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Case 9:08-cv-80804-KAM Document 24 Entered on FLSD Docket 09/18/2008 Page 1 of 4
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
RESPONSE TO DEFENDANT EPSTEIN’S MOTION TO DISMISS
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 respond to
Defendant Epstein’s Motion to Dismiss until fifteen days after the Court rules on her motion to
remand.
1. Defendants removed this action to federal court on July 21, 2008. (DE 1).
2. Plaintiff filed a motion to remand on August 18, 2008. (DE 11). 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.
3. If this action was improperly removed and is, consequently, remanded to state court
for lack of jurisdiction, it would be a waste of time and resources for Plaintiff to
respond to and the Court to consider Defendant Epstein’s motion to dismiss.
Case 9:08-cv-80804-KAM Document 24 Entered on FLSD Docket 09/18/2008 Page 2 of 4
WHEREFORE, Plaintiff respectfully requests the Court grant her motion for an
enlargement of time to respond to Defendant Epstein’s motion to dismiss until fifteen days after
the Court rules on her motion to remand.
CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3
On September 18, Plaintiff’s cou
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