Epstein Secrets

A. MARIE VILLAFAÑA Assistant United States Attorney [email protected] Florida Bar No. 0018255 500 East Broward Boulevard, 7th Floor Ft. Lauderdale, FL 33394 Telephone: 954-356-7255 Facsimile: 954-356-7230 Case 9:08-cv-80119-KAM Document 121 Entered on FLSD Docket 05/29/2009 Page 16 of 17

endment right against compelled self-incrimination in connection with civil litigation, a court can stay discovery or the entire civil case. Diaz v. Jenne, 2007 WL 624286 *1 (S.D. Fl. Feb. 23, 2007) (Cooke, J.). “However, ‘the Constitution does not require a stay of civil proceedings pending the outcom

0018255 500 East Broward Boulevard, 7th Floor Ft. Lauderdale, FL 33394 Telephone: 954-356-7255 Facsimile: 954-

stay discovery or the entire civil case. Diaz v. Jenne, 2007 WL 624286 *1 (S.D. Fl. Feb. 23, 2007) (Cook

mplaint demonstrates his reliance upon such a report from a single credible victim or eyewitness sufficient to demonstrate for probable cause: "Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used "the Epstein ploy .

e judged by the facts that existed at the time of the defendant's arrest, not evidence subsequently learned or provided to the prosecution. Madly v. Jenne, 867 So. 2d 1250, 1251 (Fla. 4th DCA 2004) ("Probable cause is judged by the facts and legal state of affairs that existed at the time of the arres

ow potential defendants could be in essence blackmailed into paying settlement that far exceeded the value of any legitimate damage claim. 20. Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used the "Epstein Ploy .

ies in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff and felon) assisted ROTHSTEIN in making these offers by providing confidential, privileged and work- prod

ow potential defendants could be in essence blackmailed into paying settlement that far exceeded the value of any legitimate damage claim. 20. Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used the "Epstein Ploy .

ies in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff and felon) assisted ROTHSTEIN in making these offers by providing confidential, privileged and work- prod

ow potential defendants could be in essence blackmailed into paying settlement that far exceeded the value of any legitimate damage claim. 20. Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used the "Epstein Ploy .

ies in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff and felon) assisted ROTHSTEIN in making these offers by providing confidential, privileged and work- prod

Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: ssistant United States Attorne 500 East Broward Boulevard, 7th Floor Ft. Lauderdale, FL 33394 Telephone: Facsimile: -16- EFTA00185221 Case 9:09-cv-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 17 of 17 CERTIFICAT

mendment right against compelled self-incrimination in connection with civil litigation, a court can stay discovery or the entire civil case. Diaz'. Jenne, 2007 WL 624286 al (S.D. Fl. Feb. 23, 2007) (Cooke, J.). "However, 'the Constitution does not require a stay of civil proceedings pending the outco

mplaint demonstrates his reliance upon such a report from a single credible victim or eyewitness sufficient to demonstrate for probable cause: "Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used "the Epstein ploy .

e judged by the facts that existed at the time of the defendant's arrest, not evidence subsequently learned or provided to the prosecution. Madly v. Jenne, 867 So. 2d 1250, 1251 (Fla. 4th DCA 2004) ("Probable cause is judged by the facts and legal state of affairs that 14 EFTA00583965 existed at th

ow potential defendants could be in essence blackmailed into paying settlement that far exceeded the value of any legitimate damage claim. 20. Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used the "Epstein Ploy .

ies in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff and felon) assisted ROTHSTEIN in making these offers by providing confidential, privileged and work- prod

ow potential defendants could be in essence blackmailed into paying settlement that far exceeded the value of any legitimate damage claim. 20. Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used the "Epstein. Ploy

ies in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff and felon) assisted ROTHSTEIN in making these offers by providing confidential, privileged and work- prod