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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
and his response to the Complaint is not yet due. The Motion to Stay is ' The stated exceptions to Rule 7.1(A)(1) are inapplicable here. HERMAN 5' MERMELSTEIN, P. A. www.hermanlaw.com - 2 - EFTA00234046 Case 9:08-cv-80069-KAM Document 7-1 Entered on FLSD Docket 02/13/2008 Page 3 of 5 therefore prem
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
by Mother, and in preparing this Memorandum of Law in Opposition, Plaintiff is left to guess at the authorities relied upon by Mother. HERMAN 6. MERMELSTEIN, 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
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
es ofJane Doe and Jane Doe's Father are redacted from Exhibit "A" hereto to protect the Minor Plaintiff's anonymity. (See Complaint 1 4). HERMAN 5. MERMELSTEIN, P. A. - 3 - votAchemunlaw.com Case No. 08-80736-CV-MARRA P-003655 EFTA00190771 Case 9:08-cv-80069-KAM Document 7-1 Entered on FLSD Docket 0
Entities connected to both the Certificate of Service and MERMELSTEIN

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSON
Jeffrey Marc Herman
PERSON
Adam D. Horowitz
PERSONStuart S. Mermelstein
PERSONJANE DOE NO
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONFL Bar No.
ORGANIZATION
Oliver Stone
PERSONCourt Order
ORGANIZATIONThe Motion to Stay
ORGANIZATIONThe Motion to Stay Proceedings
ORGANIZATIONthe Motion's Certificate
ORGANIZATIONthe Custodial Parent Modification
ORGANIZATION
Palm Beach County
LOCATIONScott Rothstein
PERSONthe Southern District
LOCATION