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- 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
emaining silent for fear of self incrimination in a parallel criminal proceeding does not rise to the level of an unconstitutional infringement.”2 Shell Oil, 866 F.Supp. at 540. Accordingly, the Defendant’s right to silence is not a basis to stay the civil case pending resolution of a criminal action.
- 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
emaining silent for fear of self incrimination in a parallel criminal proceeding does not rise to the level of an unconstitutional infringement.”2 Shell Oil, 866 F.Supp. at 540. Accordingly, the Defendant’s right to silence is not a basis to stay the civil case pending resolution of a criminal action.
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
e Doe. 'In this regard, The Defendant's silence by invoking the Fifth Amendment does not prohibit adverse inferences against him in the civil case. Shell Oil. 866 F.Supp. at 40. - 3 - EFTA00201248 Case 9:08-cv-80811-KAM Document 64-3 Entered on FLSD Docket 04/24/2009 Page 4 of 13 Case 9:08-cv-80381
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
e Doe. 'In this regard, The Defendant's silence by invoking the Fifth Amendment does not prohibit adverse inferences against him in the civil case. Shell Oil, 866 F.Supp. at 40. - 3 - EFTA00222588 Case 9:08-cv-80119-KAM Document 82 Entered on FLSD Docket 04/23/2009 Page 4 of 9 defendant's right aga
Entities connected to both Ventura and Shell Oil

Jeffrey Epstein
PERSONJane Doe
PERSON
United States
LOCATIONJack Goldberger
PERSON
Scarlett Johansson
PERSON
Kenneth Marra
PERSONFox Grove
LOCATION
Alan Dershowitz
PERSON
Adam D. Horowitz
PERSON
Prince Andrew
PERSONBrosky
PERSONRobert D. Critton
PERSONthe Eleventh Circuit
ORGANIZATIONRehtorik
PERSONMiami-Dade County Police Department
ORGANIZATION
George W. Bush
PERSON
Bradley Edwards
PERSONLeon Black
PERSON
James Baker
PERSONStuart S. Mermelstein
PERSON