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gainst 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 entered where a
n be used at trial. Id; Pillsbury Company 11 Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03/25/2009 Page 12 of 15 Page 12 v. Conboy. 495 U.S. 248, 103 S.Ct. 608 (1983). See also, Hubbell, supra, as to what is encompassed by the phrase "in any criminal case" contained in the Fift
te 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 created a test for these circumstances. stating that where there exists a
convict the witness of a crime or could aid in the development of other incriminating evidence that can be used at trial. Id; Pillsbury Company v. Conboy, 495 U.S. 248, 103 S.Ct. 608 (1983). Certainly, if the USAO decides to prosecute EPSTEIN for an alleged violation of the NPA, it would undoubtedly
gainst 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 (11th Cir. 1994). In Ventura, a stay was entered where a De
1321(2f M24 C.M.A. v. Epstein, et al. Page 12 the development of other incriminating evidence that can be used at trial. Id; Pillsbury Company v. Conboy, 495 U.S. 248, 103 S.Ct. 608 (1983). See also, Hubbell, supra, as to what is encompassed by the phrase "in any criminal case" contained in the Fifth
te 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 created a test for these circumstances. stating that where there exists a
convict the witness of a crime or could aid in the development of other incriminating evidence that can be used at trial. Id; Pillsbury Company v. Conboy, 495 U.S. 248, 103 S.Ct. 608 (1983). Certainly, if the USAO decides to prosecute EPSTEIN for an alleged violation of the NPA, it would undoubtedly
Entities connected to both Brosky and Conboy

Jeffrey Epstein
PERSONJack Goldberger
PERSON
United States
LOCATIONFisher
PERSONJane Doe
PERSONVentura
LOCATION
Adam D. Horowitz
PERSON
McCormick
PERSONPillsbury Company
ORGANIZATIONHubbell
PERSONBraswell
PERSON
Hogan
PERSONthe Southern District
LOCATIONFox Grove
LOCATION
Kenneth Marra
PERSON
Edwin
PERSONYarborough
PERSON
Jay Lefkowitz
PERSONMichael J. Pike
PERSON
David Rodgers
PERSON