048.pdf
202 KB
Extraction Summary
9
People
5
Organizations
5
Locations
4
Events
4
Relationships
2
Quotes
Document Information
Type:
Legal motion
File Size:
202 KB
Summary
This document is a legal motion filed on June 9, 2009, by Plaintiff Jane Doe No. 101 requesting an extension of time and page limits to respond to Jeffrey Epstein's Motion to Dismiss. The request is based on an upcoming court hearing scheduled for June 12, 2009, in a related case (Jane Doe No. 2 vs. Jeffrey Epstein) which addresses potential breaches of Epstein's Non-Prosecution Agreement. The document includes certificates of conference and service, listing legal counsel for both parties, including Bruce Reinhart as counsel for a co-defendant named Sarah.
People (9)
| Name | Role | Context |
|---|---|---|
| Jane Doe No. 101 | Plaintiff |
Party filing the motion for enlargement of time
|
| Jeffrey Epstein | Defendant |
Defendant in the civil action
|
| Jane Doe No. 2 | Plaintiff (Related Case) |
Plaintiff in related case No. 09-CV-80119-MARRA/JOHNSON
|
| Robert C. Josefsberg | Attorney |
Counsel for Plaintiff Jane Doe No. 101
|
| Katherine W. Ezell | Attorney |
Counsel for Plaintiff Jane Doe No. 101
|
| Robert Critton | Attorney |
Counsel for Defendant Jeffrey Epstein
|
| Jack Goldberger | Attorney |
Attorney listed on service list
|
| Bruce E. Reinhart | Attorney |
Attorney listed on service list, Counsel for Co-Defendant Sarah
|
| Sarah | Co-Defendant |
Mentioned as 'Co-Defendant, Sarah' in service list (likely Sarah Kellen)
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| United States District Court for the Southern District of Florida |
Court where the case is filed
|
|
| Podhurst Orseck, P.A. |
Law firm representing the Plaintiff
|
|
| Burman, Critton, Luttier & Coleman LLP |
Law firm representing the Defendant
|
|
| Atterbury, Goldberger & Weiss, P.A. |
Law firm listed on service list
|
|
| Bruce E. Reinhart, P.A. |
Law firm listed on service list
|
Timeline (4 events)
2009-05-01
2009-05-26
Defendant filed Motion to Dismiss First Amended Complaint
Southern District of Florida
2009-06-09
2009-06-12
Scheduled hearing for all cases consolidated for discovery under Jane Doe No. 2 vs. Jeffrey Epstein
Southern District of Florida
Locations (5)
| Location | Context |
|---|---|
|
Location of Podhurst Orseck, P.A.
|
|
|
Location of defense attorneys' offices
|
|
|
Address for Podhurst Orseck, P.A.
|
|
|
Address for Burman, Critton, Luttier & Coleman LLP
|
|
|
Address for Atterbury, Goldberger & Weiss, P.A. and Bruce E. Reinhart, P.A.
|
Relationships (4)
Listed as Attorney for Plaintiff
Listed as Attorney for Plaintiff
Listed as Counsel for Defendant
Listed as Counsel for Co-Defendant, Sarah
Key Quotes (2)
"Defendant's seeking to stay/continue all civil cases pending against him and the Court's own inquiry as to whether the Defendant is in breach of the Non-Prosecution Agreement between the Defendant and the United States."Source
048.pdf
Quote #1
"It would be a waste of the time of the undersigned attorneys to prepare a response to the Motion to Dismiss... when the response may be made obsolete, irrelevant or incomplete on the very day it is due as the result of matters to be discussed at the hearing on June 12th."Source
048.pdf
Quote #2
Full Extracted Text
Complete text extracted from the document (5,968 characters)
Case 9:09-cv-80591-KAM Document 48 Entered on FLSD Docket 06/09/2009 Page 1 of 5
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
FOR THE SOUTHERN DISTRICT OF FLORIDA
JANE DOE No. 101,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
____________ /
____________ /
Civil Action No. 09-80591-CIV-Marra/Johnson
PLAINTIFF JANE DOE NO.101 'S MOTION FOR ENLARGEMENT OF TIME
AND PAGE LIMITS FOR RESPONSE TO DEFENDANT'S MOTION TO DISMISS
THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE,
FOR A MORE DEFINITE STATEMENT
AND PAGE LIMITS FOR RESPONSE TO DEFENDANT'S MOTION TO DISMISS
THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE,
FOR A MORE DEFINITE STATEMENT
Plaintiff, Jane Doe No. 101 ("Plaintiff'), moves this Court for an order enlarging the time
and page limits in which she must reply to Defendant's Motion to Dismiss the First Amended
Complaint or, in the Alternative, for a More Definite Statement. The grounds for this motion are as
follows:
and page limits in which she must reply to Defendant's Motion to Dismiss the First Amended
Complaint or, in the Alternative, for a More Definite Statement. The grounds for this motion are as
follows:
1. Plaintiff's First Amended Complaint [DE 9] was filed on May 1, 2009.
2. Pursuant to an unopposed motion for enlargement, Defendant filed his Motion to
Dismiss Plaintiff's First Amended Complaint or, in the Alternative, for a More Definite Statement
( "Motion to Dismiss") on May 26, 2009. [DE 29] The Motion is 36 pages.
