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Case 9:08-cv-80804-KAM Document 9 Entered on FLSD Docket 08/13/2008 Page 1 of 5




                             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.
 ________________________________/

       PLAINTIFF’S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE
           CIVIL RICO CASE STATEMENT PURSUANT TO LOCAL RULE 12.1

         Plaintiff Jane Doe moves, 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 file a Civil

 RICO Case Statement under Local Rule 12.1 until fifteen days after the Court rules on her

 motion to remand, which will be filed on or about August 18, 2008.

         1.   Defendants removed this action to federal court on July 21, 2008. (DE 1).

         2.   Because Plaintiff has pleaded a cause of action under section 772.103, Florida

              Statutes, she is required to file a Civil RICO Case Statement within thirty days of

              removal. See S.D. Fla. L.R. 12.1.

         3.   Plaintiff believes this action was improperly removed from state court and shall file

              a motion to remand on or about August 18, 2008. It is Plaintiff’s contention that the

              Court lacks subject matter jurisdiction over this case because it does not involve a

              federal question or parties with complete diversity of citizenship.
Case 9:08-cv-80804-KAM Document 9 Entered on FLSD Docket 08/13/2008 Page 2 of 5




        4.   If this action was improperly removed, Plaintiff should not be required to expend the

             time and expense necessary to create and file a Civil Rico Cast Statement, which

             would not be required in Florida state court.

        WHEREFORE,

[…]

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