Court Records
Case 9:08-cv-80119-KAM Document 104-1 Entered on FLSD Docket 05/19/2009 Page 1 of 6
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE NO.2,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
CASE NO.; 08-CV-801I9-MARRA/
JANE DOE NO.3, CASE NO.; 08-CV-80232-MARRA/
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
JANE DOE NO.4, CASE NO.; 08-CV-80380-MARRA/
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
JANE DOE NO. 5,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
CASE NO.; 08-CV-80381-MARRA/
Ail
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JANE DOE NO. 6,
Plaintiff, CASE NO.; 08-CV-80994-MARRA/
vs.
JEFFREY EPSTEIN,
Defendant.
JANE DOE NO. 7, CASE NO.; 08-CV-80993-MARRA/
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
C.M.A., CASE NO.; 08-CV-80811-MARRA/
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
JANE DOE, CASE NO.; 08-CV-80893-MARRA/
Plaintiff,
vs.
JEFFREY EPSTEIN, et al.,
Defendants.
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DOE II,
Plaintiff, CASE NO.; 08-CV-80469-MARRA/JOHNSON
vs.
JEFFREY EPSTEIN, et al,
Defendants.
JANE DOE NO. 101, CASE NO.; 08-CV-80591-MARRA
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
JANE DOE NO. 102, CASE NO.; 08-CV-80656-MARRA/JOHNSON
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
AFFIDAVIT OF MICHAEL J. PIKE, ESQUIRE
STATE OF FLORIDA
SS
COUNTY OF PALM BEACH )
PERSONALLY APPEARED before the undersigned Notary Public, Michael
J. Pike, Esq., who after being sworn states the following:
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Case 9:08-cv-80119-KAM Document 104-1 Entered on FLSD Docket 05/19/2009 Page 4 of 6
1. My name is Michael Pike, and I am one of the attorneys assigned
to this matter. Burman, Critton, Luttier and Coleman, LLP, Robert D. Critton, Jr.,
Esq., J. Michael Burman, Esq., and I represent Jeffrey Epstein. I have
knowledge of the facts outlined in the Motion to Strike Cases from Current Trial
Dockets and/or Motion to Continue Cases and/or Motion to Modify Trial and
Scheduling Orders ("Motion to Strike"). I have fully read the Motion, and I
personally drafted the Motions and Replies to various discovery responses
identified by docket entry in the Motion to Strike.
2. The information set forth in the Motion to Strike is true and accurate
in that the undersigned law firm, on behalf of Jeffrey Epstein, has attempted in
good faith to obtain discovery in preparation for trial and in accordance with this
Court's Order Setting Trial Date and Discovery Deadlines, Referring Case to
Mediation and Referring Discovery Motions to the United States Magistrate
Judge.
3. Unfortunately, due to the Plaintiff's delays, objections to relevant
discovery and refusal to allow Jeffrey Epstein to identify Plaintiffs in other Third-
Party Subpoenas, the undersigned has a good faith belief that it will be
impossible to complete discovery pursuant to the Court's Scheduling Order. In
fact, as outlined in the Motion to Strike, it is abundantly clear that Jeffrey Epstein
has not been afforded any meaningful discovery and cannot properly prepare the
cases for trial. It will also be impossible to satisfy the remaining schedules
referenced in the Motion.
4. In short, Plaintiffs have refused and/or failed to produce any
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meaningful discovery and/or answer any meaningful discovery responses. As a
result, the undersigned has not had an opportunity to depose any individuals that
may have information about the allegations made by Plaintiffs.
5. Next, as stated in the Motion to Strike, Plaintiffs' counsel refuses to
allow the undersigned law firm to identify Plaintiffs by their true legal names in
the style of the case and/or identify the Plaintiffs in any third party subpoenas,
which has effectively prevented the undersigned law firm from obtaining any
meaningful discovery about the Plaintiffs and/or the damages they seek. As
stated in the Motion to Strike, Brad EM has agreed to such a procedure
relative to third party subpoenas.
6. As a result, good cause has been shown to continue the actions or
modify the schedules. Therefore, the cases should be struck from the current
trial dockets, continued to the next available trial dockets or, alternatively, the
discovery schedules and other related schedules outlined in the Court's
Scheduling Orders should be modified as requested in the Motion. Without the
granting of the Continuance and/or a Modified Scheduling Order, Mr. Epstein's
due process rights will be violated in that he will not be able to prepare and
properly defend the cases for trial. This will substantially prejudice Jeffrey
Epstein.
FURTHER THE AFFIANT SAYETH NAUGH
STATE OF FLORIDA
COUNTY OF PALM BEACH
Mich YI J. Pi e, sq.
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Case 9:08-cv-80119-KAM Document 104-1 Entered on FLSD Docket 05/19/2009 Page 6 of 6
I hereby Certify that on this day, before me, an officer duly authorized to
administer oaths and take acknowledgments, personally appeared
Michael J. Pike, Esquire, known to me to be the person described in and who
executed the foregoing Affidavit, who acknowledged before me that he/she
executed the same, that I relied upon the following form of identification of the
above named person:49/0-'94a_ .77 .4,ea" , and that an oath was/was
not taken.
IT SS my hand and official seal in the County and State last aforesaid
this day of /V , 2009.
(S JF-SSICA CADWELL
MY COMMON I DO 853529
COVES: Apnl 19.2013 Bonded inns Nests Mt Uneenvreen
y
C_ a -0C be)
RINT NAME: - --t----55/(24 e NOTARY PUBLIC/STATE OF FLORIDA
COMMISSION NO.:
MY COMMISSION EXPIRES:
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