Epstein Secrets

of 3 Rule 7 .1 Certification Defense counsel has spoken with Plaintiffs' counsel and he has no objections to the entry of the proposed order. By: Isl Michael J. Pike Robert D. Critton, Jr. Michael J. Pike Attorneys for Defendant Epstein Certificate of Service I HEREBY CERTIFY that the foregoing document is be

Pro Hae Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F isidrogarcia@b

ey Epstein, in an abundance of caution requests that the court enter the attached proposed Agreed Order which shall not preclude him from attending Jane Does' mediations or the trials of these cases. Case 9:08-cv-80119-KAM Document 542 Entered on FLSD Docket 05/11/2010 Page 2 of 3 Rule 7 .1 Certifi

he above interrogatories and requests; and C. proper. for such other and further relief as this Court deems just and Respectfully submitted, By: Isl Michael J. Pike MICHAEL J. PIKE, ESQ. Florida Bar #617296 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed wit

dment privilege must be sustained as it has correctly been applied relative to similar requests throughout this litigation. For example, Plaintiff (Jane Doe) also sought Request for Admissions dealing with Epstein's "financial history," "net worth," "fraudulent conveyances" and "real- estate ownership."

l for the movant conferred by e-mail with counsel for the Plaintiff and Counsel for Plaintiff is not in agreement with the requested extension. By: Isl Michael J. Pike \\ ~ ROBERT D. CRITTON, JR. ~ Florida Bar #224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 Case 9:08-cv-80119-KAM Document 491 Entered o

11, 08-80893, 09-80469, 09-80591,09-80656,09-80802,09-81092 --------------~/ DEFENDANT'S MOTION FOR EXTENSION OF TIME TO FILE REPLY TO PLAINTIFF, JANE DOE'S, RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL (485) Defendant, Jeffrey Epstein, (h

ing the Reply to exceed the maximum limit of IO pages. Case 9:08-cv-80119-KAM Document 501 Entered on FLSD Docket 03/26/2010 Page 2 of 4 By: Isl Michael J. Pike MICHAEL J. PIKE, ESQ. Florida Bar #617296 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed wit

nt's Reply in an organized and understandable manner, the IO page limitation is required to be exceeded. 2. The undersigned has contacted Plaintiff Jane Doe and there is no objection to the request to exceed the IO page limitation. WHEREFORE, Defendant respectfully requests that this Court grant Defenda

15) days from the date of the Court's order at the undersigned's office, and for such other and further relief as this court deems just and proper. Isl Michael J. Pike Robert D. Critton Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 Attorneys for Defendant Epstein Certificate of Service I HEREBY

because the company was administratively dissolved in September 2009 should fall on deaf ears. It is clear that Mr. Horowitz knew, two weeks before Jane Doe #3's !ME, that Epstein's office was located at 250 Australian A venue. 1 7. Just as the Florida Science Foundation is not listed on the building's d

el for the movant conferred via e-mail with counsel for the Plaintiff and counsel for the Plaintiff is in agreement with moving the above date. By: Isl Michael J. Pike MICHAEL J. PIKE, ESQ. Florida Bar #617296 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with

JOINT MOTION FOR AN EXTENSION OF TIME TO COMPLETE DISCOVERY Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, and Plaintiff, JANE DOE, by and through her undersigned attorneys respectfully moves this Court for an extension of time to complete discovery deadlines, and as good cause