Case 9:09-cv-80802-KAM

Document 9

Entered on FLSD Docket 07/30/2009

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 09-CV-80802-MARRA/JOHNSON

JANE DOE NO. 8,
 Plaintiff,
 vs.
JEFFREY EPSTEIN,
 Defendant.
/

PLAINTIFF’S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO DEFENDANT’S MOTION TO DISMISS

Plaintiff, Jane Doe No. 8, by and through undersigned counsel, files this Unopposed Motion for Enlargement of Time to Respond to Defendant’s Motion to Dismiss, and states as follows:

1. Defendant Jeffrey Epstein filed a Motion to Dismiss in this action on July 14, 2009. Pursuant to S.D.Fla.R. 7.1, Plaintiff has until July 31, 2009 to file her response to the Motion to Dismiss.

2. Due to obligations of Plaintiff’s counsel in other cases and matters, including in related cases against Defendant Jeffrey Epstein, Plaintiff requests an enlargement of time until August 12, 2009 to file her Memorandum in response to the Motion to Dismiss.

3. Plaintiff’s counsel has conferred with Defendant’s counsel regarding this request for enlargement of time, and has been advised that Defendant does not oppose the Motion.

WHEREFORE, Plaintiff Jane Doe No. 8 respectfully requests an enlargement of time until August 12, 2009 to file her Memorandum in response to Defendant’s Motion to Dismiss.

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Case 9:09-cv-80802-KAM

Document 9

Entered on FLSD Docket 07/30/2009

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Dated: July 30, 2009. Respectfully submitted,

By: s/ Stuart S. Mermelstein
Stuart S. Mermelstein (FL Bar No. 947245)
ssm@sexabuseattorney.com
Adam D. Horowitz (FL Bar No. 376980)
ahorowitz@sexabuseattorney.com
MERMELSTEIN & HOROWITZ, P.A.
Attorneys for Plaintiff Jane Doe 8
18205 Biscayne Blvd., Suite 2218
Miami, Florida 33160
Tel: 305-931-2200
Fax: 305-931-0877

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Case 9:09-cv-80802-KAM

Document 9

Entered on FLSD Docket 07/30/2009

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CERTIFICATE OF SERVICE

I hereby certify that on July 30, 2009, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day to all parties on the attached Servi ce 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 parties who are not authorized to receive electronically Notices of Electronic Filing.

/s/ Stuart S. Mermelstein

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Case 9:09-cv-80802-KAM

Document 9

Entered on FLSD Docket 07/30/2009

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SERVICE LIST
DOE vs. JEFFREY EPSTEIN
CASE NO.: 09-CV-80802-MARRA/JOHNSON
United States District Court, Southern District of Florida

Jack Alan Goldberger, Esq.
jgoldberger@agwpa.com

Robert D. Critton, Esq.
rcritton@bclclaw.com

/s/ Stuart S. Mermelstein

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court-records/Doe No. 8 v. Epstein, No. 909-cv-80802 (S.D. Fla. 2009)/009.pdf
{"year":"2009","court":"S.D. Fla","people":["jeffrey epstein","stuart s. mermelstein","adam d. horowitz","jack goldberger","robert d. critton"]}