Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-80804-CJV-MARRA/JOHNSON JANE DOE a/k/a JANE DOE NO Plaintiff vs JEFFREY EPSTEIN HALEY ROBSON and SARAH KELLEN Defendants PROPOSED ORDER THIS CAUSE having come before this Court upon Plaintiff Jane Does UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE CIVIL RICO CASE STATEMENT PURSUANT TO LOCAL RULE and this Court being fully advised it is hereby ORDER.ED AND ADJUDGED that I The Motion is hereby granted Plaintiffs shall have an enlargement of time to file a Civil RICO Case Statement until fifteen days after their motion for remand is decided DONE AND ORDERED this __ day of Copies furnished to All counsel HON Case Document Entered on FLSD Docket Page of CM/ECF Live Database flsd Motions QS-c.1t aOSQ4 _Qoe e.in.et,il U.S District Court Southern District of Florida Notice of Electronic Filing Page of The following transaction was entered by Kuvin Spencer on at PM EDT and filed on Case Name Case Number Doe Epstein et al Filer Jane Doe Document Number Docket Text Unopposed MOTION for Extension of Time to File CIVIL RICO CASE STATEMENT by Jane Doe Kuvin Spencer Notice has been electronically mailed to Spencer Todd Kuvin skuvin riccilaw.com Theodore Jon Leopold tleopold riccilaw.com lcuomo riccilaw.com Guy Alan Lewis Jewis lewistein.com Michael Ross Tein tein lewistein.com kmeyers lewistein.com mcapote lewistein.com Notice has not been delivered electronically to those listed below and will be provided by other means For further assista11.ce please contact our Help Desk at The following document are associated with this transaction Document description:Main Document 267Original fllename:n/a Electronic document Stamp STAMP dcecfStamp _ID Date FileNumber 5f92a5ffe52e756eabfb67el https ecf.flsd.uscourts.gov/cgi-bin ispatch pl Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUIBERN DISTRICT OF FLORIDA CASE NO 08-80804-CIV-MARRA/JOHNSON JANE DOE a/k/a JANE DOE NO Plaintiff vs JEFFREY EPSTEIN HALEY ROBSON and SARAH KELLEN Defendants PLAINTIFFS UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE CIVIL RICO CASE STATEMENT PURSUANT TO LOCAL RULE Plaintiff Jane Doe moves pursuant to Rule A of the Local Rules of the United States District Court for the Southern District of Florida for an enlargement of time to file a Civil RICO Case Statement under Local Rule I until fifteen days after the Court rules on her motion to remand which will be filed on or about August Defendants removed this action to federal court on July DE Because Plaintiff has pleaded a cause of action under section Florida Statutes she is reqired to file a Civil RICO Case Statement within thirty days of removal See S.D Fla L.R Plaintiff believes this action was improperly removed from state court and shall file a motion to remand on or about August It is Plaintiffs contention that the Court lacks subject matter jurisdiction over this case because it does not involve a federal question or parties with complete diversity of citizenship Case Document Entered on FLSD Docket Page of lfth:s action was improperly removed Plaintiff should not be required to expend the time and expense necessary to create and file a Civil Rico Cast Statement which would not be required in Florida state court WHEREFORE Plaintiff respectfully request the Court grant her motion for an enlargement of time to file a Civil RICO Case Statement until fifteen days after the Comt rules on her motion to remand CERTIFICATE OF COMPLIANCE WITH LOCAL RULE On August undersigned counsel conferred with counsel for the Defendants in a good faith effort to resolve the issues raised in this motion and Defendants counsel advised that Defendants do not oppose this motion sf Spencer Kwin Spencer Kuvin Florida Bar Number Certificate of Services I hereby certify that on August I electronically filed the foregoing docll!Ilent with the Clerk of the Court using CM/ECF I also certify that the foregoing document is being served this day on all counsel of record or prose parties identified on the attached Service List in the manner specified either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing sf Spencer Kuvin Spencer Kuvin Florida Bar Number Attorney E-Mail Address RJCCI LEOPOLD P.A PGA Blvd Suite200 Palm Beach Gardens FL Telephone Facsimile Counsel for Plaintiff Jane Doe 2of4 Case Document Entered on FLSD Docket Page of SERVICE LIST Doe Epstein et al CASE NO 08-80804-Civ-MARRA/JOHNSON United States District Court Southern District of Florida Robert Critton Esq Burman Critton Luttier Coleman LLP Flagler Drive Suite West Palm Beach PL Phone Fax Counsel for Jeffrey Epstein Served via U.S Mail postage prepaid Guy Alan Lewis Esq Email lewis lewistein.com LewisTein Grand Avenue Suite Coconut Grove FL Phone IO I Pax Counsel for Jeffrey Epstein Served via CM/ECF Bruce Reinhart Esq Bruce Reinhart P.A Australian Avenue South Suite West Palm Beach FL Phone Fax Counsel for Sarah Kellen Served via U.S Mail postage prepaid Michael Tein Esq Email tein lewistein.com LewisTein Grand Avenue Suite Coconut Grove FL Phone IOI Fax Counsel for Jeffrey Epstein Served via CM/ECF of4 Case Document Entered on FLSD Docket Page of Douglas McIntosh Esq Jason A McGrath Esq McIntosh Sawran Peltz Cartaya P.A Centurion Tower Suite I I I I I Forum Place West Palm Beach FL I Phone Fax I Counsel for Haley Robson Served via U.S Mail postage prepaid 4of4
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