004.pdf
95.3 KB
Extraction Summary
9
People
3
Organizations
2
Locations
3
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal motion (motion to stay proceedings)
File Size:
95.3 KB
Summary
This is a Motion to Stay Proceedings filed on January 29, 2008, in the US District Court for the Southern District of Florida. Jane Doe's Mother (Intervenor-Plaintiff) requests the court pause the lawsuit against Jeffrey Epstein until Jane Doe No. 1 turns 18 on May 13, 2008. The motion reveals that Jane Doe No. 1 is estranged from her father (who filed the suit) and that the father filed the suit without her knowledge or consent.
People (9)
| Name | Role | Context |
|---|---|---|
| Jane Doe No. 1 | Plaintiff / Minor Child |
Subject of the motion; 17 years old; estranged from father; does not consent to lawsuit filed by father.
|
| Jane Doe's Father | Plaintiff / Parent |
Filed lawsuit against Epstein; estranged from daughter since Nov 22, 2007; divorced from mother.
|
| Jane Doe's Mother | Intervenor-Plaintiff / Parent |
Filing motion to stay proceedings; divorced from father; has submitted an affidavit.
|
| Jane Doe's Stepmother | Plaintiff |
Listed as a plaintiff individually.
|
| Jeffrey Epstein | Defendant |
Defendant in the civil lawsuit Case No. 08-80069.
|
| Theodore J. Leopold | Attorney |
Counsel for Intervenor-Plaintiff (Jane Doe's Mother); filed the motion.
|
| Jeffrey M. Herman | Attorney |
Recipient of electronic filing notice.
|
| Stuart S. Mermelstein | Attorney |
Recipient of electronic filing notice.
|
| Adam D. Horowitz | Attorney |
Recipient of electronic filing notice.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of Florida |
Venue of the lawsuit.
|
|
| Ricci-Leopold, P.A. |
Firm representing Theodore J. Leopold.
|
|
| Herman Law |
Implied by email domains of opposing counsel.
|
Timeline (3 events)
2007-11-22
Thanksgiving Day; Start of estrangement between Jane Doe No. 1 and Jane Doe's Father.
Unknown
2008-01-29
Filing of Motion to Stay Proceedings.
United States District Court Southern District of Florida
Locations (2)
| Location | Context |
|---|---|
|
Jurisdiction
|
|
|
Address of Ricci-Leopold, P.A.
|
Relationships (3)
Document states she has been estranged from him since Nov 22, 2007.
Document states they are divorced.
Jane Doe No. 1 is listed as Plaintiff vs Jeffrey Epstein.
Key Quotes (4)
"JANE DOE NO. 1 will be 18 on May 13, 2008."Source
004.pdf
Quote #1
"JANE DOE NO. 1 has been estranged from JANE DOE'S FATHER since Thanksgiving Day, November 22, 2007."Source
004.pdf
Quote #2
"JANE DOE'S FATHER filed this lawsuit against Defendant Jeffrey Epstein without the knowledge, consultation or consent of JANE DOE NO. 1."Source
004.pdf
Quote #3
"JANE DOE NO. 1 does not want this lawsuit to be prosecuted on her behalf by JANE DOE'S FATHER."Source
004.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (2,951 characters)
Case 9:08-cv-80069-KAM Document 4 Entered on FLSD Docket 01/29/2008 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-80069 CIV-MARRA/JOHNSON
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-80069 CIV-MARRA/JOHNSON
JANE DOE NO.1, by and through
JANE DOE's FATHER as parent and natural
guardian, and JANE DOE's FATHER, and
JANE DOE's STEPMOTHER, individually,
Plaintiffs,
JANE DOE's FATHER as parent and natural
guardian, and JANE DOE's FATHER, and
JANE DOE's STEPMOTHER, individually,
Plaintiffs,
JANE DOE'S MOTHER, individually and as parent
and natural guardian of JANE DOE NO. 1,
Intervenor-Plaintiff,
and natural guardian of JANE DOE NO. 1,
Intervenor-Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
/
MOTION TO STAY PROCEEDINGS PENDING JANE
DOE NO. 1 REACHING AGE OF MAJORITY
Defendant.
