Case 9:09-cv-80591-KAM

Document 25

Entered on FLSD Docket 05/21/2009

Page 1 of 3

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

Case No. 9:09-CV-80591-KAM

Jane Doe 101,
 Plaintiff,
 vs.
 Jeffrey Epstein,
 Defendant.

MOTION FOR LIMITED APPEARANCE, CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILINGS

In accordance with Local Rule 4.B of the Special Rules Governing the Admission and Practice of Attorneys of the United States District Court for the Southern District of Florida, the undersigned respectfully moves for the admission of Jay P. Lefkowitz, P.C., of the law firm of Kirkland & Ellis LLP (Citigroup Center, 153 East 53rd Street, New York, New York 10022- 4611, Telephone: 212-446-4970), for purposes of limited appearance as co-counsel on behalf of Defendant Jeffrey Epstein herein, in the above-styled case only, and pursuant to Rule 2B, Southern District of Florida, CMJECF Administrative Procedures, to permit Jay P. Lefkowitz, P.C. to receive electronic filings in this case, and in support thereof states as follows:

I. Jay P. Lefkowitz is not admitted to practice in the Southern District of Florida and is a member in good standing of the bars of the State of New York and District of Columbia, and is admitted to practice before the United States Supreme Court, the United States Courts of Appeals for the District of Columbia Circuit, Second Circuit, Fourth Circuit, Fifth Circuit, Eighth Circuit, Ninth Circuit, and Eleventh Circuit, the United States District Courts for the

Case 9:09-cv-80591-KAM Document 25 Entered on FLSD Docket 05/21/2009 Page 2 of 3

District of Columbia, Southern District of New York, Eastern District of Michigan, Eastern

District of Wisconsin, and District of Colorado, and the United States Tax Court.

2. Movant, Robert D. Critton, Jr., Esquire, of the law firm of Burman Critton Luttier & Coleman, P.A. (515 N. Flagler Drive, Suite 400, West Palm Beach, FL 33401, Telephone: 561-842-2820), is a member in good standing of The Florida Bar and the United States District Court for the Southern District of Florida, maintains an office in this State for the practice of law, and is authorized to file through the Court's electronic filing system. Movant consents to be designated as a member of the Bar of this Court with whom the Court and opposing counsel may readily communicate regarding the conduct of the case, upon whom filings shall be served, who shall be required to electronically file all documents and things that may be filed electronically, and who shall be responsible for filing documents in compliance with the CM/ECF Administrative Procedures. See Section 2B of the CM/ECF Administrative Procedures.

3. In accordance with the local rules of this Court, Jay P. Lefkowitz, P.C. has made

payment of this Court's $75 admission fee. A certification in accordance with Rule 4B is

attached hereto.

4. Jay P. Lefkowitz, P.C., by and through designated counsel and pursuant to Section 2B, Southern District of Florida, CM/ECF Administrative Procedures, hereby requests the Court to provide Notice of Electronic Filings to Jay P. Lefkowitz, P.C. at email address: jay.lefkowitz@kirkland.com.

WHEREFORE, Robert D. Critton, Jr. moves this Court to enter an Order permitting Jay P. Lefkowitz, P.C. to appear before this Court on behalf of Jeffrey Epstein for all purposes relating to the proceedings in the above-styled matter and directing the Clerk to provide notice of electronic filings to Jay P. Lefkowitz, P.C.

Case 9:09-cv-80591-KAM

Document 25

Entered on FLSD Docket 05/21/2009

Page 3 of 3

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filings 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 21 st day of May, 2009

| Robert C. Josefsberg, Esq.        | Jack Alan Goldberger, Esq.            |
|-|-|
| Katherine W. Ezell, Esq.          | Atterbury Goldberger & Weiss, P.A.    |
| Podhurst Orseck, P.A.             | 250 Australian Avenue South           |
| 25 West Flagler Street, Suite 800 | Suite 1400                            |
| Miami, FL 33130                   | West Palm Beach, FL 33401-5012        |
| 305 358-2800                      | 561-659-8300                          |
| Fax: 305 358-2382                 | Fax: 561-835-8691                     |
| rjosefsberg@podhurst.com          | jagesg@bellsouth.net                  |
| kezell@podhurst.com               | Counsel for Defendant Jeffrey Epstein |
| Counsel for Plaintiff             |                                       |

Respectfully submitted,

<signature>
ROBERT D. CRITTON, JR., ESQ.
Florida Bar No. 224162
rcrit@bclclaw.com
MICHAEL J. PIKE, ESQ.
Florida Bar #617296
mpike@bclclaw.com
BURMAN, CRITTON, LUTTIER & COLEMAN
515 N. Flagler Drive, Suite 400
West Palm Beach, FL 33401
561/842-2820 Phone
561/515-3148 Fax
(Counsel for Defendant Jeffrey Epstein)
court-records/Doe No. 101 v. Epstein, No. 909-cv-80591 (S.D. Fla. 2009)/025.pdf
{"year":"2009","court":"S.D. Fla","people":["jeffrey epstein","jay p. lefkowitz","robert d. critton","robert c. josefsberg","jack goldberger","katherine w. ezell","michael j. pike"]}