Epstein Secrets

t Defendant’s Motions to Stay and/or Continue Action be denied in their entirety. Dated: April 23, 2009 Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERM

- incrimination or losing the civil case in [summary proceedings]”). The cases relied upon by Defendant are consistent with these authorities. In Ventura v. Brosky, 2006 WL 3392207 (S.D. Fla. 2006), the Court stated the rule that a stay is warranted to avoid a situation “where a defendant in both cri

e his privilege against self-incrimination or to lose the civil case in summary or default judgment proceedings.” Id. at *1. Moreover, the stay in Ventura was granted on motion of the defendant Miami-Dade County Police Department because it would be prejudiced by its codefendant, a former police offic

t Defendant’s Motions to Stay and/or Continue Action be denied in their entirety. Dated: April 23, 2009 Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERM

- incrimination or losing the civil case in [summary proceedings]”). The cases relied upon by Defendant are consistent with these authorities. In Ventura v. Brosky, 2006 WL 3392207 (S.D. Fla. 2006), the Court stated the rule that a stay is warranted to avoid a situation “where a defendant in both cri

e his privilege against self-incrimination or to lose the civil case in summary or default judgment proceedings.” Id. at *1. Moreover, the stay in Ventura was granted on motion of the defendant Miami-Dade County Police Department because it would be prejudiced by its codefendant, a former police offic

e copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 25th day of March, 2009. Adam D. Horowitz, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 [email protected] [email protected] Counse

liability against EPSTEIN. This is inherently unfair and precisely the special circumstances where "in the interests of justice" a stay is required. Ventura v. Brosky, 2006 WL 3392207 (S.D. Fla. 2006), citing. United States v. Lot 5, Fox Grove, 23 F.3d 359 (11 th Cir. 1994). In Ventura, a stay was enter

stay is required. Ventura v. Brosky, 2006 WL 3392207 (S.D. Fla. 2006), citing. United States v. Lot 5, Fox Grove, 23 F.3d 359 (11 th Cir. 1994). In Ventura, a stay was entered where a Defendant was confronted with issue of waiving his 5th Amendment Privilege or to loose a civil case by way of motion for

e copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 25th day of March, 2009. Adam D. Horowitz, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ahorowitzehermanlaw.com Iriveraahermanlaw.com Counse

liability against EPSTEIN. This is inherently unfair and precisely the special circumstances where "in the interests of justice" a stay is required. Ventura v. Broskv 2006 WL 3392207 (S.D. Fla. 2006), glikg, r United States v. Lot 5. Fox Grove 23 F.3d 359 (11th Cir. 1994). In Ventura, a stay was entered