Epstein Secrets

ERMELSTEIN, P. A. www.hermanlaw.com - 1 - EFTA00234045 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

be considered in a case where there is another pending lawsuit or administrative proceeding addressing the identical issues. See Ortega Trujillo'. Conver & Co. Communications. Inc. 225 F.3d 1262 (11th Cir. 2000). Even then, a case in federal court should not be stayed absent "exceptional circumstances." American Manufact

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

be considered in a case where there is another pending lawsuit or administrative proceeding addressing the identical issues. See Ortega Trujillo v. Conver & Co. Communications. Inc. 225 F.3d 1262 (11th Cir. 2000). Even then, a case in federal court should not be stayed absent "exceptional circumstances." American Manufact

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

be considered in a case where there is another pending lawsuit or administrative proceeding addressing the identical issues. 513e Ortega Trujillo!. Conver & Co. Communications, Inc. 225 F.3d 1262 (I 1 th Cir. 2000). Even then, a case in federal court should not be stayed absent "exceptional circumstances." American Manufa