Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 25 Entered on FLSD Docket 0718/2008 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MEMORANDUM OF LAW IN RESPONSE TO DEFENDANT'S MOTION FOR STAY Plaintiff, Jane Doe No. 2, by and through her undersigned counsel, submits this Memorandum of Law in Response to Motion for Stay, as follows: INTRODUCTION Defendant Jeffrey Epstein's Motion to Stay this action is based on the incorrect premise that there are criminal actions pending against him in Palm Beach Circuit Court, State of Florida. Jeffrey Epstein, Case No. 2006 CF 09454 AXXMB (Fifteenth Judicial Circuit, Palm Beach County), and in the Southern District of Florida, In re Grand Jury, No. FGJ 07-103 (WPB) (S.D. Fla.). The Motion to Stay as to the state court criminal action was rendered moot on June 30, 2008 when Jeffrey Epstein entered a plea of guilty to