This document is an 'Unopposed Motion for Extension of Time' filed by Jeffrey Epstein's legal team in the case of Jane Doe No. 102 v. Jeffrey Epstein on November 16, 2009. The motion requests an extension until November 27, 2009, for Epstein to respond to the complaint, citing that the parties are working together and are 'close to a resolution' of the case. The document includes a certificate of service listing the attorneys involved for both the plaintiff (Podhurst Orseck, P.A.) and the defendant (Atterbury Goldberger & Weiss, P.A. and Burman, Critton, Luttier & Coleman).
This is an unopposed motion filed on October 29, 2009, in the US District Court for the Southern District of Florida by Jeffrey Epstein's legal team. Epstein requests an extension until November 16, 2009, to respond to a complaint filed by 'Jane Doe No. 102' on May 1, 2009, citing that the parties are working together to potentially resolve the case. The document lists legal counsel for both sides, including Robert Critton and Jack Goldberger for Epstein, and Robert Josefsberg and Katherine Ezell for the plaintiff.
This document is an unopposed motion filed on October 15, 2009, by Jeffrey Epstein's legal team requesting an extension of time until October 30, 2009, to respond to a complaint filed by Jane Doe No. 102. The document indicates that the parties are working together to potentially resolve the case. It lists legal counsel for both the plaintiff (Podhurst Orseck, P.A.) and the defendant (Burman, Critton, Luttier & Coleman; Atterbury Goldberger & Weiss, P.A.).
This document is an unopposed motion filed on June 18, 2009, in the US District Court for the Southern District of Florida (Case No. 09-80656) by Jeffrey Epstein's legal team. Epstein requests an extension until July 5, 2009, to respond to a complaint filed by Jane Doe No. 102, citing the workload from multiple concurrent cases where he is a defendant. The document confirms that Plaintiff's counsel agreed to this extension and lists the legal representatives for both parties.
Legal document filed on May 11, 2009, in the US District Court for the Southern District of Florida (Case 09-80656). Attorneys Robert D. Critton, Jr. and Michael J. Pike of the firm Burman, Critton, Luttier & Coleman formally entered their appearance as counsel for the defendant, Jeffrey Epstein, in a civil suit brought by Jane Doe No. 102. The document includes a certificate of service listing other counsel involved, including Jack Alan Goldberger for the defense and attorneys from Podhurst Orseck, P.A. for the plaintiff.
This document is a Motion for Extension of Time filed on December 2, 2009, by Jeffrey Epstein's legal team in the case of Jane Doe No. 101 v. Jeffrey Epstein. The defense requested an extension until December 15, 2009, to file a reply, citing ongoing settlement negotiations and the need to investigate the implications of the 'Rothstein Rosenfeldt & Adler, PA' firm implosion on the Plaintiff's counsel. The document notes that Plaintiff's counsel opposed this extension request.
This document is a Reply filed by Jeffrey Epstein's legal team in November 2009 requesting a permanent order for the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), which was undergoing restructuring. The filing highlights that the Department of Justice had seized approximately 40 boxes of documents from RRA, including about 13 boxes related to Epstein cases, amidst concerns of 'serious ethical and potentially criminal issues' at the firm. The document also argues against delaying the deposition of RRA's Chief Restructuring Officer, Herbert Stettin, citing upcoming trial deadlines.
This document is an unopposed motion filed on October 29, 2009, by Jeffrey Epstein's legal team requesting an extension of time until November 16, 2009, to file a reply to Plaintiff Jane Doe 101's response to the motion to dismiss. The document indicates that the parties are working together to find a resolution to the case. The motion was filed in the U.S. District Court for the Southern District of Florida.
This document is an unopposed motion filed on October 15, 2009, by Jeffrey Epstein's legal team requesting an extension of time until October 30, 2009, to reply to Plaintiff Jane Doe 101's response to the motion to dismiss. The motion states that the parties are working together to find a resolution to the case and that the plaintiff's counsel agrees to the extension. The document includes a procedural history of filings and a service list of attorneys involved.
This document is an 'Unopposed Motion for Extension of Time' filed on August 7, 2009, in the case of Jane Doe No. 101 v. Jeffrey Epstein in the Southern District of Florida. Epstein's legal team requests an extension until October 15, 2009, to reply to the Plaintiff's response to the motion to dismiss, citing that the parties are working together to find a resolution. The motion lists legal counsel for both sides, including attorneys from Burman, Critton, Luttier & Coleman, Atterbury Goldberger & Weiss, and Podhurst Orseck.
This document is a 'Notice of Compliance' filed on July 28, 2009, by Jeffrey Epstein's legal team in the U.S. District Court for the Southern District of Florida. It pertains to multiple civil cases filed by 'Jane Doe' plaintiffs against Epstein. The filing states that while the court ordered the parties to agree on a preservation of evidence order, they were unable to reach a full agreement, leading Epstein to submit his own proposed order. The document includes a comprehensive service list detailing the attorneys representing the various plaintiffs and defendants, including Sarah Kellen.
This document is an unopposed motion filed on July 2, 2009, by Jeffrey Epstein's legal counsel in the US District Court for the Southern District of Florida (Case No. 09-80591). Epstein's attorneys request an extension until August 21, 2009, to reply to Plaintiff Jane Doe 101's response to a motion to dismiss, citing workload from other cases involving Epstein. The document confirms that Plaintiff's counsel agreed to this extension via telephone and correspondence.
Legal filing from June 12, 2009, in the case of Jane Doe No. 101 v. Jeffrey Epstein in the Southern District of Florida. Epstein's legal team withdraws seven specific arguments previously made in a Motion to Dismiss regarding the Plaintiff's First Amended Complaint, including arguments about the plaintiff's minority status and predicate offenses. The defense states it will now rely solely on arguments regarding count merger and subparagraph D.
