Epstein Secrets

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

f criminal proceedings, "a party bears the heavy burden of demonstrating that there would be a clear case of hardship if a stay did not issue." GLL GmbH & Co. Messeturm KG v. La Vecchia, 247 F.R.D. 231, 233 (D. Me. 2008) (internal quotations omitted). Epstein's motion fails for at least three reasons. Fir

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

f criminal proceedings, "a party bears the heavy burden of demonstrating that there would be a clear case of hardship if a stay did hot issue." GLL GmbH & Co. Messeturm KG v. La Vecchia, 247 F.R.D. 231, 233 (D. Me. 2008) (internal quotations omitted). Epstein's motion fails for at least three reasons. Fir

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

f criminal proceedings, "a party bears the heavy burden of demonstrating that there would be a clear case of hardship if a stay did not issue." GLL GmbH & Co. Messeturm KG1 LaVecchia, 247 F.R.D. 231, 233 (D. Me. 2008) (internal quotations omitted). Epstein's motion fails for at least three reasons. First,