Epstein Secrets

12008 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80069-CIV-MARRA/JOHNSON JANE DOE NO. I, by and through JANE DOE's FATHER as parent and natural guardian, and JANE DOE's FATHER, and JANE DOE's STEPMOTHER, individually, Plaintiffs, vs. JEFFREY EPSTEIN, Defenda

-1 Entered on FLSD Docket 02/13/2008 Page 4 of 5 Doe's Father, as the custodial parent, is the natural guardian, and the only natural guardian, of Jane Doe. As the natural guardian, Jane Doe's Father may sue on behalf of Jane Doe. See Fed.R.Civ.P. 17(b) (providing that capacity to sue or be sued shall b

Stay is defective and should be stricken. The Motion to Stay also raises due process concerns because it was not served on all parties according to the Certificate of Service accompanying the Motion. The Defendant has not yet filed an appearance in the case, and his response to the Complaint is not yet due. The Motion to

3/2008 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80069-CIV-MARRA/JOHNSON JANE DOE NO. I, by and through JANE DOE's FATHER as parent and natural guardian, and JANE DOE's FATHER, and JANE DOE's STEPMOTHER, individually, Plaintiffs, vs. JEFFREY EPSTEIN, Defenda

nt 7 Entered on FLSD Docket 02/13/2008 Page 4 of 5 Doe's Father, as the custodial parent, is the natural guardian, and the only natural guardian, of Jane Doe. As the natural guardian, Jane Doe's Father may sue on behalf of Jane Doe. See Fed.R.Civ.P. 17(b) (providing that capacity to sue or be sued shall b

Stay is defective and should be stricken. The Motion to Stay also raises due process concerns because it was not served on all parties according to the Certificate of Service accompanying the Motion. The Defendant has not yet filed an appearance in the case, and his response to the Complaint is not yet due. The Motion to

supplied). b. "I am the mother and natural guardian for Jane Doe No. I.. .." (Affidavit of ¶ 1) (emphasis supplied). Exh. "A" to Motion to Stay, Jane Doe's Mother does not have "joint control" or legal custody of Jane Doe, and is not her natural guardian under Florida law. Jane Doe's Mother and Jane Doe

Stay is defective and should be stricken. The Motion to Stay also raises due process concerns because it was not served on all parties according to the Certificate of Service accompanying the Motion. The Defendant has not yet filed an appearance in the case, and his response to the Complaint is not yet due. The Motion to

lleged the following: In fact. RRA did have inside information due to its representation of one of Epstein's alleged victims in a civil case styled Jane Doe v. Jeffrey Epstein, pending in the Southern District of Florida. Representatives of D3 were offered Tonja Haddad, P.A. • 315 SE 7" Street, Fort Lau

tes upon which each and every purported abuse of process occurred, Edwards again replied: "the date of service of each of the above as reflected on the Certificate of Service of each." Accordingly, Edwards has not pointed to, and indeed cannot point to, one act either outside of or extrinsic to the litigation, undeniably

lleged the following: In fact, RRA did have inside information due to its representation of one of Epstein's alleged victims in a civil case styled Jane Doe v. Jeffrey Epstein, pending in the Southern District of Florida. Representatives of D3 were offered Tonja Haddad?... • 315 SE 7th Street, Fort L

tes upon which each and every purported abuse of process occurred, Edwards again replied: "the date of service of each of the above as reflected on the Certificate of Service of each." Accordingly, Edwards has not pointed to, and indeed cannot point to, one act either outside of or extrinsic to the litigation, undeniably

CASE NO.: 08-80069-CIV-MARRA/JOHNSON JANE DOE. NO. 1, by and through JANE DOB's FATHER as parent and natural guardian, and JANE DOB's FATHER, and JANE DOE's STEPMOTHER, individually, Plaintiffs, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFFS' MEMORANDUM OF LAW IN OPPOSITION TO MOTION TO STAY PROCEEDINGS

Stay is defective and should be stricken. The Motion to Stay also raises due process concerns because it was not served on all parties according to the Certificate of Service accompanying the Motion. The Defendant has not yet filed an appearance in the case, and his response to the Complaint is not yet due. The Motion to