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659 F.2d 660, 668 (5th Cir. 1981) (add’l citations omitted). Examples of “special circumstances” provided by the Supreme Court in [United States v. Kordel] are: (1) if the Government brought the civil action solely to obtain evidence for its criminal prosecution, (2) if the Government failed to advise t
. -12- Unlike Wright and Incendy, Epstein also has not been criminally indicted. In some districts, this alone is virtually dispositive. See, e.g., Sterling Nat’l Bank v. A-1 Hotels Internat’l, 175 F. Supp. 2d 573, 576-77 (S.D.N.Y. 2001) (“district courts in this Circuit ‘generally grant the extraordinary remedy of
rovided by the Supreme Court in [United States v. Kordel] are: (1) if the Government brought the civil act
this alone is virtually dispositive. See, e.g., Sterling Nat’l Bank v. A-1 Hotels Internat’l, 175 F. Supp. 2d 573, 57
her unfair injury; or (4) any other special circumstances indicating unconstitutionality or even impropriety. Incendy at 956 (citing United States. Kordel, 397 U.S. 1, 11 (1970)). See also Securities and Exchange Comm' n I Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o `special circumstanc
of 17 Unlike Wright and Incendy, Epstein also has not been criminally indicted. In some districts, this alone is virtually dispositive. See, e.g., Sterling Nat'l Bank'. A-1 Hotels haernat'l, 175 F. Supp. 2d 573, 576-77 (S.D.N.Y. 2001) ("district courts in this Circuit `generally grant the extraordinary remedy of a
her unfair injury; or (4) any other special circumstances indicating unconstitutionality or even impropriety. Incendy at 956 (citing United States. Kordel, 397 U.S. 1, 11 (1970)). See also Securities and Exchange Con:nen, Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o `special circumstances'
22771 Unlike Wright and Incendy, Epstein also has not been criminally indicted. In some districts, this alone is virtually dispositive. See, e.g., Sterling Nat'l Bank'. A-1 Hotels Internatt 175 F. Supp. 2d 573, 576-77 (S.D.N.Y. 2001) ("district courts in this Circuit `generally grant the extraordinary remedy of a
evidence for its criminal prosecution," or (2) "fail to advise the defendant in its civil proceeding that it contemplates his criminal prosecution." Kordel, 397 U.S. at 11-12 (emphasis added). In Kordel, a corporate executive was convicted of violating the Food, Drug, and Cosmetic Act partly on the basi
nt undermining the rights of a defendant in a criminal investigation "by conducting a de facto criminal investigation using nominally civil means." Sterling Nat'l Bank v. A-1 Hotels Int'l, 175 F. Supp. 2d 573, 579 (S.D.N.Y. 2001). EFTA00076651 The 'Rhodes' Case In the Rhodes case, the defendant Jason Rhodes, a h
evidence for its criminal prosecution," or (2) "fail to advise the defendant in its civil proceeding that it contemplates his criminal prosecution." Kordel, 397 U.S. at 11-12 (emphasis added). In Kordel, a corporate executive was convicted of violating the Food, Drug, and Cosmetic Act partly on the ba
nt undermining the rights of a defendant in a criminal investigation "by conducting a de facto criminal investigation using nominally civil means." Sterling Nat'l Bank v. A-1 Hotels Intl, 175 F. Supp. 2d 573, 579 (S.D.N.Y. 2001). The `Rhodes' Case In the Rhodes case, the defendant Jason Rhodes, a hedge fund manage
Entities connected to both Kordel and Sterling National Bank

Jeffrey Epstein
PERSON
United States
LOCATIONJane Doe
PERSON
Alexander Acosta
PERSONFox Grove
LOCATIONWright
PERSONCooke
PERSON
Kenneth Marra
PERSONThe First Circuit
ORGANIZATIONMicrofinancial
PERSONShell Oil Co.
ORGANIZATIONPervis
PERSONAlachua County
LOCATIONLauer
PERSONMicrofinancial, Inc.
ORGANIZATION
Scarlett Johansson
PERSONS.D. Fl
LOCATIONJane Doe Litigation
PERSONJANE DOE NO.
PERSOND.D.C. Mar. 31, 2007
ORGANIZATION