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Case 9:08-cv-80804-KAM Document 3 Entered on FLSD Docket 07/25/2008 Page 1 of 6

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

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

JANE DOE, a/k/a
JANE DOE NO. 1,

Plaintiff,

vs.

JEFFREY EPSTEIN, HALEY
ROBSON, and SARAH KELLEN,

Defendants.
________________________________/

DEFENDANTS JEFFREY EPSTEIN AND SARAH KELLEN’S MOTION
FOR ENLARGEMENT OF TIME TO ANSWER OR OTHERWISE
RESPOND TO COMPLAINT

Defendants Jeffrey Epstein and Sarah Kellen move, pursuant to Rule 7.1(A)

of the Local Rules of the United States District Court for the Southern District of

Florida, for an enlargement of time to answer or otherwise respond to the amended

complaint until ten days after their motion for stay, filed contemporaneously with

this motion, is decided, and as grounds for this relief respectfully state as follows:

1. This civil action is a private counterpart to a pending federal criminal

action.

3059 GRAND AVENUE, SUITE 340, COCONUT GROVE, FLORIDA 33133
Case 9:08-cv-80804-KAM Document 3 Entered on FLSD Docket 07/25/2008 Page 2 of 6

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

2. The pending criminal action purports to arise from the alleged sexual

assault of a minor, Jane Doe.

3. Mr. Epstein and Ms. Kellen have filed a motion, contemporaneous

with the filing of this motion, seeking a stay of this action under 18 U.S.C. § 3509.

Under that section, when an alleged sexual assault involving a child victim results

in a “criminal proceeding,” a commonly derived civil suit “shall be stayed until the

end of all phases of the criminal action.” 18 U.S.C. § 3509(k) (emphasis added).

4. If Mr. Epstein and Ms. Kellen’s stay motion is granted, they will not

be required to respond to

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