Epstein Secrets

ered on FLSD Docket 11/05/2009 Page 3 of 4 give plaintiffs ten days notice prior to the transfer of any assets in excess of $500). Additionally, as the Eleventh Circuit explained in Rosen: In actions at law, plaintiffs in Florida possess an adequate, exclusive prejudgment remedy for the sequestration of assets unde

0 Entered on FLSD Docket 11/05/2009 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON  JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-80380, 08-80993,08-80811, 09-80591, 09-80656, 08-80381, 08-80994,

njoin the stay. And we conclude that this provision does not violate separation of powers principles.") (emphasis added). One district court within the Eleventh Circuit, facing the identical issue with a pending state prosecution, recently construed "the plain language of § 3509(k)" as "requirfing] a stay in a case

12 Entered on FLSD Docket 06/20/2008 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. DEFENDANT'S MOTION FOR STAY Defendant Jeffrey Epstein respectfully moves for a mandatory stay of

". Defendant has not to date filed a "responsive pleading" in this case within the meaning of Fed.R.Civ.P. 7(a). It is established in the courts of the Eleventh Circuit that a motion to dismiss is not a "responsive pleading" and does not affect a plaintiff's right to amend the pleading once as a matter of course. Wi

41 Entered on FLSD Docket 09/22/2008 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT'S MOTION TO DISMISS Plaintiff, Jane Doe No. 2,

ss, prejudice, and a meritorious defense are the most often 'In Bonner.. City of Pritchard, 661 F.2d 1206, 1207 & 1209 (11111 Cir. 1981) (en banc), the Eleventh Circuit adopted as binding precedent the decisions of the Fifth Circuit rendered prior to October 1, 1981. 2 EFTA00222637 Case 9:08-cv-80381-KAM Docume

ument 26 Entered on FLSD Docket 07'16/2008 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80381-CIV-MARRA/JOHNSON JANE DOE NO. 5, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. OPINION AND ORDER ON MOTION TO SET ASIDE CLERK'S ENTRY OF DEFAULT THIS CAUSE comes before the Co

njoin the stay. And we conclude that this provision does not violate separation of powers principles.") (emphasis added). One district court within the Eleventh Circuit, facing the identical issue with a pending state prosecution, recently construed "the plain language of § 3509(k)" as "requirfing] a stay in a case

12 Entered on FLSD Docket 06/20/2008 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. DEFENDANT'S MOTION FOR STAY Defendant Jeffrey Epstein respectfully moves for a mandatory stay of