Epstein Secrets

"A defendant's privilege against self-incrimination is a factor favoring a stay only after that defendant has been indicted." United States ex rel. Gonzalez v. Fresenius Medical Care North America, 571 F.Supp.2d 758, 763 (W.D. Tex. 2008) (internal quotation omitted) (emphasis added). See, e.g., Ventura

Case 9:08-cv-80811-KAM Document 64-2 Entered on FLSD Docket 04/24/2009 Page 1 of 10 • Case 9:08-cv-80893-KAM Document 31 Entered on FLSD Docket 04/09/2009! Page 1 of 14 UNITED STATES DISTRICT COURT SOU

there is a strong presumption in favor of discovery, and the [movant] must overcome the presumption in its request for a stay? United States ex teL Gonzalez v. Fresenius Medical Care North America, 571 F.Supp.2d 758, 761 (W.D. Tex. 2008). Epstein has failed to even consider this interest of Jane Doe in

Case 9:08-cv-80811-KAM Document 64-3 Entered on FLSD Docket 04/24/2009 Page 1 of 13 Case 9:08-cv-80381-KAM Document 77 Entered on FLSD Docket 04/23/2009 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN

U.S. District Court for the Southern District of Florida, Case No. 08-80069, which was filed without the consent of the mother"), In re Sandberg v. Gonzalez, Case No. 50 2008 DR 001141 (Palm Beach Co. Family Ct.) (1/31/08). If this turns out to be the case, there is complete diversity, regardless of Rob

s"). 5 Lewis Tein n. 3059 Gump Ave mut Sulu 340, Cocorout Goon. haulm 33133 So1316 EFTA00234228 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07121:2008 Page 6 of 100 1. The amount in controversy in this action exceeds $75,000. This case is a duplicate of the First Federal Lawsuit. In th