This document is an unopposed motion filed on May 18, 2009, by Jeffrey Epstein's legal counsel in the case of Jane Doe No. 101 v. Jeffrey Epstein in the Southern District of Florida. Epstein's lawyers requested permission to exceed the standard 20-page limit for their upcoming motion to dismiss, citing complex legal issues regarding the interpretation of 18 U.S.C. §2255 and its applicability to the alleged conduct. Plaintiff's counsel agreed to this request via telephone.
This document is a legal response filed by Jeffrey Epstein's legal team on May 11, 2009, in the case of Jane Doe No. 101 v. Jeffrey Epstein. Epstein's attorneys oppose the plaintiff's motion to proceed anonymously, arguing that Epstein's due process rights to conduct discovery—specifically issuance of third-party subpoenas to medical providers and employers—require the use of the plaintiff's legal name. The filing asserts that the plaintiff's privacy interests do not outweigh the presumption of open judicial proceedings and Epstein's right to defend himself against allegations of sexual exploitation and coercion.
This document is a Notice of Appearance filed on May 7, 2009, in the United States District Court for the Southern District of Florida (Case No. 09-80591-MARRA/JOHNSON). Attorneys Robert D. Critton, Jr. and Michael J. Pike of the law firm Burman, Critton, Luttier & Coleman formally enter their appearance as counsel for the Defendant, Jeffrey Epstein. The document includes a Certificate of Service listing counsel for the Plaintiff (Jane Doe No. 101) and co-counsel for the Defendant.
Legal filing from May 4, 2009, in the case of Jane Doe No. 101 v. Jeffrey Epstein in the Southern District of Florida. Epstein's legal team accepts consolidation of multiple civil cases for depositions but opposes general consolidation for all discovery, arguing that individual cases have distinct facts and defenses that would be confused by a blanket consolidation. The document lists numerous related case numbers (e.g., 08-80119, 08-80381, 09-80469) and requests clarification on the court's previous orders regarding case management.
This document is an unopposed motion filed on May 4, 2009, by Jeffrey Epstein's attorneys in the case of Jane Doe No. 101 v. Jeffrey Epstein (Case No. 09-80591) in the Southern District of Florida. Epstein's counsel requests an extension until May 26, 2009, to respond to the complaint filed on April 17, 2009. The reasons cited include the burden of other cases naming Epstein as a defendant and a conflicting state court trial scheduled for mid-May involving the defense counsel.
This document is a 'Stipulation of Dismissal with Prejudice' filed in the US District Court for the Southern District of Florida on June 24, 2010. It formally ends the lawsuit between Plaintiff 'C.L.' and Defendant Jeffrey Epstein following a settlement agreement. The document is signed by attorneys Robert D. Critton, Jr. (representing Epstein) and Spencer T. Kuvin (representing C.L.).
This document is an Emergency Motion filed on June 14, 2010, by Jeffrey Epstein's legal team to quash a subpoena and prevent the deposition of Maritza Milagros Vasquez, scheduled for the following day. Epstein's lawyers argue that the subpoena issued by C.L.'s counsel (Spencer Kuvin) is premature under Rule 26(d) and that the cross-notice by Jane Doe's counsel (Brad Edwards) is invalid because discovery in the Jane Doe case had already concluded on May 31, 2010. The document includes the motion, a subpoena exhibit, and a cross-notice exhibit.
This document is a legal response filed by Plaintiff C.L. opposing Jeffrey Epstein's motion to dismiss Count III of her complaint. The core legal argument concerns whether the Adam Walsh Act (2006) can be applied retroactively to Epstein's conduct; the Plaintiff argues it provides a civil, non-punitive remedy and thus does not violate the Ex Post Facto clause. The document also graphically describes Epstein's 'systematic' child exploitation enterprise, involving at least three assistants who recruited, groomed, and paid minor girls, which Epstein sought to strike from the record.
This document is a partial transcript from a court proceeding on September 17, 2009, detailing the cancellation of a deposition involving Jeffrey Epstein. The deposition was called off because Jeffrey Epstein made face-to-face contact with the plaintiff, Jane Doe 4, which her counsel, Adam Horowitz, stated intimidated her and violated a prior stipulation that Epstein would not be present. Defense counsel, Robert Critton, argued that Epstein was instructed to leave the building and planned to appear via Skype, and that the encounter would not have happened if the plaintiff and her counsel had arrived on time.
This document is a legal letter dated August 27, 2009, from Robert D. Critton, Jr. of Burman, Critton, Luttier & Coleman, LLP to Stuart S. Mermelstein, Esq. of Herman & Mermelstein, P.A. It concerns the case Jane Doe No. 4 v. Epstein, informing Mermelstein that Mr. Epstein intends to be present at his client's deposition as a party-defendant, but will not engage in conversation with Mermelstein's client.
This document is a service list for the 2008 court case No. 50 2008 CA 006596 XXXX MB AB. It provides the names, law firms, and contact information for the attorneys representing various parties in the case. Key parties and their counsel include the State of Florida (represented by Lanna Belohlavek), Jeffrey Epstein (represented by Jack A. Goldberger and Robert Critton), Sarah Kellen (represented by Bruce E. Reinhart), and Haley Robson (represented by Douglas M. McIntosh and Jason A. McGrath).
This document is a condensed transcript (Pages 1-4) of a videotaped deposition of Bradley J. Edwards, taken on March 23, 2010, in West Palm Beach, Florida. The case involves Jeffrey Epstein as the plaintiff against Scott Rothstein, Bradley J. Edwards, and L.M. Notable attendees included Jeffrey Epstein himself and his legal team, including Alan Dershowitz.
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