015-01.pdf

1.26 MB
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Extraction Summary

11
People
8
Organizations
3
Locations
4
Events
3
Relationships
5
Quotes

Document Information

Type: Legal motion (motion to stay), affidavit, and discovery response
File Size: 1.26 MB
Summary

This document is a Motion to Stay proceedings filed by Jeffrey Epstein's legal team in a civil case brought by a plaintiff identified as C.M.A. Epstein argues that the civil case should be paused until late 2010, when his Non-Prosecution Agreement (NPA) with federal prosecutors expires, to avoid forcing him to waive his 5th Amendment rights against self-incrimination while facing potential ongoing criminal liability. The filing includes an affidavit from his criminal defense attorney, Jack Goldberger, and an Indictment from 2006 for Felony Solicitation of Prostitution.

People (11)

Name Role Context
Jeffrey Epstein Defendant
Seeking a stay of civil proceedings until his Non-Prosecution Agreement (NPA) expires in late 2010 to avoid waiving 5...
Sarah Kellen Co-Defendant
Named as a defendant in the civil suit.
C.M.A. Plaintiff
Plaintiff in the civil suit alleging sexual abuse by Epstein in 2004.
Jack A. Goldberger Defense Attorney
Epstein's criminal defense attorney; provided an affidavit supporting the motion for stay.
Robert D. Critton, Jr. Defense Attorney
Attorney for Epstein, signed the motion.
Michael J. Pike Defense Attorney
Attorney for Epstein.
Richard Horace Willits Plaintiff Attorney
Counsel for Plaintiff C.M.A.
Jack Scarola Plaintiff Attorney
Co-Counsel for Plaintiff.
Jack P. Hill Plaintiff Attorney
Co-Counsel for Plaintiff.
Bruce Reinhart Defense Attorney
Counsel for Defendant Sarah Kellen.
Kim E. Rosin Notary Public
Notarized Goldberger's affidavit.

Organizations (8)

Name Type Context
United States District Court, Southern District of Florida
Court handling the civil case.
15th Judicial Circuit Court, Palm Beach County
State court handling Epstein's criminal matter.
USAO (United States Attorney's Office)
Federal prosecutor, party to the Non-Prosecution Agreement (NPA).
SAO (State Attorney's Office)
State prosecutor for Palm Beach County.
FBI (Federal Bureau of Investigation)
Denied a FOIA request from Epstein regarding the investigation.
Burman, Critton, Luttier & Coleman
Law firm representing Epstein in the civil matter.
Atterbury Goldberger & Weiss, P.A.
Law firm representing Epstein in criminal matters.
Searcy Denney Scarola Barnhart & Shipley, P.A.
Law firm representing the Plaintiff.

Timeline (4 events)

2004
Alleged sexual abuse of Plaintiff C.M.A. by Epstein (referenced in discovery response).
N/A
2006-07-01
Indictment of Jeffrey Epstein by a grand jury.
Palm Beach County, FL
Jeffrey Epstein State of Florida
2008-06-30
Non-Prosecution Agreement (NPA) took effect.
Southern District of Florida
2010
Anticipated expiration of the Non-Prosecution Agreement (NPA).
N/A

Locations (3)

Location Context
Location of various law firms involved.
Location of Plaintiff's counsel's office.
Jurisdiction of the court.

Relationships (3)

Jeffrey Epstein Co-Defendants Sarah Kellen
Listed as Defendants in the case caption.
Jeffrey Epstein Attorney-Client Jack A. Goldberger
Goldberger affidavit states he is the criminal defense attorney for Epstein.
Jeffrey Epstein Legal Adversaries C.M.A.
Plaintiff and Defendant in civil suit 08-CV-80811.

Key Quotes (5)

"The Non-Prosecution Agreement... expires by those same terms in late 2010 so long as EPSTEIN complies with the terms and conditions - violations of which remain undefined."
Source
015-01.pdf
Quote #1
"What the NPA does not outline or define is what constitutes a breach or what act or omission constitutes a breach thereof."
Source
015-01.pdf
Quote #2
"The USAO has already attempted to claim violations of the NPA due to, among other things, EPSTEIN defending the civil actions against him."
Source
015-01.pdf
Quote #3
"[Epstein is] forced to choose between waiving his 5th Amendment Privilege or risk losing this civil case..."
Source
015-01.pdf
Quote #4
"The threat of criminal prosecution against EPSTEIN by USAO in the Southern District of Florida continues presently and through late 2010."
Source
015-01.pdf
Quote #5

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