Epstein Secrets

r inequity in being required to go forward, if there is even a fair possibility that the stay for which he prays will work damage to someone else." Landis v. North American Co., 299 U.S. 248, 255 (1936). A civil defendant who asserts the Fifth Amendment privilege "may have to accept certain bad conseq

v. JEFFREY EPSTEIN, Defendant. MOTION TO STRIKE REFERENCES TO NON-PROSECUTION AGREEMENT OR, IN THE ALTERNATIVE, TO LIFT PROTECTIVE ORDER BARRING JANE DOE'S ATTORNEY'S FROM REVEALING PROVISIONS IN THE AGREEMENT Plaintiff, Jane Doe, hereby moves this Court to strike all references to a "non- prosecution

ent in parallel litigation under the Crime Victim's Rights Act. Doe v. United States, No. 9:08-CV-80736-KAM. The agreement, however, was provided to Jane Doe's counsel subject to a protective order. That protective order precludes Jane Doe's 3 EFTA00722661 Case 9:08-cv-80893-KAM Document 32 Entered on

r inequity in being required to go forward, if there is even a fair possibility that the stay for which he prays will work damage to someone else." Landis v. North American Co., 299 U.S.. 248, 255 (1936). A civil defendant who asserts the Fifth Amendment privilege "may have to accept certain bad conse

ons asked and the documents requested . . . ." Id. Here Epstein has made sweeping generalizations about the applicability of the Fifth Amendment to Jane Doe's specific discovery requests. But in his motion, he has merely cobbled together a few grandiose quotations about general Fifth Atnendment principles

the record." Dade Cnty. Sch. Bd. v. Radio Station WQBA, 731 So. 2d 638, 644 (Fla.1999). "This rule applies in cases of summary judgments as well." Landis v. Allstate Ins. Co., 546 So. 2d 1051, 1053 (Fla. 1989); see also Rivernider, supra (holding that although trial judge erred in granting summary ju

ge female plaintiff. To augment his concocted story, Rothstein invited D3 to his office to view the thirteen banker's boxes of actual case files in Jane Doe in order to demonstrate that the claims against Epstein were legitimate and that the evidence against Epstein was real. In particular, Rothstein cla

r inequity in being required to go forward, if there is even a fair possibility that the stay for which he prays will work damage to someone else." Landis'. North American Co., 299 U.S. 248, 255 (1936). A civil defendant who asserts the Fifth Amendment privilege "may have to accept certain bad consequ

ions asked and the documents requested .. . ." Id. Here Epstein has made sweeping generalizations about the applicability of the Fifth Amendment to Jane Doe's specific discovery requests. But in his motion, he has merely cobbled together a few grandiose quotations about general Fifth Amendment principles

is letter on the Docket September 4, 2020 of Case No. 20cv00484. Dated: 09/09/2020 SO ORDERED DEBRA FREEMAN United States Magistrate Judge Re: Jane Doe v. Darren It Indyke, et aL, 20 Civ. 484 (DCF) (JGK) Dear Judge Freeman: The Government respectfully submits this letter to request that the Court:

een asserted. This Court has the inherent power to stay civil cases in the interests of justice pending the completion of criminal prosecution. See Landis v. North Am. Co., 299 U.S. 248, 255 (1936); Kashi v. Gratsos, 790 F.2d 1050, 1057 (2d Cir. 1986). Courts routinely grant applications to stay civil