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Case 9:08-cv-80069-KAMCase 9:08-cv-80069-KAM
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efta-efta00234042DOJ Data Set 9Other

Case 9:08-cv-80069-KAM

Date
Unknown
Source
DOJ Data Set 9
Reference
EFTA 00234042
Pages
3
Persons
4
Integrity
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Summary

Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80069 CIV-MARRA/JOHNSON JANE DOE NO.1, by and through JANE DOE's FATHER as parent and natural guardian, and JANE DOE's FATHER, and JANE DOE's STEPMOTHER, individually, Plaintiffs, vs. JEFFREY EPSTEIN, Defendant. MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW Applicant, JANE DOE'S MOTHER, individually and as parent and natural guardian of JANE DOE NO. 1, by and through the undersigned counsel, moves this Court, pursuant to Federal Rule of Civil Procedure 24(b), for leave to intervene as a plaintiff in this action in order to assert the claims against Defendant JEFFREY EPSTEIN set forth in Applicant's proposed complaint (attached hereto as EXHIBIT "A'). In support of this motion, Applicant states that: I. Applicant has claims that share common questions of law or fact with the main action. 2. Applicant's motio

Persons Referenced (4)

United StatesTheodore J. Leopold

“...Dated: January 29th, 2008 Respectfully submitted, RICCI—LEOPOLD, PA. By: /s/Theodore J. Leopold, Esq. THEODORE J. LEOPOLD I HEREBY CERTIFY that a true and correct copy of th...”

Jeffrey M. Herman

“... and that ECF will send an c-notice of the electronic filing to the following: Jeffrey M. Herman, Mermelstein, Stuart S. Adam I). Ilorowitz, /s/Theodore J. Leopold, Esq. THEODORE J. LEOPOLD, E...”

Jeffrey Epstein

“...JANE DOE's FATHER, and JANE DOE's STEPMOTHER, individually, Plaintiffs, vs. JEFFREY EPSTEIN, Defendant. MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW Applicant, JANE DOE'S MOTHER, indivi...”

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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80069 CIV-MARRA/JOHNSON JANE DOE NO.1, by and through JANE DOE's FATHER as parent and natural guardian, and JANE DOE's FATHER, and JANE DOE's STEPMOTHER, individually, Plaintiffs, vs. JEFFREY EPSTEIN, Defendant. MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW Applicant, JANE DOE'S MOTHER, individually and as parent and natural guardian of JANE DOE NO. 1, by and through the undersigned counsel, moves this Court, pursuant to Federal Rule of Civil Procedure 24(b), for leave to intervene as a plaintiff in this action in order to assert the claims against Defendant JEFFREY EPSTEIN set forth in Applicant's proposed complaint (attached hereto as EXHIBIT "A'). In support of this motion, Applicant states that: I. Applicant has claims that share common questions of law or fact with the main action. 2. Applicant's motion to intervene is timely. 3. The original parties to this action will not be prejudiced by the intervention of Applicant. 4. Pursuant to Local Rule 7.1.A.3, counsel for Applicant, in a good faith attempt to resolve this dispute, made a reasonable effort to confer with all parties who may be affected by EFTA00234042 Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 2 of 3 her intervention in this action. Counsel for Applicant conferred with Counsel for JANE DOE'S FATHER, who do not agree to her intervention in this action. MEMORANDUM OF LAW Under Federal Rule of Civil Procedure 24(b)(l)(B), "[o]n timely motion, the court may permit anyone to intervene who . . . has a claim or defense that shares with the main action a common question of law or fact." "Rule 24(b) should be liberally construed. `Basically, anyone may be permitted to intervene if his claim and the main action have a common question of law or fact,' unless the court in its `sound discretion (determines that) the intervention will unduly delay or prejudice the adjudication of the rights of the original parties.'" Moore v. Tangipahoa Parish School Bd., 298 F. Supp. 288, 292-93 (D.C. La. 1969) (quoting Allen v. County School Board of Prince Edward County, 28 F.R.D. 358, 363 (E.D. Va. 1961)) (citation and footnote omitted). Applicant, JANE DOE'S MOTHER, is the parent and natural guardian of JANE DOE NO. 1. As demonstrated in the attached proposed complaint, Applicant has claims for the same causes of action as JANE DOE'S FATHER. Therefore, her claims share common questions of law and fact with the main action. Applicant's motion to intervene is timely because it has been filed within days of the filing of the initial complaint in this action. And, because this action has just been initiated, permitting Applicant to intervene at this stage will not unduly delay the proceedings or prejudice the original parties. Page 2 of 3 EFTA00234043 Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 3 of 3 WHEREFORE, Applicant, JANE DOE's MOTHER, respectfully requests the Court grant her motion to intervene and accept the attached proposed Intervenor's Complaint as filed. Dated: January 29th, 2008 Respectfully submitted, RICCI—LEOPOLD, PA. By: /s/Theodore J. Leopold, Esq. THEODORE J. LEOPOLD I HEREBY CERTIFY that a true and correct copy of the foregoing was filed electronically on January 29th , 2008 with the Clerk of the Court through ECF, and that ECF will send an c-notice of the electronic filing to the following: Jeffrey M. Herman, Mermelstein, Stuart S. Adam I). Ilorowitz, /s/Theodore J. Leopold, Esq. THEODORE J. LEOPOLD, ESQ. Florida Bar No. 705608 RICCI-LEOPOLD, P.A. Page 3 of 3 EFTA00234044