Dismiss Plaintiff's First Amended Complaint or, in the Alternative, for a More Definite Statement
( "Motion to Dismiss") on May 26, 2009. [DE 29] The Motion is 36 pages.
3. Ordinarily, a response to the Motion to Dismiss would be due on June 12, 2009. As
it happens, however, the Court has set a hearing on that very day for all cases consolidated for
discovery and procedural issues under the case known as Jane Doe No. 2 vs. Jeffrey Epstein, Case
No.09-CV-80119-MARRA/JOHNSON. Apparently the Court set the hearing as the result of
it happens, however, the Court has set a hearing on that very day for all cases consolidated for
discovery and procedural issues under the case known as Jane Doe No. 2 vs. Jeffrey Epstein, Case
No.09-CV-80119-MARRA/JOHNSON. Apparently the Court set the hearing as the result of
Case 9:09-cv-80591-KAM Document 48 Entered on FLSD Docket 06/09/2009 Page 2 of 5
Defendant's seeking to stay/continue all civil cases pending against him and the Court's own inquiry
as to whether the Defendant is in breach of the Non-Prosecution Agreement between the Defendant
and the United States.
as to whether the Defendant is in breach of the Non-Prosecution Agreement between the Defendant
and the United States.
4. Under any circumstances, responding to Defendant's Motion would take more
than the usual time allotted under the Local Rules for the Southern District of Florida, because of
its length, comprehensiveness and complexity. In this instance, however, the fact and importance
of the hearing set for June 12th is a further complication which will likely affect the substance of
Plaintiff's response, as well as its timing. Furthermore, Defendant's motion combines two motions
in one 36 page document. Plaintiff seeks leave to file an equal number of pages in response.
than the usual time allotted under the Local Rules for the Southern District of Florida, because of
its length, comprehensiveness and complexity. In this instance, however, the fact and importance
of the hearing set for June 12th is a further complication which will likely affect the substance of
Plaintiff's response, as well as its timing. Furthermore, Defendant's motion combines two motions
in one 36 page document. Plaintiff seeks leave to file an equal number of pages in response.
5. The issues raised by Defendant's Motion to Stay/Continue the Civil Cases Pending
Against Him and the Court's inquiry are intertwined with many of those issues that will necessarily
be involved in Plaintiff's response to Defendant's Motion to Dismiss. It would be a waste of the
time of the undersigned attorneys to prepare a response to the Motion to Dismiss and of the judicial
labor involved in reviewing it, when the response may be made obsolete, irrelevant or incomplete
on the very day it is due as the result of matters to be discussed at the hearing on June 12th.
Against Him and the Court's inquiry are intertwined with many of those issues that will necessarily
be involved in Plaintiff's response to Defendant's Motion to Dismiss. It would be a waste of the
time of the undersigned attorneys to prepare a response to the Motion to Dismiss and of the judicial
labor involved in reviewing it, when the response may be made obsolete, irrelevant or incomplete
on the very day it is due as the result of matters to be discussed at the hearing on June 12th.
6. This motion is not made for the purpose of delay and should be granted in the interest
of equity and fairness.
of equity and fairness.
WHEREFORE, Plaintiff, Jane Doe No. 101, requests an enlargement of time of up to 14
days and page limits of up to 36 pages in which she must reply to Defendant's Motion to Dismiss
the First Amended Complaint or, in the Alternative, for a More Definite Statement, so as to make
her reply due five (5) days after the Court issues its ruling resulting from the hearing set for June 12,
2009, or on June 26, 2009, whichever is later.
days and page limits of up to 36 pages in which she must reply to Defendant's Motion to Dismiss
the First Amended Complaint or, in the Alternative, for a More Definite Statement, so as to make
her reply due five (5) days after the Court issues its ruling resulting from the hearing set for June 12,
2009, or on June 26, 2009, whichever is later.