/
MOTION TO STAY PROCEEDINGS PENDING JANE
DOE NO. 1 REACHING AGE OF MAJORITY
JANE DOE'S MOTHER, individually and as parent and natural guardian of JANE DOE
NO. 1, by and through the undersigned counsel, moves the Court to stay these proceedings
pending JANE DOE NO. 1 reaching the age of majority, and as grounds for said motion states as
follows:
NO. 1, by and through the undersigned counsel, moves the Court to stay these proceedings
pending JANE DOE NO. 1 reaching the age of majority, and as grounds for said motion states as
follows:
1. JANE DOE NO. 1 is a minor child, 17 years of age, who is under the joint control of her
parents and natural guardians, JANE DOE'S FATHER and JANE DOE'S MOTHER, who are
divorced.
parents and natural guardians, JANE DOE'S FATHER and JANE DOE'S MOTHER, who are
divorced.
2. JANE DOE NO. 1 will be 18 on May 13, 2008. See affidavit of JANE DOE'S MOTHER
(attached hereto as EXHIBIT "A").
(attached hereto as EXHIBIT "A").
3. JANE DOE NO. 1 has been estranged from JANE DOE'S FATHER since Thanksgiving
Day, November 22, 2007. See Exhibit "A" (Affidavit of JANE DOE'S MOTHER).
Day, November 22, 2007. See Exhibit "A" (Affidavit of JANE DOE'S MOTHER).
Case 9:08-cv-80069-KAM Document 4 Entered on FLSD Docket 01/29/2008 Page 2 of 2
4. JANE DOE'S FATHER filed this lawsuit against Defendant Jeffrey Epstein without the
knowledge, consultation or consent of JANE DOE NO. 1. See Exhibit "A" (Affidavit of JANE
DOE'S MOTHER).
knowledge, consultation or consent of JANE DOE NO. 1. See Exhibit "A" (Affidavit of JANE
DOE'S MOTHER).
5. JANE DOE NO. 1 does not want this lawsuit to be prosecuted on her behalf by JANE
DOE'S FATHER. See Exhibit "A" (Affidavit of JANE DOE'S MOTHER).
DOE'S FATHER. See Exhibit "A" (Affidavit of JANE DOE'S MOTHER).
6. Pursuant to Local Rule 7.1.A.3, counsel for Intervenor-Plaintiff JANE DOE'S
MOTHER, in a good faith attempt to resolve this dispute, made a reasonable effort to confer with
all parties who may be affected by this motion to stay. Counsel for Intervenor-Plaintiff JANE
DOE'S MOTHER conferred with Counsel for JANE DOE'S FATHER, who do not agree to the
Court entering a stay in this action.
MOTHER, in a good faith attempt to resolve this dispute, made a reasonable effort to confer with
all parties who may be affected by this motion to stay. Counsel for Intervenor-Plaintiff JANE
DOE'S MOTHER conferred with Counsel for JANE DOE'S FATHER, who do not agree to the
Court entering a stay in this action.
WHEREFORE, Intervenor-Plaintiff, JANE DOE'S MOTHER, moves the Court to stay
these proceedings pending JANE DOE NO. 1 reaching the age of majority at which time she can
decide whether, and how, to continue prosecution of this action.
these proceedings pending JANE DOE NO. 1 reaching the age of majority at which time she can
decide whether, and how, to continue prosecution of this action.
I HEREBY CERTIFY that a true and correct copy of the foregoing was filed electronically
on January 29th, 2008 with the Clerk of the Court through ECF, and that ECF will send an e-notice
of the electronic filing to the following: Jeffrey M. Herman, jherman@hermanlaw.com; Stuart S.
Mermelstein, smerme1stein@hermanlaw.com; Adam D. Horowitz,
ahorowitz@hennanlaw.com.
on January 29th, 2008 with the Clerk of the Court through ECF, and that ECF will send an e-notice
of the electronic filing to the following: Jeffrey M. Herman, jherman@hermanlaw.com; Stuart S.
Mermelstein, smerme1stein@hermanlaw.com; Adam D. Horowitz,
ahorowitz@hennanlaw.com.
Respectfully submitted,
/s/Theodore J. Leopold, Esq.
THEODORE J. LEOPOLD, ESQ.
Florida Bar No. 705608
RICCI~LEOPOLD, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens FL 33410
Phone: 561-684-6500;
Fax: 561-515-2610
Email: tleopold@riccilaw.com
THEODORE J. LEOPOLD, ESQ.
Florida Bar No. 705608
RICCI~LEOPOLD, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens FL 33410
Phone: 561-684-6500;
Fax: 561-515-2610
Email: tleopold@riccilaw.com
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