Related Documents (6)

DOJ Data Set 9OtherUnknown

Case 9:08-cv-80069-KAM

Case 9:08-cv-80069-KAM Document 4-1 Entered on FLSD Docket 01/29/2008 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80069 CIV-MARRA/JOHNSON JANE DOE NO.1, by and through JANE DOE's FATHER as parent and natural guardian, and JANE DOE's FATHER, and JANE DOE's STEPMOTHER, individually, Plaintiffs, JANE DOE'S MOTHER, individually and as parent and natural guardian of JANE DOE NO. 1, Intervenor-Plaintiff, vs. JEFFREY EPSTEIN, Defendant. MOTION TO STAY PROCEEDINGS PENDING JANE DOE NO. 1 REACHING AGE OF MAJORITY JANE DOE'S MOTHER, individually and as parent and natural guardian of JANE DOE NO. 1, by and through the undersigned counsel, moves the Court to stay these proceedings pending JANE DOE NO. 1 reaching the age of majority, and as grounds for said motion states as follows: 1. JANE DOE NO. 1 is a minor child, 17 years of age, who is under the joint control of her parents and natural guardians, JANE DOE'S FATHER and JANE DOE'S M

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DOJ Data Set 9OtherUnknown

Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 31 Entered on FLSD Docket 07 29 '2008 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. I JANE DOE NO. 3, vs. JEFFREY EPSTEIN. JANE DOE NO. 4, vs. JEFFREY EPSTEIN. JANE DOE NO. 5, vs. JEFFREY EPSTEIN. CASE NO.: 08-80119-CIV-ICAM-LRJ CASE NO.: 08-80232-CIV-KAM-LRJ CASE NO.: 08-80380-CIV-KAM-LRJ CASE NO.: 08-80381-CIV-KAM-LRJ DEFENDANT'S NOTICE OF FILING EXHIBITS Defendant Jeffrey Epstein hereby files the following two exhibits to his Reply in Support of Motion to Stay, filed under seal on July 28, 2008: A. Exhibit "A" is the July 9, 2008 Declaration of Assistant United States Attorney , M previously filed by the United States in In re: Jane Doe, Case No. 08- 80736-CIV-Marra/Johnson (S.D. Fla.) (DE 14). LeaTsinri 3059 GRAND Avavue. Surn 340.COCONtri GROvE. FLORIDA 33133 EFTA00221651 Case 9:08-cv-80119-KAM Document 31 Entered on FLSD Docket 07'29'2008 Page 2 of 3

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DOJ Data Set 9OtherUnknown

U.S. Department of Justice

U.S. Department of Justice FILE COPY United States Attorney • Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 44.10, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH A LEGAL PROCEEDING. EFTA00223533 U.S. Department of Justice United States Attorney" Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561)820-8711 Facsimile: (561) 820-8777 July 10, 2008 VIA FACSIMILE AND U.S. MAIL Richard H. Willits. P.A. Re: Jeffrey Epstein : NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Willits: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to your client, On June 30

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DOJ Data Set 11OtherUnknown

EFTA02729648

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DOJ Data Set 9OtherUnknown

Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 12 Entered on FLSD Docket 06/20/2008 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. DEFENDANT'S MOTION FOR STAY Defendant Jeffrey Epstein respectfully moves for a mandatory stay of this action under Title 18, United States Code, Section 3509(k). As discussed below, this action is subject to a mandatory stay based on the existence of two pending parallel criminal actions. Introduction This civil action is a private counterpart to two ongoing criminal actions, one in Palm Beach state court, the other in Miami federal court. Both cases purport to arise from the same occurrence: the alleged sexual assault of a minor, Jane Doe No. 2. A federal statute directly on point provides that when an alleged sexual assault involving a child victim results in a "criminal proceeding," a commonly EFTA00221641 Case 9:08-cv-80119-KAM

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DOJ Data Set 9OtherUnknown

Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 105 Entered on FLSD Docket 05:19/2009 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. MOTION FOR LEAVE TO WITHDRAW AS CO-COUNSEL LEWIS TEIN, P.L. hereby moves for leave to withdraw as co-counsel for defendant Jeffrey Epstein, stating as follows: 1. On December 30, 2008, Lewis Tein filed its notice of withdrawal as counsel for Mr. Epstein [DE 53], noting that two other law firms who previously entered their appearance on Mr. Epstein's behalf would remain as co-counsel. 2. We have since learned through discussions with the Clerk of Court that absent a formal order of withdrawal by this Court, Lewis Tein will continue to be listed as counsel for Mr. Epstein on the CM/ECF. 3. Accordingly, Lewis Tein respectfully requests that this Court enter an order allowing it to withdraw as counsel for Mr. Epstein. Lewis 'reins.

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