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,

estigation will be closed is not immoderate or unreasonable. St. Paul Fire and Marine Insurance Company v. U.S„ 24 CI.Ct at 515-16; Ea to Wilson v, National Association of Letter Carriers, 2006 WL 3791313, *1 (E.D. La. 2006Xgranting motion to stay civil proceeding for 2 years and 7 months pending criminal investigation); Ostrow v, U.

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,

gation will be closed is not immoderate or unreasonable. St. Paul Fire and Marine Insurance Company v. U.S., 24 CI.Ct at 515-16; see also Wilson v. National Association of Letter Carriers, 2006 WL 3791313, *1 (ED. La. 2006)(granting motion to stay civil proceeding for 2 years and 7 months pending criminal investigation). Here, Epstei

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)

v. U.S., 24 Cl.Ct at 515-16; see also Wilson v. National Association of Letter Carriers, 2006 WL 3791313, *1 (E.D. La. 2006)(granting mo