Court Records
Case 9:09-cv-80591-KAM Document 40 Entered on FLSD Docket 06/04/2009 Page 1 of 10 Plaintiff, vs. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:09-CV-80591-KAM Jeffrey Epstein, Defendant. / MOTION FOR LIMITED APPEARANCE, CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILINGS In accordance with Local Rule 4.13 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 Michael D. Shumsky, of the law firm of Kirkland & Ellis LLP (655 15th Street N.W., Washington, D.C. 20005, Telephone: 202-879- 5228), 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, CM/ECF Administrative Procedures, to permit Michael D. Shumsky to receive electronic filings in this case, and in support thereof states as follows: I. Michael D. Shumsky 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 Connecticut and District of Columbia, and is admitted to practice before the United States Supreme Court, the United States Courts of Appeals for the Second Circuit, Seventh Circuit, Ninth Circuit, District of Columbia Circuit, and Federal Circuit, and the United States District Court for the District of Columbia. EFTA02738477 Qase 9:09-cv-80591-KAM Document 40 Entered on FLSD Docket 06/04/2009 Page 2 of 10 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: [Phone Redacted]), 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 though 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, Michael D. Shumsky has made payment of this Court's $75 admission fee. A certification in accordance with Rule 4B is attached hereto. 4. Michael D. Shumsky, 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 Michael D. Shumsky at email address: michael.shumsky@,kirkland.com. WHEREFORE, Robert D. Critton, Jr. moves this Court to enter an Order permitting Michael D. Shumsky 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 Michael D. Shumsky. CERTIFICATE OF SERVICE EFTA02738478 Case 9:09-cv-80591-KAM Document 40 Entered on FLSD Docket 06/04/2009 Page 3 of 10 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 21g day of May, 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 [Phone Redacted] Fax: [Phone Redacted] riosefsberalanodhurst.com kezellanodhurst.com Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 [Phone Redacted] Fax: [Phone Redacted] [Email Redacted] Counsel for Defendant Jeffrey Epstein Respectfully subny ted ROBERT O. CRITTON, JR., ESQ. Florida ar No. 224162 rcritebdclaw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mvikeabc1claw.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) EFTA02738479 case 9:09-cv-80591-KAM Document 40 Entered on FLSD Docket 06/04/2009 Page 4 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:09-CV-80591-ICAM Jane Doe 101, Plaintiff, vs. Jeffrey Epstein, Defendant. CERTIFICATION OF MICHAEL D. SHUMSKY Michael D. Shumsky, Esquire, pursuant to Rule 4B of the Special Rules Governing the Admission and Practice of Attorneys, hereby certifies that (1) I have studied the Local Rules of the United States District Court for the Southern District of Florida; and (2) I am a member in good standing of the bars of the State of Connecticut and District of Columbia, and am admitted to practice before the United States Supreme Court, the United States Courts of Appeals for the Second Circuit, Seventh Circuit, Ninth Circuit, District of Columbia Circuit, and Federal Circuit, and the United States District Court for the District of Columbia. Michael D. Shumsky EFTA02738480 Case 9:09-cv-80591-KAM Document 40 Entered on FLSD Docket 06/04/2009 Page 5 of 10 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' day of Mav, 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 [Phone Redacted] Fax: [Phone Redacted] rjosefsbergenodhurst.com kezellQuodhurst.com Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 [Phone Redacted] Fax: [Phone Redacted] iagesaebellsouth.net Counsel for Defendant Jeffrey Epstein Respectfully su itted, By: ROBERT . CRITTON, JR., ESQ. Florida No. 224162 [Email Redacted] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [Email Redacted] BURMAN, CRITTON, LUTHER & 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) EFTA02738481 ease 9:09-cv-80591-KAM Document 40 Entered on FLSD Docket 06/04/2009 Page 6 of 10 United States District Court for the District of Columbia CLERK'S OFFICE 333 Constitution Avenue, NW Washington, DC 20001 I, NANCY M. MAYER-WHITTINGTON, Clerk of the United States District Court for the District of Columbia, do hereby certify that: MICHAEL D. SHUMSKY was, on the 2nd day of October A.D. 2006 admitted to practice as an Attorney at Law at the Bar of this Court, and is, according to the records of this Court, a member of said Bar in good standing. In Testimony Whereof, I hereunto subscribe my name and affix the seal of said Court in the City of Washington this 27th day of May A.D. 2009. NANCY M. MAYER-WHITTINGTON, CLERK By: EFTA02738482 Case 9:09-cv-80591-KAM Document 40 Entered on FLED Docket 06/04/2009 Page 7 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:09-CV-80591-KAM Jane Doe 101, Plaintiff, vs. Jeffrey Epstein, Defendant. ORDER GRANTING MOTION FOR LIMITED APPEARANCE OF MICHAEL D. SHUMSKY, CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILINGS THIS CAUSE having come before the Court on the Motion for Limited Appearance of Michael D. Shumsky and Consent to Designation, requesting, pursuant to Rule 4B of the Special Rules Governing the Admission and Practice of Attorneys in the United States District Court for the Southern District of Florida, permission for a limited appearance of Michael D. Shumsky in this matter and request to electronically receive notice of electronic filings. This Court having considered the motion and all other relevant factors, it is hereby ORDERED and ADJUDGED that: The Motion for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filings is GRANTED. Michael D. Shumsky is granted to appear and participate in this action on behalf of Jeffrey Epstein. The Clerk shall provide electronic notification of all electronic filings to Michael D. Shumsky at michael.shumsky®Icirkland.com. EFTA02738483 Case 9:09-cv-80591-KAM Document 40 Entered on FLSD Docket 06/04/2009 Page 8 of 10 Case No. 9:09-CV-80591-KAM DONE AND ORDERED in day of Copies furnished to: All Counsel of Record at , Florida this United States District Judge EFTA02738484 Case 9:09-cv-80591-KAM Document 40 Entered on FLSD Docket 06/04/2009 Page 9 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:09-CV-80591-KAM Jane Doe 101, Plaintiff, vs. Jeffrey Epstein, Defendant. ORDER GRANTING MOTION FOR LIMITED APPEARANCE OF MICHAEL D. SHUMSKY, CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILINGS THIS CAUSE having come before the Court on the Motion for Limited Appearance of Michael D. Shumsky and Consent to Designation, requesting, pursuant to Rule 4B of the Special Rules Governing the Admission and Practice of Attorneys in the United States District Court for the Southern District of Florida, permission for a limited appearance of Michael D. Shumsky in this matter and request to electronically receive notice of electronic filings. This Court having considered the motion and all other relevant factors, it is hereby ORDERED and ADJUDGED that: The Motion for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filings is GRANTED. Michael D. Shumsky is granted to appear and participate in this action on behalf of Jeffrey Epstein. The Clerk shall provide electronic notification of all electronic filings to Michael D. Shumsky at michael.shumsky®kirkland.com. EFTA02738485 . Case 9:09-cv-80591-KAM Document 40 Entered on FLSD Docket 06/04/2009 Page 10 of 10 Case No. 9:09-CV-80591-ICAM DONE AND ORDERED in at , Florida this day of United States District Judge Copies furnished to: All Counsel of Record EFTA02738486