Michael J. Pike
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Jeffrey Epstein
|
Client |
10
Very Strong
|
10 | |
|
person
Robert D. Critton Jr.
|
Business associate |
1
|
1 | |
|
person
Jeffrey Epstein
|
Legal representative |
1
|
1 | |
|
person
Robert D. Critton Jr.
|
Correspondents involved in same case |
1
|
1 | |
|
person
Adam Horowitz
|
Correspondents involved in same case |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| 2010-04-12 | N/A | Date of signature/service of the document. | West Palm Beach, FL | View |
| 2010-03-23 | N/A | Service of Motion for Extension of Time via CM/ECF | Electronic Filing | View |
| 2009-07-28 | N/A | Defendant Jeffrey Epstein filed a Notice of Compliance regarding the Court's Order DE #192. | United States District Cour... | View |
| 2009-07-28 | N/A | Filing of Defendant Jeffrey Epstein's Notice of Compliance with Court Order (DE #192) | United States District Cour... | View |
| 2009-06-11 | N/A | Certificate of Service mailed to opposing counsel. | West Palm Beach, FL | View |
| 2009-06-05 | N/A | Filing of Notice of Appearance by Burman, Critton, Luttier & Coleman, LLP for Jeffrey Epstein | US District Court, Southern... | View |
| 2009-05-11 | N/A | Notice of Appearance filed by attorneys Robert D. Critton, Jr. and Michael J. Pike on behalf of J... | US District Court Southern ... | View |
027.pdf
This document is a Motion for Leave to File Under Seal submitted on May 29, 2009, by attorneys for Plaintiffs Jane Doe No. 101 and 102 in the Southern District of Florida. The plaintiffs request permission to file their response to Epstein's Motion to Stay under seal, or alternatively, request the court to unseal the Non-Prosecution Agreement (NPA) so they can adequately respond. The document includes a comprehensive service list detailing attorneys representing Epstein, co-defendant Sarah Kellen (represented by Bruce Reinhart), and various other Jane Doe plaintiffs.
025.pdf
This document is a legal reply filed on May 29, 2009, by Plaintiffs Jane Doe No. 101 and 102 in the Southern District of Florida, arguing for the right to proceed anonymously in their lawsuit against Jeffrey Epstein. The plaintiffs contend that Epstein aims to reveal their identities to harass and intimidate them, and they cite various legal precedents and the Non-Prosecution Agreement (NPA) to support their request for privacy due to the sexual nature of the crimes committed against them as minors. The document also includes a service list detailing the attorneys representing various parties in related cases against Epstein.
015-01.pdf
This document is a Motion to Stay proceedings filed by Jeffrey Epstein's legal team in a civil case brought by a plaintiff identified as C.M.A. Epstein argues that the civil case should be paused until late 2010, when his Non-Prosecution Agreement (NPA) with federal prosecutors expires, to avoid forcing him to waive his 5th Amendment rights against self-incrimination while facing potential ongoing criminal liability. The filing includes an affidavit from his criminal defense attorney, Jack Goldberger, and an Indictment from 2006 for Felony Solicitation of Prostitution.
013.pdf
This document is a Motion to Dismiss filed by Jeffrey Epstein's defense team in the U.S. District Court for the Southern District of Florida on May 6, 2009, against Plaintiff Jane Doe II. The defense argues that the federal case should be dismissed because a nearly identical state case was filed 10 months prior, and because the plaintiff is improperly applying a 2006 amendment to 18 U.S.C. §2255 retroactively to conduct alleged to have occurred between 2003 and 2005, thereby violating the Ex Post Facto clause. Additionally, the motion argues that the statute does not allow for multiplying damages per incident and that the plaintiff failed to allege the necessary interstate commerce elements required for federal jurisdiction.
009.pdf
This document is a legal response filed by Jeffrey Epstein's attorneys on May 4, 2009, in the Southern District of Florida. Epstein opposes the court's potential order to consolidate multiple civil lawsuits (filed by various 'Jane Doe' plaintiffs) for all discovery purposes, arguing that while consolidating depositions is acceptable, full consolidation would confuse distinct facts and defenses unique to each case. The filing lists numerous related case numbers and requests clarification on how consolidation would operate regarding motion practice.
007.pdf
This document is an unopposed motion filed on May 1, 2009, in the Southern District of Florida (Case 09-CIV-80469) by Jeffrey Epstein's attorneys requesting a five-day extension to file a response to Jane Doe II's complaint. The extension (until May 6, 2009) was requested because Epstein's counsel, Robert D. Critton, Jr., was preparing for an unrelated state court trial. The document confirms that Plaintiff's counsel, Isidro M. Garcia, agreed to this extension.
