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it is clear that Epstein has met the elements of St. Paul Fire necessary for this Court to enter a stay: 1. E
[email protected] Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger &
dicial Circuit Court, Palm Beach County). When an ongoing criminal investigation exists, courts have granted motions to stay civil proceedings. In St. Paul Fire and Marine Insurance Company v. U.S., 24 CI.Ct 513 (1991), the court held that staying a civil action for 6-9 months was reasonable in light of a pe
rights and participate in civil discovery in order to defend this civil action. Accordingly, Epstein adopts his arguments set forth in the Reply to Jane Doe's Response In Opposition filed in 08-CIV-80893 (DE 54) and incorporates same herein by reference. EFTA00201284 Case 9:08-cv-80811-KAM Document 81
dicial Circuit Court, Palm Beach County). When an ongoing criminal investigation exists, courts have granted motions to stay civil proceedings. In St. Paul Fire and Marine Insurance Company v. U.S., 24 CI.Ct 513 (1991), the court held that staying a civil action for 6-9 months was reasonable in light of a pe
Case 9:08-cv-80893-KAM Document 54 Entered on FLSD Docket 05/12/2009 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV- 80893 — MARRA/JOHNSON Defendant, Jeffrey Epstein's Reply to Plaintiff's Response
mpanion case are closed). Here, Epstein is not required to "contemplate an in haec verba iron-clad comparison of separate issues by direct proof." St. Paul Fire and Marine Insurance Company v. U.S., 24 CI.Ct at 516. Instead, a reading of the complaint, the NPA (in camera), the pleadings in support of and ag
to Compel Response to 1st RTP and 1st Interrogs filed by . (Hill, Jack) (Entered: 04/20/2009) 04 /22%2009 63 r 313:: MOTION for Leave to File Jane Doe's No. 101's Motion For Leave to File Brief as Amicus Curiae in Support of Plaintiffs Response in Opposition to Defendant Jeffrey Epstein's Motion to
Entities connected to both St. Paul Fire and Jane Doe

Jeffrey Epstein
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
Alan Dershowitz
PERSONRobert D. Critton
PERSONMichael J. Pike
PERSONJack Scarola
PERSONRichard Horace Willits
PERSONJack Patrick Hill
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
Lake Worth
LOCATIONFLSD Docket
ORGANIZATION
Searcy Denney
PERSONBURMAN
PERSON
Eastwood
PERSONthe United States Attorneys' Office
LOCATIONNational Association of Letter Carriers
ORGANIZATIONMarine Insurance Company
ORGANIZATIONM.D. G.a.
PERSON