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

ase 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, notice of the relief sought by Jane Doe's Mother is fatally defective

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

ase 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, notice of the relief MI VI sought by other is fatally defective. 3.

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

ase 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, notice of the relief sought by Jane Doe's Mother is fatally defective.