Epstein Secrets

r Continue Action be denied in their entirety. Dated: April 23, 2009 Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) Adam D. Horowitz (FL Bar No. 376980) MERMELSTEIN & 11OROWITZ, P.A. Attorneys for Plaintiffs - 7 - EFTA00201252 Case 9:08-cv-80811-KAM

t is therefore difficult to understand how this can be grounds for a stay. Defendant does nothing more than speculate on the intentions of the USAO. The Motion to Stay is therefore, at best, premature. D. Plaintiffs Would Be Prejudiced by a Stay ° The cases discussing the stay issues are premised on a pending cr

r Continue Action be denied in their entirety. Dated: April 23, 2009 Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERMELSTEIN & HOROWITZ, P.A. Attorneys for

t is therefore difficult to understand how this can be grounds for a stay. Defendant does nothing more than speculate on the intentions of the USAO. The Motion to Stay is therefore, at best, premature. D. Plaintiffs Would Be Prejudiced by a Stay 'The cases discussing the stay issues are premised on a pending cri

ctfully 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 for Plaintiffs Jane Doe et al.

N & MERMELSTEIN, P. A. www.hermanlaw.com - I - EFTA00313588 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, not

ctfully 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. Horowitz (FL Bar No. 376980) aho

ERMELSTEIN, P. A. - 1 - www.hermanlaw.com EFTA00188252 Case 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, not

ctfully request that the Motion to Stay be denied. Dated: February 13, 2008 Respectfully submitted, By: 5/ Jeffrey M. Herman Jeffrey.M. Herman (FL Bar No. 521647) ihermanOltermanlaw.com Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) ahorowi

- 1 - Case No. 08-80736-CV-MARRA P-003653 EFTA00190769 Case 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 Plaintiffs counsel was served with the Motion. Asa result, notic