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etermination that Epstein had violated the agreement could the U.S. Attorney's Office move forward to prosecute Epstein. See generally Santobello v. New York, 404 U.S. 257 (1971). Finally and most fundamentally, Epstein has it entirely within his power to avoid criminal prosecution by complying with non-
8, 255 (1936). A civil defendant who asserts the Fifth Amendment privilege "may have to accept certain bad consequences that flow from that action? Mid-America's Process Serv. v. Ellison, 767 F.2d 684, 686 (10th Cir. 1985). 10 EFTA00722675 Case 9:08-cv-80893-KAM Document 31 Entered on FLSD Docket 04/09/
etermination that Epstein had violated the agreement could the U.S. Attorney's Office move forward to prosecute Epstein. See generally Santobello v. New York, 404 U.S. 257 (1971). Finally and most fundamentally, Epstein has it entirely within his power to avoid criminal prosecution by complying with non-
8, 255 (1936). A civil defendant who asserts the Fifth Amendment privilege "may have to accept certain bad consequences that flow from that action? Mid-America's Process Serv. v. Ellison, 767 F.2d 684, 686 (10th Cir. 1985). 10 EFTA00201245
his room at a hotel in New York, New York; e. On or about January 15, 2008, a prostitute working with the Emperors Club went to a client's hotel in New York, New York; f. On or about January 18, 2008, TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the d endant, spoke over the telephone If with a new prostit
703. Moreover, the fact that Coleman waited until Mid-Ameri- ca's agent had departed the meeting at which the bids were awarded before im- pugning Mid-America's ability to perform the contract is persuasive evidence that publication was not made in good faith or in a proper manner. The district court did n
Entities connected to both New York and Mid-America's

Jeffrey Epstein
PERSON
United States
LOCATION
Bill Clinton
PERSONJane Doe
PERSON
Scarlett Johansson
PERSON
Kenneth Marra
PERSON
Wilbur Ross
PERSONJack Goldberger
PERSON
North America
LOCATION
Alberto Gonzales
PERSONSantobello
PERSONVentura
LOCATION
Ellison
PERSON
Landis
PERSONNorth American Co.
ORGANIZATIONthe Indictment and Information
ORGANIZATIONFox Grove
LOCATIONEpstein Motion to Stay
PERSONW.D. Tex
PERSONthe Best Evidence Rule
ORGANIZATION