021.pdf
This document is an 'Opposition to Remand Motion' filed by defendants Jeffrey Epstein and Sarah Kellen in September 2008 in the Southern District of Florida. The defendants argue that the case should remain in federal court because the plaintiff fraudulently joined co-defendant Haley Robson (a Florida resident) solely to destroy diversity jurisdiction. The filing contends that the plaintiff has no valid cause of action against Robson for civil conspiracy, intentional infliction of emotional distress (IIED), or civil RICO under Florida law, arguing that Robson's alleged actions do not meet the legal standards for these torts.
019.pdf
Defendant Jeffrey Epstein moves to dismiss Counts I (sexual assault), II (civil conspiracy), and IV (civil RICO) of Jane Doe's amended complaint. The motion argues that the sexual assault claim improperly relies on a criminal statute with no private right of action, the conspiracy claim lacks an actionable underlying tort, and the RICO claim fails to allege a direct injury resulting from a predicate act. The document outlines relevant Florida case law and statutes to support the dismissal of these claims.
017.pdf
This document is a Motion to File Under Seal submitted by defendants Jeffrey Epstein and Sarah Kellen on July 25, 2008, in the case of Jane Doe v. Epstein et al. The defendants request to seal their 'motion for stay' to protect a confidential agreement between Epstein and the U.S. Attorney's Office for the Southern District of Florida. The document includes certificates of compliance and service, noting that the plaintiff opposes the motion, and lists the legal counsel representing all parties involved.
014.pdf
This document is a legal response filed on August 22, 2008, by Jeffrey Epstein's legal team in the case of Jane Doe vs. Jeffrey Epstein, Haley Robson, and Sarah Kellen. Epstein's lawyers state they have no opposition to the plaintiff's Motion to Preserve Evidence (DE 12). However, they dispute the plaintiff's certification of compliance, arguing that plaintiff's counsel filed the motion prematurely without properly conferring with the defense or waiting for a return call regarding Epstein's position.
008.pdf
This document is a motion filed by Jeffrey Epstein's legal team on August 8, 2008, requesting an extension to file a response to the complaint in the case of Jane Doe #1. Epstein's lawyers argue that the deadline should be aligned with parallel cases (Jane Doe Nos. 2-5) to September 4, 2008, to promote judicial economy. The document notes that co-defendants Haley Robson and Sarah Kellen had not yet been served at the time of filing.
003.pdf
This document is a Motion for Enlargement of Time filed on July 25, 2008, in the Southern District of Florida civil case Jane Doe v. Jeffrey Epstein, et al. Defendants Epstein and Sarah Kellen request an extension to answer the complaint until 10 days after a decision is made on their contemporaneous motion to stay the case, citing 18 U.S.C. § 3509 regarding civil stays during parallel criminal proceedings involving child victims. The document includes a service list detailing legal representation for all parties, including Bruce Reinhart as counsel for Sarah Kellen.
002.pdf
Defendants Jeffrey Epstein and Sarah Kellen filed a request for oral argument on July 25, 2008, in the Southern District of Florida regarding a motion to stay civil proceedings pending the resolution of a criminal action. The document lists legal representation for all parties, including Jane Doe (Plaintiff) and Haley Robson (Co-Defendant). Attorneys Michael R. Tein and Guy A. Lewis are the primary signatories for Epstein.
030.pdf
This document is a Notice of Withdrawing Subpoena filed on June 14, 2010, in the United States District Court for the Southern District of Florida. Plaintiff C.L., represented by attorney Spencer T. Kuvin, withdrew a subpoena and cancelled the deposition of Maritza Milagros Vasquez, which had been scheduled for June 15, 2010. The document includes a certificate of service listing legal counsel for various parties involved in the primary case (Jane Doe No. 2 v. Jeffrey Epstein) and related cases.
017.pdf
Legal filing from November 2009 in the case of Jane Doe No. 2 v. Jeffrey Epstein. Epstein's attorneys reply to a response regarding the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), which was undergoing restructuring. The document notes that the Department of Justice had seized approximately 40 boxes of documents from RRA, including 13 boxes related to the Epstein case, and alludes to serious ethical and criminal issues involving the RRA firm that could impact the validity of the cases against Epstein.
