Epstein Secrets

f, C.M.A., by and through her undersigned attorneys, respectfully moves this Court for an extension of time in which file to a response to Defendant Jeffrey Epstein's Motion to Stay And Or Continue Action For Time Certain Based. On Parallel Civil And Criminal Proceedings With Incorporated Memorandum of Law. Local

Plaintiff, Jane Doe, hereby moves this Court to strike all references to a "non- prosecution agreement" contained in defendant, Jeffrey Epstein's ("Epstein") Motion to Stay these proceedings. Under the Best Evidence Rule, Fed. R. Evid. 1002, and the principles underlying the rule, Epstein is required t

eement. In his motion to stay these proceedings, defendant Epstein has argued that he must invoke his Fifth Amendme

80893 - MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. NOTICE OF CHANGE OF ADDRESS

ed on FLSD Docket 04/09/2009 Page 2 of 14 against any stay -- particularly since it involves allegations of serious sexual abuse against a minor. I. EPSTEIN IS NOT FACING PENDING CRIMINAL CHARGES AGAINST HIM RELATED TO JANE DOE. Epstein's initial burden is to show some sort of risk of criminal prosecuti

ion that civil and criminal cases proceed together." United States ex reL Gonzalez v. Fresenius Medical Care North America, 571 F.Supp.2d 758, 761 (W.D. Tex. 2008) (internal quotation omitted). Epstein has shown no good reason for deviating from normal practice here. One last reason weighing against a

a stay only after that defendant has been indicted." United States ex rel. Gonzalez v. Fresenius Medical Cam North America, 571 F.Supp.2d 758, 763 (W.D. Tex. 2008) (internal quotation omitted) (emphasis added). See, e.g., Ventura v. Brosky, 2006 WL 3392207 (S.D. Fla. 2006) (granting a stay of civil proc

ed on FLSD Docket 04/09/2009. Page 2 of 14 against any stay — particularly since it involves allegations of serious sexual abuse against a minor. I. EPSTEIN IS NOT FACING PENDING CRIMINAL CHARGES AGAINST HIM RELATED TO JANE DOE. Epstein's initial burden is to show some sort of risk of criminal prosecuti

9/2009! Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No.: 08-CIV-80893 - MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO STAY COMPLAINT . Plaintiff, Jane Doe, hereby responds to the motion by def

RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO STAY COMPLAINT . Plaintiff, Jane Doe, hereby responds to the motion by defendant Jeffrey Epstein ("Epstein') to stay this action until late 2010. The motion for a stay should be denied. Defendant has not carried his heavy burden of justifying a stay in th

80893 - MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant PLAINTIFF'S RESPONSE IN OPPO

on that civil and criminal cases proceed together." United States ex rel. Gonzalez v. Fresenlus Medical Care North America, 571 F.Supp.2d 758, 761 (W.D. Tex. 2008) (internal quotation omitted). Epstein has shown no good reason for deviating from normal practice here. One last reason weighing against a

stay only after that defendant has been indicted." United States ex rel. Gonzalez v. Fresenius Medical Care North America, 571 F.Supp.2d 758, 763 (W.D. Tex. 2008) (internal quotation omitted) (emphasis added). See, e.g., Ventura v. Brosky, 2006 WL 3392207 (S.D. Fla. 2006) (granting a stay of civil proc

09/2009 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No.: 08-CIV-80893 - MARRA/JOHNSON JANE DOE, 1. Plaintiff, JEFFREY EPSTEIN, Defendant. / PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO STAY COMPLAINT Plaintiff, Jane Doe, hereby responds to the motion by d

S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO STAY COMPLAINT Plaintiff, Jane Doe, hereby responds to the motion by defendant Jeffrey Epstein ("Epstein") to stay this action until late 2010. The motion for a stay should be denied. Defendant has not carried his heavy burden of justifying a stay in th

80893 - MARRA/JOHNSON JANE DOE, 1. Plaintiff, JEFFREY EPSTEIN, Defendant. / PLAINTIFF'S RESPONSE IN

ed on FLSD Docket 04/09/2009 Page 2 of 14 against any stay -- particularly since it involves allegations of serious sexual abuse against a minor. I. EPSTEIN IS NOT FACING PENDING CRIMINAL CHARGES AGAINST HIM RELATED TO JANE DOE. Epstein's initial burden is to show some sort of risk of criminal prosecuti

on that civil and criminal cases proceed together." United States ex rel. Gonzalez I. Fresenius Medical Care North America, 571 F.Supp.2d 758, 761 (W.D. Tex. 2008) (internal quotation omitted). Epstein has shown no good reason for deviating from normal practice here. One last reason weighing against a

stay only after that defendant has been indicted." United States ex rel. Gonzalez I. Fresenius Medical Care North America, 571 F.Supp.2d 758, 763 (W.D. Tex. 2008) (internal quotation omitted) (emphasis added). See, e.g., Ventura Brosky, 2006 WL 3392207 (S.D. Fla. 2006) (granting a stay of civil procee