Epstein Secrets

ocket 05'13/2009 Page 3 of 7 Page 3 significant fact that a stay may be issued in light of an ongoing investigation. It is clear from the NPA and Jack Goldberger's Affidavit (attached to the Motion to Stay) ". . .that the criminal matters against Epstein remain ongoing until the NPA expires by its terms in late

unsel of record identifiecl,gp the following Service List in the , 2009 manner specified by CM/ECF on this 43 day of Richard Horace Willits, Esq. Jack Alan Goldberger, Esq. Atterbury Goldberger & Weis ratings] fnr Plaintiff r4.A. Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shi le

other civil actions." See Motion to Stay and Jack Goldberger Affidavit attached thereto as Exhibit "B". Thus,

rivilege and risk loosing this case by virtue of not being able to present evidence, or waive that right and risk a potential criminal prosecution. Eastwood v. U.S., 2008 WL 5412857, *1 (ED. Tenn.))("Vvien a party to a civil action is subject to criminal proceedings and/or investigations that relate to s

al discovery beyond the limits of Fed.R.Crim.Pro. 16(b). Epstein satisfies the requirements to stay this action as set forth in St. Paul Fire and in Eastwood, including the similarity of issues underlying the civil litigation and ongoing criminal investigation. As such, a stay should be entered in the ins

to Stay, but her response ignores the significant fact that a stay may be issued in light of an ongoing investigation. It is clear from the NPA and Jack Goldberger's Affidavit ". . .that the criminal matters against Epstein remain ongoing until the NPA expires by its terms in late 2010. . ., and the threat of cri

ards & Atterbury Goldberger & Weiss, P.A. Associates, LLC 1 Counsel for Plaintiff Paul G. Cassell, Esq. Pro Hac Vice Co-counsel for Plaintiff Jack Alan Goldberger, Esq. Co-Counsel for Defendant Jeffrey Epstein 6 EFTA00234813 Case 9:08-cv-80893-KAM Document 54 Entered on FLSD Docket 05'12'2009 Page 7 of

other civil actions." See Motion to Stay and Jack Goldberger Affidavit attached thereto as Exhibit "B" (DE24,

rivilege and risk loosing this case by virtue of not being able to present evidence, or waive that right and risk a potential criminal prosecution. Eastwood v. U.S. 2008 WL 5412857, *1 (E.D. Tenn.)X"When a party to a civil action is subject to criminal proceedings and/or investigations that relate to suc

al discovery beyond the limits of Fed.R.Crim.Pro. 16(b). Epstein satisfies the requirements to stay this action as set forth in St. Paul Fire and in Eastwood, including the similarity of issues underlying the civil litigation and ongoing criminal investigation. As such, a stay should be entered in the in

eattorney.com Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australi

ll an ongoing criminal investigation." See Jack Goldberger's Affidavit, ,J7 (attached to the Motion to Stay)

right and risk a potential criminal prosecution. Eastwood v. U.S., 2008 WL 5412857, *1 (E.D. Tenn.))("When

this action as set forth in St. Paul Fire and in Eastwood, including the similarity of issues underlying t

et 06/05/2009 Page 4 of 4 COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 25

nhart Shipley, P.A. 2139 Palm Beach Lakes Boulevard st Palm Beach, FL 33409 Fax: jsxesearcvlaw.com jphesearcylaw.com Co-Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 net Counsel for Defendants Jeffr

rivilege and risk loosing this case by virtue of not being able to present evidence, or waive that right and risk a potential criminal prosecution. Eastwood v, U.S., 2008 WL 5412857, *1 (E.D. Tenn.))("When a party to a civil action is subject to criminal proceedings and/or investigations that relate to s

al discovery beyond the limits of Fed.R.Crim.Pro. 16(b). Epstein satisfies the requirements to stay this action as set forth in St. Paul Fire and in Eastwood, including the similarity of issues underlying the civil litigation and ongoing criminal investigation. As such, a stay should be entered in the in

se of sheer embarrass- ment," he said. "But she very much looked 14. Any prudent man would have had second thoughts about that." Defense attorney Jack Goldberger maintains that not only did Epstein pass a polygraph test showing he did not know the girls were minors, but their stories weren't credible. The

the Palm Beach County Jail early July 23 and released hours later. Epstein's legal team 'doesn't dispute that lie had girls over for massages," Goldberger said. But he said their claims that they had sex- ual encounters with him lack credi- bility. "They arc incapable of being believed' he said, They

lad of Ricky Bobby raced ahead of the competition to remain the box office champ for a second weekend with $23 mil- WATT SIYILSOThe Acsocerec n.. Eastwood honored BEVERLY HILLS - Actor Clint Eastwood ac- cepts the Founders Award from actor Mor- gan Freeman at the Golden Boot Awards. Established in 198