pdf
Quote #2
Full Extracted Text
Complete text extracted from the document (2,890 characters)
Case 9:09-cv-80802-KAM Document 22 Entered on FLSD Docket 12/03/2009 Page 1 of 4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-CV-80802-MARRA/JOHNSON
JANE DOE NO. 8,
Plaintiff,
vs.
vs.
JEFFREY EPSTEIN,
Defendant.
____________________________________/
____________________________________/
PLAINTIFF JANE DOE NO. 8’S UNOPPOSED MOTION FOR
ENLARGEMENT OF TIME TO FILE AMENDED COMPLAINT
ENLARGEMENT OF TIME TO FILE AMENDED COMPLAINT
Plaintiff, Jane Doe No. 8, by and through undersigned counsel, hereby files this
Unopposed Motion for Enlargement of Time to File Amended Complaint, and states as
follows:
Unopposed Motion for Enlargement of Time to File Amended Complaint, and states as
follows:
1. On November 18, 2009, this Court entered an Opinion and Order on
Defendant Epstein’s Motion to Dismiss (DE 18), dismissing Count III of Plaintiff’s
Complaint without prejudice, with leave to amend the Complaint in compliance with the
Court’s Order.
Defendant Epstein’s Motion to Dismiss (DE 18), dismissing Count III of Plaintiff’s
Complaint without prejudice, with leave to amend the Complaint in compliance with the
Court’s Order.
2. Plaintiff seeks an enlargement of time until December 14, 2009, to file
her Amended Complaint in accordance with the November 18th Order. Plaintiff requests
this extension of time due to obligations of Plaintiff’s counsel in other cases and matters,
including other Epstein cases.
her Amended Complaint in accordance with the November 18th Order. Plaintiff requests
this extension of time due to obligations of Plaintiff’s counsel in other cases and matters,
including other Epstein cases.
3. This Motion seeks a brief enlargement of time and is not brought for purposes
of undue delay.
of undue delay.
4. Plaintiffs’ counsel has conferred with Defendant’s counsel regarding this
Case 9:09-cv-80802-KAM Document 22 Entered on FLSD Docket 12/03/2009 Page 2 of 4
request for enlargement of time, and there are no objections to Plaintiff’s request.
WHEREFORE, Plaintiff, Jane Doe No. 8, respectfully requests an Order granting an
enlargement of time until December 14, 2009, to file her Amended Complaint in the above-
captioned matter.
enlargement of time until December 14, 2009, to file her Amended Complaint in the above-
captioned matter.
Dated: December 3, 2009.
Respectfully submitted,
By: s/ Stuart Mermelstein
Stuart S. Mermelstein (FL Bar No. 947245)
ssm@sexabuseattorney.com
Adam D. Horowitz (FL Bar No. 376980)
ahorowitz@sexabuseattorney.com
MERMELSTEIN & HOROWITZ, P.A.
Attorneys for Plaintiffs
18205 Biscayne Blvd., Suite 2218
Miami, Florida 33160
Tel: (305) 931-2200
Fax: (305) 931-0877
Stuart S. Mermelstein (FL Bar No. 947245)
ssm@sexabuseattorney.com
Adam D. Horowitz (FL Bar No. 376980)
ahorowitz@sexabuseattorney.com
MERMELSTEIN & HOROWITZ, P.A.
Attorneys for Plaintiffs
18205 Biscayne Blvd., Suite 2218
Miami, Florida 33160
Tel: (305) 931-2200
Fax: (305) 931-0877
2
Case 9:09-cv-80802-KAM Document 22 Entered on FLSD Docket 12/03/2009 Page 3 of 4
3
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE
I hereby certify that on December 3, 2009, I electronically filed the foregoing
document with the Clerk of the Court using CM/ECF. I also certify that the foregoing
document is being served this day to all parties 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 parties who are not authorized to receive
electronically Notices of Electronic Filing.
document with the Clerk of the Court using CM/ECF. I also certify that the foregoing
document is being served this day to all parties 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 parties who are not authorized to receive
electronically Notices of Electronic Filing.
/s/ Stuart Mermelstein
Case 9:09-cv-80802-KAM Document 22 Entered on FLSD Docket 12/03/2009 Page 4 of 4
4
SERVICE LIST
DOE vs. JEFFREY EPSTEIN
United States District Court, Southern District of Florida
SERVICE LIST
DOE vs. JEFFREY EPSTEIN
United States District Court, Southern District of Florida
Jack Alan Goldberger, Esq.
jgoldberger@agwpa.com
jgoldberger@agwpa.com
Robert D. Critton, Esq.
rcritton@bclclaw.com
rcritton@bclclaw.com
/s/ Stuart Mermelstein
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