Epstein Secrets

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

lows: I. Introduction This action alleges the sexual assault of Plaintiff Jane Doe No. 1 ("Jane Doe") by the Defendant when she was 14 years old. The Motion to Stay Proceedings filed by Jane Doe's Mother is without basis and should be stricken or denied for the following reasons: I. It fails to include or be accompanied b

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

ng Age of Majority, as follows: I. Introduction This action alleges the sexual assault of Plaintiff by the Defendant when she was 14 years old. The Motion to Stay Proceedings filed bother is without basis and should be stricken or denied for the following reasons: I. It fails to include or be accompanied by a memorandum

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

lows: I. Introduction This action alleges the sexual assault of Plaintiff Jane Doe No. 1 ("Jane Doe") by the Defendant when she was 14 years old. The Motion to Stay Proceedings filed by Jane Doe's Mother is without basis and should be stricken or denied for the following reasons: 1. It fails to include or be accompanied b