Case 9:08-cv-80119-KAM Document 25 Entered on FLSD Docket 07/18/2008 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-801 l9-MARRA 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 v. 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 violations of Florida Statute §796.07 (felony solicitation of prostitution) and §796.03 (procurement of minors to engage in prostitution) in the state criminal action. (See Defendant's Notice Concerning Motion to Stay dated July 1, 2008). Jeffrey Epstein, now an admitted sex offender, was sentenced to a term of imprisonment followed by community control and sex offender registration. As to the federal prosecution, Defendant's mistitled "Notice of Continued Pendency of HERMAN S MERMELSTEIN, P. A. www.hermanlaw.com -1- EFTA02743655