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,

nvestigation. As such, a stay should be entered in the instant matter. See also U.S. v. $75,020.00 In United States Funds, et al., 2009 WL 1010359 (M.D. G.a. 2009). 5 EFTA00201288 Case 9:08-cv-80811-KAM Document 81 Entered on FLSD Docket 05/13/2009 Page 6 of 7 Page 6 HI. Conclusion and Request for

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,

investigation. As such, a stay should be entered in the instant matter. See also U.S. v. $75,020.00 In United States Funds, et al., 2009 WL 1010359 (M.D. G.a. 2009). III. Conclusion and Request for Relief Based upon the foregoing, Epstein is entitled to a full stay of this proceeding (and other related m

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

investigation. As such, a stay should be entered in the instant matter. 5se also U.S. v. $75,020.00 in United States Funds, et al., 2009 WL 1010359 (M.D. G.a. 2009). 5 EFTA00175355 Case 9:08-cv-80811-KAM Document 81 Entered on FLSD Docket 05/13/2009 Page 7 of 7 Page 7 served this day on all counsel