2
Case 9:09-cv-80591-KAM Document 48 Entered on FLSD Docket 06/09/2009 Page 3 of 5
CERTIFICATE OF HAVING CONFERRED WITH OPPOSING
COUNSEL PURSUANT TO S.D.L.R. 7.1.A.3
COUNSEL PURSUANT TO S.D.L.R. 7.1.A.3
Katherine W. Ezell, one of the undersigned counsel for the Plaintiff hereby certifies that she
has conferred with one of the attorneys for the Defendant, Robert Critton, Esq. about the matters
raised in this Motion. Mr. Critton advised that the Defendant does not oppose the Motion or the
relief sought herein.
has conferred with one of the attorneys for the Defendant, Robert Critton, Esq. about the matters
raised in this Motion. Mr. Critton advised that the Defendant does not oppose the Motion or the
relief sought herein.
DATED this 9th day of June, 2009.
Respectfully submitted,
By: Robert C. Josefsberg
Robert C. Josefsberg,
Bar No. 040856
Katherine W. Ezell, Bar No. 114771
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800
Miami, Florida 33130
(305) 358-2800
(305) 358-2382 (fax)
rjosefsberg@podhurst.com
kezell@podhurst.com
Attorneys for Plaintiff
3
Robert C. Josefsberg,
Bar No. 040856
Katherine W. Ezell, Bar No. 114771
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800
Miami, Florida 33130
(305) 358-2800
(305) 358-2382 (fax)
rjosefsberg@podhurst.com
kezell@podhurst.com
Attorneys for Plaintiff
3
Case 9:09-cv-80591-KAM Document 48 Entered on FLSD Docket 06/09/2009 Page 4 of 5
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on this 9th day of June, 2009, we electronically filed the
foregoing document with the Clerk of the Court using CM/ECF. We also certify that the foregoing
document is being served this day on all counsel of record identified on the attached Service List
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 electronically
Notices of Electronic Filing.
foregoing document with the Clerk of the Court using CM/ECF. We also certify that the foregoing
document is being served this day on all counsel of record identified on the attached Service List
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 electronically
Notices of Electronic Filing.
Respectfully submitted,
PODHURST ORSECK, P.A.
Attorneys for Plaintiff
Attorneys for Plaintiff
By: s/Robert C. Josefsberg
Robert C. Josefsberg
Fla. Br No. 040856
rjosefsberg@podhurst.com
Katherine W. Ezell
Fla. Bar No. 114771
kezell@podhurst.com
City National Bank Building
25 W. Flagler Street, Suite 800
Miami, FL 33130
Telephone: (305) 358-2800
Facsimile: (305) 358-2382
4
Robert C. Josefsberg
Fla. Br No. 040856
rjosefsberg@podhurst.com
Katherine W. Ezell
Fla. Bar No. 114771
kezell@podhurst.com
City National Bank Building
25 W. Flagler Street, Suite 800
Miami, FL 33130
Telephone: (305) 358-2800
Facsimile: (305) 358-2382
4
Case 9:09-cv-80591-KAM Document 48 Entered on FLSD Docket 06/09/2009 Page 5 of 5
SERVICE LIST
JANE DOE NO. 101 v. JEFFREY EPSTEIN
Case No. 08-CV-80591-MARRA/JOHNSON
United States District Court, Southern District of Florida
Case No. 08-CV-80591-MARRA/JOHNSON
United States District Court, Southern District of Florida
Robert Critton Esq.
Burman, Critton, Luttier & Coleman LLP
515 North Flagler Drive, Suite 400
West Palm Beach, FL 33401
rcrit@bclclaw.com
Burman, Critton, Luttier & Coleman LLP
515 North Flagler Drive, Suite 400
West Palm Beach, FL 33401
rcrit@bclclaw.com
Jack Goldberger, Esq.
Atterbury, Goldberger & Weiss, P.A.
250 Australian Avenue South, Suite 1400
West Palm Beach, FL 33401
jagesq@bellsouth.net
Atterbury, Goldberger & Weiss, P.A.
250 Australian Avenue South, Suite 1400
West Palm Beach, FL 33401
jagesq@bellsouth.net
Bruce E. Reinhart, Esq.
Bruce E. Reinhart, P.A.
250 South Australian Avenue, Suite 1400
West Palm Beach, FL 33401
Phone: (561) 202-6360
Fax: (561) 828-0983
ecf@brucereinhartlaw.com
Counsel for Co-Defendant, Sarah
5
Bruce E. Reinhart, P.A.
250 South Australian Avenue, Suite 1400
West Palm Beach, FL 33401
Phone: (561) 202-6360
Fax: (561) 828-0983
ecf@brucereinhartlaw.com
Counsel for Co-Defendant, Sarah
5
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