Epstein Secrets

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

tances 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 where a Defendant was confronted with issue of waiving his 5th Amendment Privilege or t

nge his right against self-incrimination). The court found it appropriate to grant the request for stay. (Emphasis Added). Citing to U.S. v. Lot 5. Fox Grove, supra, the Southern District Court, Florida, in Ventura v. Brosky, 2006 WL 3392207 (S.D. Fla. 2006), stated — The Eleventh Circuit has also create

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

tances 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 where a Defendant was confronted with issue of waiving his 5th Amendment Privilege or t

nge his right against self-incrimination). The court found it appropriate to grant the request for stay. (Emphasis Added). Citing to U.S. v. Lot 5. Fox Grove, supra, the Southern District Court, Florida, in Ventura v. Brosky, 2006 WL 3392207 (S.D. Fla. 2006), stated — The Eleventh Circuit has also create

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]

stances 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 entered where a Defendant was confronted with issue of waiving his 5th Amendment Privilege o

RANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, UNITED STATES DISTRICT JUDGE APPEARANCES: 13 FOR THE PLAINTIFFS: 14 15 16 ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 18205 Biscayne Boulevard Miami, FL 33160 305.931.2200 For Jane Doe BRADLEY J. EDWARDS, ESQ. 17 Rothstein Rosenfe

As this Court has previously explained: The law regardii stays of civil actions is well-settled in the Eleventh Circuit. In United States Lot 5, Fox Grove, Alachua County, Fla, 23 F.3d 359, 363- 65 (11th Cir. 1994) ("Lot 5"), the Court articulated the following principles of law with respect to a stay

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

is warranted only when the defendant demonstrates that " `special circumstances' so require in the 'interests of justice.' "United States v. Lot 5, Fox Grove, 23 F.3d 359, 365 (11th Cir. 1994). In the Eleventh Circuit, the "special circumstances" which may support a stay are limited. The fact that the De

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,

is warranted only when the defendant demonstrates that " `special circumstances' so require in the `interests of justice.' " United States'. Lot 5. Fox Grove, 23 F.3d 359, 365 (11th Cir. 1994). In the Eleventh Circuit, the "special circumstances" which may support a stay are limited. The fact that the De