EFTA00728148.pdf

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 4.13 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: 1. 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. EFTA00728148  2. Movant, Robert D. Critton, 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, 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: WHEREFORE, Robert D. Critton 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. EFTA00728149 Dated: Respectfully submitted, Robert D. Critton, Jr. Florida Bar No. 224162 Burman Critton Luttier & Coleman, P.A. 515 N. Flagler Drive Suite 400 West Palm B Telephone: Facsimile: Attorney for Defendant Jeffrey Epstein EFTA00728150  UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:09-CV-80591-KAM 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. EFTA00728151  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 served by [specify method of service] on [date] on all counsel or parties of record on the service list. Robert D. Critton SERVICE LIST Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck Josefsberg et al. City National Bank Building 25 W Flagler Street, Suite 800 Miami, FL 3 Telephone: Fax: Attorneys for Plaintiff Jane Doe 101 EFTA00728152  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 EFTA00728153