Case 9:08-cv-80804-KAM

Document 16 Entered on FLSD Docket 08/29/2008

Page 1 of 3

# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

JANE DOE, by and through JANE
DOE'S MOTHER, as parent and natural
guardian

CASE NO.: 08-80804-CIV-
MARRA/JOHNSON

Plaintiff,

VS.

JEFFREY EPSTEIN, HALEY
ROBSON, and SARAH KELLEN

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, AND IMPROPER SUBMISSION OF PROPOSED ORDER REGARDING PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT TO FILE CML RICO CASE STATEMENT PURSUANT TO LOCAL RULE 12.1

COMES NOW, the Defendant, Haley Robson, by and through her undersigned attorneys, and files this, her Notice of Lack of Compliance with Local Rule 7. 1.8.3 and Notice oflncorrect Assertion of Certification of Compliance with Local Rule 7. I. 8. 3, Inaccurate Characterization ofPlaintiffs Motion for Enlargement ofTime to File Civil Rico Case Statement Purrnant 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

MCINTOSH, SAWRAN, PELTZ, & CARTAYA, P.A. ATTORNEYS AT LAW 1601 FORUM PLACE SUITE 1110 WEST PALM BEACH, FL 33401

TELEPHONE (561) 682-3202

FACSIMILE (561) 682-3206

Case 9:08-cv-80804-KAM Document 16 Entered on FLSD Docket 08/29/2008 Page 2 of 3

## CASE NO. 08-80804-CIV-MARRA/JOHNSON

Pursuant to Local Rule 12.1, as well as a proposed 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 lmown to represent Defendant Haley Robson, were consulted in any way regarding this Motion and most certainly did _ not communicate to opposing counsel regarding whether said Motion would be not communicate to opposing counsel regarding whether said Motion would be opposedor 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
Facsimile: (561) 682-3206
By: <signature>
DOUGLAS M. MCINTOSH
Florida Bar No.: 325597
JASON A. MCGRAITH
Florida Bar No.: 97349

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MCINTOSH, SAWRAN, PELTZ, & CARTAYA, P.A. ATTORNEYS AT LAW 1601 FORUM PLACE SUITE 1110 WEST PALM BEACH, FL 33401

TELEPHONE (561) 682-3202

FACSIMILE (561) 682-3206

Case 9:08-cv-80804-KAM Document 16 Entered on FLSD Docket 08/29/2008 Page 3 of 3

# CASE NO. 08-80804-CIV-MARRA/JOHNSON

## 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, Sarah Kellen) 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, Luttier & Coleman, P.A. 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401

MICHAEL R. TEIN, ESQUIRE

GUY ALAN LEWIS, ESQUIRE
(Attorneys for Defendant, Jeffrey Epstein)
Lewis Tein, P.L.
3059 Grand Avenue, Suite 340
Coconut Grove, FL 33133

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MCINTOSH, SAWRAN, PELTZ, & CARTAYA, P.A. ATTORNEYS AT LAW 1601 FORUM PLACE SUITE 1110 WEST PALM BEACH, FL 33401

TELEPHONE (561) 682-3202 FACSIMILE (561) 682--3206
documents/doj-60374c4c2bfcd3f2.pdf
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