Epstein Secrets

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] MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd., Suite 2218 Miami,

- 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

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] MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd., Suite 2218 Miami,

- 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

EREBY CERTIFY that a true 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]

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

denied in their entirety. Dated: April 23, 2009 Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) Adam D. Horowitz (FL Bar No. 376980) MERMELSTEIN & 11OROWITZ, P.A. Attorneys for Plaintiffs - 7 - EFTA00201252 Case 9:08-cv-80811-KAM Document 64-3 Entered on

lf- 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 crim

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] MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd., Suite 2218 Miami,

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

EREBY CERTIFY that a true 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

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

EREBY CERTIFY that a true 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. Jack Alan Goldberger Stuart S. Mermelstein Es• Atterbu Goldberger & Weiss P.A. Counsel for Plaintiff Jane Doe #2 ounse or 'e en ant Je rey

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