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,

stage. The motion also concentrates on Epstein's risk of loosing this entire civil action as a result of Epstein invoking his 5th Amendment rights. Severino v. Klytie's Developments. Inc., 2008 WL 1782637, '2 (D. Colo)(recognizing that a stay is appropriate under similar circumstances as in the instant

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)

ult of Epstein invoking his 5th Amendment rights. Severino v. Klytie's Developments, Inc., 2008 WL 1782637,

U.S. Mail and facsimile to the following addressees this Cday of May, 2009. Brad Edwards, Esq. The Law Office of Brad Edwards & Associates, LLC Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. EFTA00234815 Case 9:08-cv-80893-KAM Document 55 Entered on FLSD Docket 05/13/2009 Page 2 of 2 Page 2

ice of Brad Edwards & Associates, LLC Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. EFTA00

titutional rights and allowing for a stay of the civil case until the criminal aspects/investigation of Defendant's companion case are closed). 2. Severino v. Klvtie's Developments, Inc., 27 L 1782637, *2 (D. Colo)(recognizing that a stay is appropriate under simil ces as in the instant case). By: R