UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶
JANE DOE, by and through JANE CASE NO.: 08-80804-CIV-DOE'S MOTHER, as parent and natural MARRAZM guardian¶
Plaintiff,¶
vs.¶
JEFFREY EPSTEIN, and¶
Defendants.¶
NOTICE OF LACK OF COMPLIANCE WITH LOCAL RULE 7.1.8.3 AND NOTICE OF INCORRECT ASSERTION OF CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.8.3. INACCURATE CHARACTERIZATION OF PLAINTIFF'S MOTION FOR ENLARGEMENT OF TIME TO FILE CIVIL RICO CASE STATEMENT PURSUANT TO LOCAL RULE 12.1 AS UNOPPOSED. D IMPROPER SUBMISSION OF PROPOSED ORDER REGARDING PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT TO FILE CIVIL RICO CASE STATEMENT PURSUANT TO LOCAL RULE 12.1¶
COMES NOW, the Defendant, by and through her undersigned attorneys, and files this, her Notice of Lack of Compliance with Local Rule 7.1.8.3 and Notice of Incorrect Assertion of Certification of Compliance with Local Rule 7.1.8.3, Inaccurate Characterization of Plaintiff's Motion for Enlargement of Time to File Civil Rico Case Statement Pursuant to Local Rule 12.1 as Unopposed, and Improper Submission of Proposed Order Regarding Plaintiff's Unopposed Motion for Enlargement of Time to File Civil Rico Case Statement Pursuant to Local Rule 12.1, and sets forth as follows:¶
- I. On August 13, 2008, counsel for the Plaintiffs submitted to the Court an Unopposed Motion for Enlargement of Time to File Civil Rico Case Statement
CASE NO. 08-80804-CIV-MARRALMI.¶
Pursuant to Local Rule 12.1, as well as aproposed order on said motion. (True and correct copies of these documents are attached hereto as Exhibit A.) The Motion inaccurately certifies that opposing counsel conferred with counsel for the Defendants and that Defendants' counsel do not oppose the motion. Neither of the undersigned attorneys, whom are known to represent Defendant were consulted in any way regarding this Motion and most certainly did not communicate to opposing counsel regarding whether said Motion would be opposed or not. Therefore the certification is incorrect as was the presentation to the Court of the Motion and the proposed order as being unopposed.¶
CERTIFICATE OF SERVICE¶
WE HEREBY CERTIFY that on August 29, 2008, I electronically filed the foregoing document 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 attached Service List, either via U.S. Mail or 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 Notices of Electronic Filing.¶
McINTOSH, SAWRAN, PELTZ & CARTAYA, P.A. Centurion Tower 1601 Forum Place, Suite 1110 West Palm Beach, Florida 33401 Telephone: (561) 682-3202 Facsimil (561) 682-3206
¶
By:¶
DOUGLAS M. MCINTOSH Florida Bar No.: 325597 JASON A. Florida Bar o.: 734¶
CASE NO. 08-80804-CIV-MARRA/MMII¶
SERVICE LIST¶
THEODORE J. LEOPOLD, ESQUIRE SPENCER T. KUVIN, ESQUIRE (Attorneys for Plaintiff) Ricci -Leopold, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410¶
BRUCE E. REINHART, ESQUIRE (Attorneys for Defendant,1 Bruce E. Reinhart, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401¶
JACK A. GOLDBERGER, ESQ. (Attorneys for Defendant, Jeffrey Epstein) Atterbury, Goldberger & Weiss, P.A. 250 S. Australian Avenue, Suite 1400 West Palm Beach, FL 33401¶
ROBERT D. CRITTON, JR., ESQUIRE MICHAEL J. PIKE, ESQUIRE (Attorneys for Defendant, Jeffrey Epstein) Burman, Critton, Luther & Coleman, P.A. 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401¶
MICHAEL R. TEIN, ESQUIRE GUY ALAN MI ESQUIRE Attorneys for Defendant, Jeffrey Epstein) Tein, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, FL 33133¶