Epstein Secrets

ard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ahorowitzehermanlaw.com Iriveraahermanlaw.com Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jaqeso

in the plea agreement with SA's See Exhibit "B" Goldberger Affidavit - EPSTEIN's criminal counsel. These al

tances where "in the interests of justice" a stay is required. Ventura v. Broskv 2006 WL 3392207 (S.D. Fla. 2006), glikg, r United States v. Lot 5. Fox Grove 23 F.3d 359 (11th Cir. 1994). In Ventura, a stay was entered where a Defendant was confronted with issue of waiving his 5th Amendment Privilege or t

nge his right against self-incrimination). The court found it appropriate 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 create

hian & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Plaintiff Service List in the manner specified by Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Counsel for Defendant Jeffrey Eps

in the plea agreement with SA's See Exhibit "B" Goldberger Affidavit - EPSTEIN's criminal counsel. These al

nge his right against self-incrimination). The court found it appropriate 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. Broskv 2006 WL 3392207 (S.D. Fla. 2006), stated — The Eleventh Circuit has also created

mstances 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 Defendant was confronted with issue of waiving his 5th Amendment Privilege or

e copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 25th day of March, 2009. Adam D. Horowitz, Esq. Jack Alan Goldberger Stuart S. Mermelstein Es• Atterbu Goldberger & Weiss P.A. Counsel for Plaintiff Jane Doe #2 ounse or 'e en ant Je rey o- Epstein 14 EFTA000673

in the plea agreement with SA's See Exhibit "B" Goldberger Affidavit - EPSTEIN's criminal counsel. These al

tances where "in the interests of justice" a stay is required. Ventura v. Broskv 2006 WL 3392207 (S.D. Fla. 2006), glikg, r United States v. Lot 5. Fox Grove 23 F.3d 359 (11th Cir. 1994). In Ventura, a stay was entered where a Defendant was confronted with issue of waiving his 5th Amendment Privilege or t

nge his right against self-incrimination). The court found it appropriate 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 create

s for Defendant Robert Deweese Critton, Jr. [email protected] Michael James Plke Burman Critton Luttier & Coleman Lead Counsel Paul G. Cassell Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. Co-Counsel Attorneys for Plaintiff Bradley James Edwards Rothstein Rosenfeldt Adler Lead Counsel Pm Hac Vic

n FLSD Docket 04/09/2009 Page 6 of 14 criminal defense attorneys, Jack Goldberger. Not surprisingly given the seriousness of such allegations, the Goldberger affidavit makes no such contention. Instead, the Goldberger affidavit is carefully worded to assert only that the U.S. Attorney's Office "might con

ay.2 A good illustration of judicial reluctance to stay cases such as this one comes from the Eleventh Circuit's decision in United States v. Lot 5, Fox Grove, Alachua County, Fla., 23 F.3d 359, 364 (11th Cir. 1994). There, the Eleventh Circuit affirmed a district court's decision not to stay a civil forf

mits the Affidavit of his criminal attorney, Jack Goldberger, who asserts that "the USAO has taken the positi

SERVICE LIST Case No.: 08-CIV-80893 - MARRA/JOHNSON Attorneys for Defendant ritton, Jr. chael James e er & Coleman 33401-2918 Lead Counsel Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. West Palm Beach FL 33401-5012 Co-Counsel Attorneys for Plaintiff Bradley JaMes Edwards ler Ft. Lauderdale, F

is warranted only when the defendant demonstrates that " `special circumstances' so require in the 'interests of justice.' "United States v. Lot 5, Fox Grove, 23 F.3d 359, 365 (11th Cir. 1994). In the Eleventh Circuit, the "special circumstances" which may support a stay are limited. The fact that the De

d to assert only that the U.S. Attorney's Office "might consider" various actions to be a breach of the non-prosecution agreement. See Affidavit of Jack A. Goldberger, Esq., at 2 (emphasis added)) This is a far cry from what Epstein's motion to stay asserts — that °the USAO has already claimed that Epstein violat

FLSD Docket 04/09/2009' Page 6 of 14 criminal defense attorneys, Jack Goldberger. Not surprisingly given the seriousness of such allegations, the Goldberger affidavit makes no such contention. Instead, the Goldberger affidavit is carefully worded to assert only that the U.S. Attorney's Office "might con

y.2 A good illustration of judicial reluctance to stay cases such as this One• comes from the Eleventh Circuit's decision in United States v. Lot 5, Fox Grove, Alachua County, Fla., 23 F.3d 359, 364 (11th Cir. 1994). There, the Eleventh Circuit effirrned a district court's decision not to stay a civil for

2 Entered on FLSD Docket 04/23/2009 Page 9 of 9 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger. Esq. [email protected] Robert D. Critton, Esq. [email protected] /s/ Stuart S. Mermelstein - 9 - EFTA00222594

mits the Affidavit of his criminal attorney, Jack Goldberger, who asserts that "the USAO has taken the positi

is warranted only when the defendant demonstrates that " `special circumstances' so require in the `interests of justice.' " United States'. Lot 5. Fox Grove, 23 F.3d 359, 365 (11th Cir. 1994). In the Eleventh Circuit, the "special circumstances" which may support a stay are limited. The fact that the De

om Burman Critton Luttier & Coleman 515 N Flagler Drive Suite 400 West Palm Beach, FL 33401-2918 561-842-2820 561-515-3148 (fax) Lead Counsel Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 835-8691 (fax) jagesq@be

n FLSD Docket 04/09/2009 Page 6 of 14 criminal defense attorneys, Jack Goldberger. Not surprisingly given the seriousness of such allegations, the Goldberger affidavit makes no such contention. Instead, the Goldberger affidavit is carefully worded to assert only that the U.S. Attorney's Office "might con

ay.2 A good illustration of judicial reluctance to stay cases such as this one comes from the Eleventh Circuit's decision in United States I. Lot 5, Fox Grove, Alachua County, Fla., 23 F.3d 359, 364 (11th Cir. 1994). There, the Eleventh Circuit affirmed a district court's decision not to stay a civil forf

DEFENDANT: ROBERT D. CRITTON, JR., ESQ. MICHAEL BURMAN, ESQ. 9 Burman Critton, etc. 515 North Flagler Street 10 West Palm Beach, FL 33401 11 JACK A. GOLDBERGER, ESQ. ' 12 Atterbury Goldberger Weiss 250 Australian Avenue South 13 West Palm Beach, FL 33401 14 ANN , ESQ. 15 Assistant U.S. Attorney 50

efense? 2 MR. CRITTON: Your Honor, Robert Critton on behalf of 3 Mr. Epstein, and my partner, Michael Burman. 4 THE COURT: Good morning. 5 MR. GOLDBERGER: Good morning, Your Honor. Jack 6 Goldberger on behalf of Mr. Epstein. 7 THE COURT: I see we have some representatives from 8 the United States A

As this Court has previously explained: The law regardii stays of civil actions is well-settled in the Eleventh Circuit. In United States Lot 5, Fox Grove, Alachua County, Fla, 23 F.3d 359, 363- 65 (11th Cir. 1994) ("Lot 5"), the Court articulated the following principles of law with respect to a stay

ed on FLSD Docket 03/25/2009 Page 14 of 15 Page 14 counsel, he is entitled to follow the recommended advice of his criminal defense attorney. See Goldberger Affidavit attached hereto. EPSTEIN's invocation of his constitutional protections of the Fifth, Sixth and Fourteenth Amendments must be upheld for

stances 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 Defendant was confronted with issue of waiving his 5th Amendment Privilege o