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Case 9:08-cv-80069-KAM Document 7 Entered on FLSD Docket 02/13/2008 Page 1 of 5

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 08-80069-CIV-MARRA/JOHNSON

JANE DOE NO. 1, by and through
JANE DOE’s FATHER as parent and natural
guardian, and JANE DOE’s FATHER, and
JANE DOE’s STEPMOTHER, individually,

Plaintiffs,
vs.

JEFFREY EPSTEIN,

Defendant.
____________________________________/

PLAINTIFFS’ MEMORANDUM OF LAW IN OPPOSITION
TO MOTION TO STAY PROCEEDINGS PENDING
JANE DOE NO. 1 REACHING AGE OF MAJORITY

Plaintiffs, Jane Doe No. 1, by and through Jane Doe’s Father as parent and natural guardian,

and Jane Doe’s Father and Jane Doe’s Stepmother, individually, submit this Memorandum of Law in

Opposition to Motion to Stay Proceedings Pending Jane Doe No. 1 Reaching Age of Majority, as

follows:

I. Introduction

This action alleges the sexual assault of Plaintiff Jane Doe No. 1 (“Jane Doe”) by the

Defendant when she was 14 years old. The Motion to Stay Proceedings filed by Jane Doe’s Mother

is without basis and should be stricken or denied for the following reasons:

1. It fails to include or be accompanied by a memorandum of law, in violation of

S.D.Fla.L.R. 7.1(A)(1). This failure is particularly glaring here, as there is no obvious or apparent

legal basis for the stay sought by Jane Doe’s Mother, and in preparing this Memorandum of Law in

Opposition, Plaintiff is left to guess at the authorities relied upon by Jane Doe’s Mother.

Herman & Mermelstein, P. A. www.hermanlaw.com
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Case 9:08-cv-80069-KAM Document 7 Entered on FLSD Docket 02/13/2008 Page 2 of 5

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