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,

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

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,

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

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)

it is clear that Epstein has met the elements of St. Paul Fire necessary for this Court to enter a stay: 1. E

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

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