006.pdf
127 KB
Extraction Summary
7
People
3
Organizations
3
Locations
3
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal motion (civil court filing)
File Size:
127 KB
Summary
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.
People (7)
| Name | Role | Context |
|---|---|---|
| Jane Doe No. 8 | Plaintiff |
Plaintiff in Case No. 09-CV-80802-MARRA-JOHNSON
|
| Jeffrey Epstein | Defendant |
Defendant in the civil case, requesting extension of time
|
| Robert D. Critton, Jr. | Attorney |
Counsel for Defendant Jeffrey Epstein; signed the motion
|
| Michael J. Pike | Attorney |
Counsel for Defendant Jeffrey Epstein
|
| Stuart S. Mermelstein | Attorney |
Counsel for Plaintiff Jane Doe #8
|
| Adam D. Horowitz | Attorney |
Counsel for Plaintiff Jane Doe #8
|
| Jack Alan Goldberger | Attorney |
Counsel for Defendant Jeffrey Epstein
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of Florida |
Court where the case is filed
|
|
| Burman, Critton, Luttier & Coleman, LLP |
Law firm representing Jeffrey Epstein
|
|
| Atterbury Goldberger & Weiss, P.A. |
Law firm representing Jeffrey Epstein
|
Timeline (3 events)
2009-07-07
2009-07-07
Locations (3)
| Location | Context |
|---|---|
|
Address for Plaintiff's counsel (Mermelstein & Horowitz)
|
|
|
Address for Defendant's counsel (Goldberger)
|
|
|
Address for Defendant's counsel (Burman, Critton, Luttier & Coleman)
|
Relationships (3)
Defendant and Plaintiff in Case 09-CV-80802
Counsel for Defendant Jeffrey Epstein
Counsel for Plaintiff Jane Doe #8
Key Quotes (3)
"Defendant seeks an extension until July 14, 2009, to file his response."Source
006.pdf
Quote #1
"There are several other cases filed with this Court in which Jeffrey Epstein is named a Defendant."Source
006.pdf
Quote #2
"Plaintiff's counsel is in agreement with the requested extension."Source
006.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (3,186 characters)
Case 9:09-cv-80802-KAM Document 6 Entered on FLSD Docket 07/07/2009 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-CV-80802-MARRA-JOHNSON
JANE DOE NO. 8
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
________________________________/
________________________________/
DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION
OF TIME IN WHICH SERVE RESPONSIVE PLEADING TO COMPLAINT
OF TIME IN WHICH SERVE RESPONSIVE PLEADING TO COMPLAINT
Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys,
respectfully moves this Court for an extension of time in which to respond to Complaint dated
May 28, 2009 [DE 1]. Defendant seeks an extension until July 14, 2009, to file his response. As
good cause in support of granting the motion, Defendant states:
respectfully moves this Court for an extension of time in which to respond to Complaint dated
May 28, 2009 [DE 1]. Defendant seeks an extension until July 14, 2009, to file his response. As
good cause in support of granting the motion, Defendant states:
1. On May 28, 2009 Plaintiff filed a Complaint [DE 1]. Defendant's response would be due
on July 7, 2009.
on July 7, 2009.
2. There are several other cases filed with this Court in which Jeffrey Epstein is named a
Defendant. In those cases, the undersigned has been preparing responses to Motions for
Protective Order and handling other matters associated therewith.
Defendant. In those cases, the undersigned has been preparing responses to Motions for
Protective Order and handling other matters associated therewith.
3. The requested extension is fair and reasonable under the circumstances as it will provide
time to allow the Defendant, EPSTEIN to fully and adequately respond.
time to allow the Defendant, EPSTEIN to fully and adequately respond.
4. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and
Plaintiff's counsel is in agreement with the requested extension.
Plaintiff's counsel is in agreement with the requested extension.
Case 9:09-cv-80802-KAM Document 6 Entered on FLSD Docket 07/07/2009 Page 2 of 3
Jane Doe No. 8 v. Epstein
Page 2
Jane Doe No. 8 v. Epstein
Page 2
WHEREFORE Defendant respectfully requests that this Court enter an Order granting an
extension until July 14, 2009, to file a response to Plaintiff's Complaint.
extension until July 14, 2009, to file a response to Plaintiff's Complaint.
Local Rule 7.1 Statement
Counsel for the movant conferred by telephone and correspondence with counsel for the
Plaintiff and Counsel for Plaintiff is in agreement with the requested extension until July 14,
2009 for Defendant to respond to Plaintiff's Complaint.
Plaintiff and Counsel for Plaintiff is in agreement with the requested extension until July 14,
2009 for Defendant to respond to Plaintiff's Complaint.
Robert D. Critton, Esq.
Attorney for Defendant
Attorney for Defendant
Certificate of Service
I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
day on all counsel of record identified on the following Service List in the manner specified by
CM/ECF on this 7th day of July, 2009:
Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
day on all counsel of record identified on the following Service List in the manner specified by
CM/ECF on this 7th day of July, 2009:
Stuart S. Mermelstein, Esq.
Adam D. Horowitz, Esq.
18205 Biscayne Boulevard
Suite 2218
Miami, FL 33160
305-931-2200
Fax: 305-931-0877
ahorowitz@hermanlaw.com
lrivera@hermanlaw.com
Counsel for Plaintiff Jane Doe #8
Adam D. Horowitz, Esq.
18205 Biscayne Boulevard
Suite 2218
Miami, FL 33160
305-931-2200
Fax: 305-931-0877
ahorowitz@hermanlaw.com
lrivera@hermanlaw.com
Counsel for Plaintiff Jane Doe #8
Jack Alan Goldberger, Esq.
Atterbury Goldberger & Weiss, P.A.
250 Australian Avenue South
Suite 1400
West Palm Beach, FL 33401-5012
561-659-8300
Fax: 561-835-8691
jagesq@bellsouth.net
Counsel for Defendant Jeffrey Epstein
Atterbury Goldberger & Weiss, P.A.
250 Australian Avenue South
Suite 1400
West Palm Beach, FL 33401-5012
561-659-8300
Fax: 561-835-8691
jagesq@bellsouth.net
Counsel for Defendant Jeffrey Epstein
Case 9:09-cv-80802-KAM Document 6 Entered on FLSD Docket 07/07/2009 Page 3 of 3
Jane Doe No. 8 v. Epstein
Page 3
Jane Doe No. 8 v. Epstein
Page 3
Respectfully submitted,
BURMAN, CRITTON, LUTTIER
& COLEMAN, LLP
515 N. Flagler Drive, Suite 400
West Palm Beach, FL 33401
(561) 842-2820
& COLEMAN, LLP
515 N. Flagler Drive, Suite 400
West Palm Beach, FL 33401
(561) 842-2820
By:
Robert D. Critton, Jr.
Florida Bar #224162
Michael J. Pike
Florida Bar #617296
Counsel for Defendant Jeffrey Epstein
rcrit@bclclaw.com
mpike@bclclaw.com
Robert D. Critton, Jr.
Florida Bar #224162
Michael J. Pike
Florida Bar #617296
Counsel for Defendant Jeffrey Epstein
rcrit@bclclaw.com
mpike@bclclaw.com
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