UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CV-80232-MARRA/JOHNSON JANE DOE NO Pl-3ai-3nt-3i-3ff vs JEFFREY EPSTEIN Defendant PLAINTIFF 2S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO DEFENDANT 2S MOTION FOR STAY 2556Plaintiff Jane Doe No by and through undersigned counsel files this Motion for Enlargem8ent of Tim8e-1 to Respond to Defendant 2s Motion for Stay and states as follows Defendant filed his Motion for Stay on June Plaintiff 2s response is due on or before July Defendant 2s Motion for Stay is based upon the existence of purported parallel crim8inal actions and is grounded in section of Title United tates Code Subsequent to filing his Motion for Stay on July Defendant Epstein filed a Notice advising this Court that the State Court cr im9inal action against the Defendant was resolved but that the federal crim9inal proceeding rem9ained pending It is Plaintiff 2s counsel 2s understanding from9 press reports however that the federal crim9in al proceeding will be reso lved in the sam9e plea deal which would m8a-1ke the Defendant 2s Motion for Stay m8oot Therefore Plaintiff respectfully requests a brief4 enlargem9ent of4 tim9e of4 twenty days within which to file a m)8e-1m8o1randum8 in oppos ition to Defendant 2s Motion for Stay This Case Document Entered on FLSD Docket Page of request for enlargem9ent of tim9e is in the interest of judicial econom9y and efficiency Addi-5t-5i-5ona-4l-5l-5y 2s counsel requests this enlargem9ent of tim9e due to the dem9ands on their tim9e in other cases and m9atters Prior to filing this Motion Plaintiff 2s couns el Adam8 Horowitz attem8p1ted to confer with defense counsel to no avail 2665W10H3EREFORE Plaintif4f4 respectf4u1lly request th at this Court enter an order enlarging by twenty days the tim)9e with in which the Plaintiff m8a-1y respond to the Defendant 2s Motion for Stay until July Dated July 2750Respectfully subm8itted By Adam8 Horowitz Jeffrey Herm8an FL Bar No jherm9an herm9anlaw.com Stuart Merm8elstein FL Bar No ssm8 herm8a-1nlaw.com Adam8 Horowitz FL Bar No ahorowitz herm8a-1nlaw.com HERMAN MERMELSTEIN P.A Attorneys for Plaintiffs Jane Doe Biscayne Blvd Suite Miam9i Florida Tel Fax Plaintiff opposes the Motion for Stay on its m8e-1rits under U.S.C Case Document Entered on FLSD Docket Page of CERTIFICATE OF SERVICE I hereby certify that on July I electroni cally filed the foregoing docum9ent with the Clerk of the Court using I also certify that the foregoing docum9ent is being served this day to all parties on the attached Service List in the m9anner specified either via transm9ission of Notices of Filing generated by CM/ECF or in som9e other authorized m9anner for those parties who are not authorized to receive electr onically Notices of Electronic Filing Adam8 Horowitz Case Document Entered on FLSD Docket Page of SERVICE LIST DOE vs JEFFREY EPSTEIN CASE NO 08-CV-80232-MARRA/JOHNSON United States District Court 2Southern District of Florida Jack Alan Goldberger jagesq bellsouth.net Michael Tein tein lewistein.com Adam8 Horowitz Case Document Entered on FLSD Docket Page of
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