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ve grounds. Plaintiffs therefore respectfully request that the Motion to Stay be denied. Dated: February 13, 2008 Respectfully submitted, By: s/ Jeffrey M. Herman Jeffrey M. Herman (FL Bar No. Stuart S. S. Mermelstein (FL Bar No. =) Adam D. Horowitz (FL Bar No. =) HERMAN & MERMELSTEIN, P.A. Attorneys for Pl
ase 9:08-cv-80069-KAM Document 7-1 Entered on FLSD Docket 02/13/2008 Page 2 of 5 2. The Motion to Stay was not served on all parties as shown on the Motion's Certificate of Service. Only Plaintiff's counsel was served with the Motion. As a result, notice of the relief sought by Jane Doe's Mother is fatally defective
ve grounds. Plaintiffs therefore respectfully request that the Motion to Stay be denied. Dated: February 13, 2008 Respectfully submitted, By: s/ Jeffrey M. Herman Jeffrey M. Herman (FL Bar No. 521647) Stuart S. Mermelstein (FL Bar No. 947245) am orownz Bar o. 376980) HERMAN & MERMELSTEIN, P.A. Attorneys fo
8 Case 9:08-cv-80069-KAM Document 7 Entered on FLSD Docket 02/13/2008 Page 2 of 5 2. The Motion to Stay was not served on all parties as shown on the Motion's Certificate of Service. Only Plaintiff's counsel was served with the Motion. As a result, notice of the relief sought by Jane Doe's Mother is fatally defective
ve grounds. Plaintiffs therefore respectfully request that the Motion to Stay be denied. Dated: February 13, 2008 Respectfully submitted, By: s/ Jeffrey M. Herman Jeffrey M. Herman (FL Bar No. 521647) iliennaigètiliennanlaw.com Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horo
ase 9:08-cv-80069-KAM Document 7-1 Entered on FLSD Docket 02/13/2008 Page 2 of 5 2. The Motion to Stay was not served on all parties as shown on the Motion's Certificate of Service. Only Plaintiff's counsel was served with the Motion. As a result, notice of the relief MI VI sought by other is fatally defective. 3.
Entities connected to both Jeffrey Marc Herman and the Motion's Certificate

Jeffrey Epstein
PERSON
Adam D. Horowitz
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONStuart S. Mermelstein
PERSON
Scarlett Johansson
PERSONJANE DOE NO
PERSONFL Bar No.
ORGANIZATIONMERMELSTEIN
ORGANIZATIONCourt Order
ORGANIZATIONthe Custodial Parent Modification
ORGANIZATION
Oliver Stone
PERSONthe Certificate of Service
ORGANIZATIONThe Motion to Stay
ORGANIZATIONTheodore Jon Leopold
PERSONThe Motion to Stay Proceedings
ORGANIZATIONConver & Co. Communications
ORGANIZATIONADJUDGED
ORGANIZATIONAmerican Manufacturers Mutual Ins
ORGANIZATION