Epstein Secrets

have counsel state their appearances? MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs Jane 2 through Jane Doe 7. THE COURT: Good morning. MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane Doe. THE COURT: Good morning. MR. : Good morning, Your Honor. Sid for Jane Doe II. THE COURT: Good

sel state their appearances? MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs Jane 2 through Jane Doe 7. THE COURT: Good morning. MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane Doe. THE COURT: Good morning. MR. : Good morning, Your Honor. Sid for Jane Doe II. THE COURT: Good morning. MR.

ard Miami, FL 33160 305.931.2200 For Jane Doe BRADLEY J. EDWARDS, ESQ. 17 Rothstein Rosenfeldt Adler 401 East Las Ola

As this Court has previously explained: The law regardii stays of civil actions is well-settled in the Eleventh Circuit. In United States Lot 5, Fox Grove, Alachua County, Fla, 23 F.3d 359, 363- 65 (11th Cir. 1994) ("Lot 5"), the Court articulated the following principles of law with respect to a stay

his new firm. The new information is as follows: Bradley J. Edwards, Esq. ROTHSTEIN ROSENFELDT ADLER Telephone Facsimile

30 page limit do not apply. U.S. District Court Southern District of Florida Notice of Electronic Filing The following transaction was entered by Edwards, Bradley on 4/9/2009 4:06 PM EDT and filed on 4/9/2009 Case Name: Doe v. Epstein Case Number: 9:08-cv-80893 https://ecf.fled.uscourts.gov/cgi-bin/

ay.2 A good illustration of judicial reluctance to stay cases such as this one comes from the Eleventh Circuit's decision in United States v. Lot 5, Fox Grove, Alachua County, Fla., 23 F.3d 359, 364 (11th Cir. 1994). There, the Eleventh Circuit affirmed a district court's decision not to stay a civil forf

Plaintiff, by One of Her Counsel, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER

3401-2918 Lead Counsel Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. West Palm Beach FL 33401-5012 Co-Counsel Attorneys for Plaintiff Bradley JaMes Edwards ler Ft. Lauderdale, FL 33301 Lead Counsel Pro Hao Vice Jacksonville , FL 32211 14 Page 14 of 14 EFTA00201258

is warranted only when the defendant demonstrates that " `special circumstances' so require in the 'interests of justice.' "United States v. Lot 5, Fox Grove, 23 F.3d 359, 365 (11th Cir. 1994). In the Eleventh Circuit, the "special circumstances" which may support a stay are limited. The fact that the De

an Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 835-8691 (fax) [email protected] Co-Counsel Attorneys for Plaintiff Bradley James Edwards Rothstein Rosenfeldt Adler 401 East Las Olas Blvd Suite 1650 Ft. Lauderdale, FL 33301 954-522-3456 954-527-8663 (fax) [email protected] Le

Plaintiff, by One of Her Counsel, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER

ay.2 A good illustration of judicial reluctance to stay cases such as this one comes from the Eleventh Circuit's decision in United States I. Lot 5, Fox Grove, Alachua County, Fla., 23 F.3d 359, 364 (11th Cir. 1994). There, the Eleventh Circuit affirmed a district court's decision not to stay a civil forf