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UTHERN DISTRICT OF FLORIDA CASE NO.: 09-CV-80802-MARRA-JOHNSON JANE DOE NO. 8 Plaintiff, v. JEFFREY
ing on whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in
996); Shell Oil Co. , 866 F. Supp. at 540-41. Court-Appointed Receiver of Lance• Mgt. Group LLC v. Lauer , 2009 WL 800144 (S.D. Fl. Mar. 25, 2009) (Marra, J.). Thus, before reaching the relative benefit and prejudice to each of the parties caused by staying the cases, the Court must determine whether
bars to suit. I. STANDARD FOR IMPOSING A DISCRETIONARY STAY A. The Defendant Must Show that the Assertion of His Fifth Amendment Privilege Against Self-Incrimination Would Automatically Result in the Entry of Summary Judgment Against Him. "The decision whether or not to stay civil litigation in deference to para
HERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80I I 9-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFRE
nt 81 Entered on FLSD Docket 04)20:2009 Page 2 of 11 II. Argument in Reply A. Defendant Has Made a Blanket Assertion of the Privilege Against Self-Incrimination That Is Insufficient 1. Defendant Cannot Rely on its Blanket Objections to Interrogatories on Fifth Amendment Grounds Defendant Epstein insists t
1996); Shell Oil Co. , 866 F. Supp. at 540-41. Court-Appointed Receiver of Lancer Mgt. Group LLC I Lauer , 2009 WL 800144 (S.D. Fl. Mar. 25, 2009) (Marra, J.). Thus, before reaching the relative benefit and prejudice to each of the parties caused by staying the cases, the Court must determine whether
bars to suit. I. STANDARD FOR IMPOSING A DISCRETIONARY STAY A. The Defendant Must Show that the Assertion of His Fifth Amendment Privilege Against Self-Incrimination Would Automatically Result in the Entry of Summary Judgment Against Him. "The decision whether or not to stay civil litigation in deference to para
1996); Shell Oil Co. , 866 F. Supp. at 540-41. Court-Appointed Receiver of Lancer Mgt. Group LLC I Lauer , 2009 WL 800144 (S.D. Fl. Mar. 25, 2009) (Marra, J.). Thus, before reaching the relative benefit and prejudice to each of the parties caused by staying the cases, the Court must determine whether
bars to suit. I. STANDARD FOR IMPOSING A DISCRETIONARY STAY A. The Defendant Must Show that the Assertion of His Fifth Amendment Privilege Against Self-Incrimination Would Automatically Result in the Entry of Summary Judgment Against Him. "The decision whether or not to stay civil litigation in deference to para
1996); Shell Oil Co. , 866 F. Supp. at 540-41. Court-Appointed Receiver of Lancer Mgt. Group LLC I Lauer , 2009 WL 800144 (S.D. Fl. Mar. 25, 2009) (Marra, J.). Thus, before reaching the relative benefit and prejudice to each of the parties caused by staying the cases, the Court must determine whether
bars to suit. I. STANDARD FOR IMPOSING A DISCRETIONARY STAY A. The Defendant Must Show that the Assertion of His Fifth Amendment Privilege Against Self-Incrimination Would Automatically Result in the Entry of Summary Judgment Against Him. "The decision whether or not to stay civil litigation in deference to para
Entities connected to both Kenneth Marra and Self-Incrimination

Jeffrey Epstein
PERSONJane Doe
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Alexander Acosta
PERSONMichael J. Pike
PERSON
Adam D. Horowitz
PERSON
Sarah Kellen
PERSONJANE DOE NO
PERSONthe Eleventh Circuit
ORGANIZATIONStuart S. Mermelstein
PERSONAtterbury Goldberger & Weiss
ORGANIZATIONJANE DOE NO.
PERSONS.D. Fl
LOCATIONWright
PERSON
Hogan
PERSONFox Grove
LOCATIONMalloy
PERSON