EFTA00201232.pdf

Case 9:08-cv-80811-KAM Document 64 Entered on FLSD Docket 04/24/2009 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON C.M.A., Plaintiff, VS. EPSTEIN and Defendants. PLAINTIFF'S MEMORANDUM IN OPPOSITION TO DEFENDANT, JEFFREY EPSTEIN'S MOTION TO STAY AND OR CONTINUE ACTION FOR TIME CERTAIN BASED ON PARALLEL CIVIL AND CRIMINAL PROCEEDINGS WITH INCORPORATED MEMORANDUM OF LAW Plaintiff, C.M.A., by and through undersigned counsel, files this Memorandum in Opposition to Defendant, Jeffrey Epstein's Motion to Stay And Or Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated Memorandum of Law (D.E. 51), and states: Defendant, Jeffrey Epstein, seeks to have this action stayed until late 2010. Epstein's Motion to Stay filed in the instant case is identical to the ones he filed in Jane Doe v. Epstein, Case. No. 08-CV-90893, Jane Doe No. 2 v. Epstein Case No. 08-CV- 80119, Jane Doe No. 3 v. Epstein, Case No. 08-CV-80232, Jane Doe No. 4 v. Epstein, Case No. 08-CV-80380, Jane Doe No. 5 v. Epstein, Case No. 08-CV-80381, Jane Doe No. 6 v. Epstein, Case No. 08-CV-90994, and Jane Doe No. 7 v. Epstein Case No. 08- 80993, which are all currently pending before this Court. Counsel for Jane Doe No.1 and Jane Does No. 2-7 have both filed Memorandums in Opposition to Epstein's EFTA00201232 Case 9:08-cv-80811-KAM Document 64 Entered on FLSD Docket 04/24/2009 Page 2 of 4 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Memorandum in Opposition to Defendant Jeffrey Epstein's Motion to Stay And Or Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated Memorandum of Law Page 2 of 4 Motions for Stay in their respective cases. Rather than unnecessarily recite and duplicate their well-reasoned arguments in opposition to Epstein's Motions for Stay, C.M.A. incorporates by reference the arguments raised in Plaintiffs Response In Opposition to Defendant's Motion to Stay Complaint in Jane Doe No.1 v. Epstein (Case No. 08-CV-80893, D.E. 31)(Attached hereto as Exhibit "1") and Plaintiffs Memorandum in Opposition to Motion to Stay and or Continue Action in Jane Doe No. 2 v. Epstein (Case No. 08-CV-80119, D.E. 82)(Attached hereto as Exhibit "2") in her Memorandum in Opposition to Epstein's Motion For Stay as if they had fully been set forth herein. WHEREFORE, in light of the foregoing, the Plaintiff respectfully requests this Court enter an order denying Defendant, Jeffrey Epstein's Motion to Stay And Or Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated Memorandum of Law. Respectfully submitted, /.s/lack P Hill JACK SCAROLA Florida Bar No. 169440 JACK P. HILL Florida Bar No.: 0547808 Searcy Denney Scarola Barnhart & Shipley, P.A. West Palm Beach, Florida 33409 Attorneys for Plaintiff EFTA00201233 Case 9:08-cv-80811-KAM Document 64 Entered on FLSD Docket 04/24/2009 Page 3 of 4 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Memorandum in Opposition to Defendant Jeffrey Epstein's Motion to Stay And Or Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated Memorandum of Law Page 3 of 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 24, 2009, I electronically filed the foregoing document with the Clerk of Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified above via transmission of Notices of Electronic Filing generated by CM/ECF. /.s/Jack P Hill JACK SCAROLA Florida Bar No. 169440 JACK P. HILL Florida Bar No.: 0547808 Attorneys for Plaintiff EFTA00201234 Case 9:08-cv-80811-KAM Document 64 Entered on FLSD Docket 04/24/2009 Page 4 of 4 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Memorandum in Opposition to Defendant Jeffrey Epstein's Motion to Stay And Or. Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated Memorandum of Law Page 4 of 4 COUNSEL LIST Jack A. Goldberger, Esquire Atterbu Goldber er & Weiss, P.A. West Palm Beach, FL 33401 Bruce E. Reinhart, Esquire mom West Palm Beach FL 33401 Robert Critton, Esquire Burman Critton Luther & Coleman LLP West Palm Beach FL 33414 Richard H. Willits, Esquire Richard H. Willits, P.A. Lake Worth, FL 33461 EFTA00201235