015.pdf
This document is a Reply Memorandum filed by Jeffrey Epstein's legal team on August 20, 2009, in the case of Jane Doe No. 8 v. Jeffrey Epstein. The defense argues that the plaintiff's claims of 'Sexual Assault and Battery' (Count I) and 'Coercion and Enticement' (Count III) should be dismissed because they are barred by the statute of limitations. Epstein's lawyers contend that because the plaintiff was aware of the injury at the time of the alleged incident in 2001 (when she was 16) and turned 18 in 2003, the time limits for filing suit (4 years and 6 years respectively) had expired by the time the complaint was filed in 2009.
008.pdf
This document is a Motion to Dismiss filed by Jeffrey Epstein's defense team on July 14, 2009, in the case of Jane Doe No. 8 v. Jeffrey Epstein. The defense argues that the plaintiff's claims of Sexual Assault and Battery (Count I) and Coercion (Count III) are barred by the applicable 4-year (state) and 6-year (federal) statutes of limitations, as the alleged incident occurred in 2001 when the plaintiff was 16. Footnotes in the document provide graphic details of the allegations, describing how Jane Doe was recruited by another girl, brought to Epstein's Palm Beach mansion, and sexually assaulted during a massage.
006.pdf
This document is an unopposed motion filed on July 7, 2009, in the US District Court for the Southern District of Florida by Jeffrey Epstein's legal team. Epstein's attorneys requested a one-week extension (until July 14, 2009) to respond to a complaint filed by 'Jane Doe No. 8' on May 28, 2009, citing workload from other cases involving Epstein. The motion notes that opposing counsel agreed to this extension.
004.pdf
Legal document filed on June 5, 2009, in the Southern District of Florida court case 'Jane Doe No. 8 v. Jeffrey Epstein'. The document is a Notice of Appearance indicating that attorneys Robert D. Critton, Jr. and Michael J. Pike of the law firm Burman, Critton, Luttier & Coleman, LLP are entering the case to represent the defendant, Jeffrey Epstein. The service list includes contact information for other attorneys involved, including Jack Alan Goldberger (also for Epstein) and Adam D. Horowitz (for the Plaintiff).
020.pdf
This document is an agreed motion filed on May 13, 2010, in the Southern District of Florida by Plaintiff Jane Doe No. 103 against Defendant Jeffrey Epstein. The plaintiff requests a one-week extension to file a response to Epstein's motion to dismiss because the parties are in the process of resolving the matter via settlement, which would render the motion moot. The document includes a comprehensive service list detailing legal counsel for Epstein, Co-Defendant Sarah Kellen (represented by Bruce Reinhart), and plaintiffs in several related cases.
016.pdf
This document is an agreed motion for an extension of time filed on April 22, 2010, in the case of Jane Doe No. 103 vs. Jeffrey Epstein (Case No. 10-80309-WJZ). Plaintiff's counsel, Katherine W. Ezell, requests an extension until May 13, 2010, to file a response to Epstein's motion to dismiss because she is leaving for a vacation in Italy the following day. The motion notes that Epstein's counsel, Robert Critton, agrees to the extension, and the document includes a service list of attorneys involved in this and related cases.
015.pdf
This document is a motion filed on April 12, 2010, by Jeffrey Epstein's legal counsel in the case 'Jane Doe No. 103 vs. Jeffery Epstein'. The defense seeks to amend their previous Motion to Dismiss to clarify an argument regarding retroactivity, specifically stating that the criminal statute (18 U.S.C. § 2252A(g)) relied upon by the plaintiff did not exist during the time of the alleged abuse (Jan 2004 - May 2005). The plaintiff's counsel reportedly did not oppose this amendment.
012.pdf
This document is a Motion to Transfer filed on April 1, 2010, by Plaintiff Jane Doe No. 103 in the US District Court, Southern District of Florida. The plaintiff seeks to transfer her case against Jeffrey Epstein to Judge Marra's division to consolidate it with other similar pending cases, specifically 'Jane Doe No. 2 vs. Jeffrey Epstein'. The document includes a service list detailing legal counsel for Epstein, co-defendant Sarah Kellen (represented by Bruce Reinhart), and plaintiffs in several related cases.
006.pdf
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.
062.pdf
This document is a motion filed by Jeffrey Epstein's attorneys requesting an extension until December 15, 2009, to respond to a complaint filed by Jane Doe No. 102. The reasons cited for the extension include ongoing resolution negotiations and questions arising from the 'implosion' of the Rothstein Rosenfeldt & Adler, PA firm.
Jane Does v. Epstein
Requesting Dr. Kliman's questionnaires used with clients, based on transcript review.
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