Mr Edwardss efforts at prosecuting both his own and his clients claims against Mr Epstein have already required Mr Epstein to assert his Fifth Amendment privilege against self incrimination in different matters also involving attorney Edwards most recently in Guiffre Maxwell No S.D.N.Y see infra where Mr Epstein was a witness not a party If a stay is not granted Mr Epstein will likewise need to assert his Fifth Amendment privilege in the instant proceeding Mr Edwards efforts at rescinding the NPA have effectively put Mr Epstein between the proverbial rock and a hard place Mr Epsteins assertion of his Fifth Amendment privilege will impair his ability to present a defense to the alleged claims against him in this pending civil case claims that as currently advanced by Mr Edwards and as illustrated in both his witness and exhibit lists in this case are claims he contends substantially overlap the subject matter of the NP A and predictably will require Mr Epstein to either assert his constitutional privilege or instead testify to matters squarely within the heartland of the protections conferred by the challenged NP A issues that Epstein submits have no bearing on this litigation but that Edwards clearly intends to make the crux of his case For Mr Epstein to claim the privilege and instead waive it in order to present his defenses could potentially expose him to criminal prosecution particularly if Mr Edwards succeeds in his efforts to invalidate the NP A Mr Edwards should not be allowed to use the Doe Case and Mr Epsteins resulting and reasonable apprehension of the potential for comprehensive criminal exposure in the Southern District of Florida to his advantage as he pursues monetary and punitive damages for his personal benefit against Mr Epstein especially at a time when Mr Epstein cannot fully defend himself due to Mr Edwardss prosecution of the Doe Case As a result Mr Epstein respectfully requests this Honorable Court to temporarily stay the above captioned matter pending the resolution of the Doe Case I BACKGROUND For nearly a decade Mr Edwards both as an attorney for alleged victims and as a claimant himself has been making claims against Mr Epstein with the express intent and desire for Mr Epstein to be criminally prosecuted See Doe United States No S.D Fla Victims Reply to Governments Response to Emergency Petition for Enforcement of Crime Victims Rights Act Doc at Jane Doe and Jane Doe 2s Response to Governments Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction Doc at Both Mr Edwards and Mr Paul Cassell his co-counsel in the Doe Case during sworn deposition testimony and in their pleadings have unequivocally stated that causing a criminal prosecution of Mr Epstein is a primary objective of their pending litigation in Doe United States Mr Edwards is himself suing Mr Epstein for malicious prosecution in the instant case and is seeking to hold Mr Epstein financially liable to Mr Edwards by among other ways portraying Mr Epstein as someone culpable of numerous federal criminal offenses involving sexual misconduct with minor females several of whom Mr Edwards intends to call as witnesses in his case-in-chief See Fifth Amended and Supplemental Witness List of Counter Plaintiff Bradley Edwards filed on July Mr Edwards has also represented three litigants in civil cases against Mr Epstein involving claims based on such allegations of sexual misconduct and in related matters,2 while also actively working to invalidate Mr Epsteins NPA and have Mr Epstein prosecuted for the very same conduct On September Mr Epstein and the United States Attorneys Office for the Southern District of Florida entered into a NP A covering five separate categories of alleged offenses relating to allegations of misconduct with minor females between and September for which the federal government was investigating Mr Epstein violations of conspiracy to violate U.S.C violations of conspiracy to violate U.S.C violations of U.S.C violations of and violations of a NPA at The NPA also encompassed offenses such as money laundering that were investigated by the United States Attorneys Office As such the efforts to invalidate the NPA also impact and impair Mr Epsteins ability to respond to questions about finances net worth financial and monetary transactions In accordance with the terms of the NP A Mr See e.g Guiffre Maxwell No S.D.N.Y Jane Doe II Epstein No S.D Fla L.M Epstein No S.D Fla Jane Doe et al Epstein No S.D Fla Epstein pied guilty to two discrete state offenses under and of the Florida Statutes See Id at On July one week after Mr Epstein entered his state pleas of guilty attorney Edwards on behalf of Jane Doe brought a petition before the District Court for the Southern District of Florida seeking to enforce Jane Does rights pursuant to the Crime Victims Rights Act U.S.C CVRA See Doe Case Dkt The petitioners in the Doe Case argued that the Government violated their rights to notice and consultation under the CVRA and as a result they are now seeking to vacate the NP A See Doe Case Dkt at Doe United States Supp 2d S.D Fla Considering the petitioners claims the court held that rescission of the NP A is a potential remedy the CVRA is properly interpreted to authorize the rescission or re-opening of a prosecutorial agreement including a non-prosecution arrangement reached in violation of a prosecutors conferral obligations under the statute Id at While the NPA has been in effect for nearly ten years there is a risk that Mr Edwards may ultimately succeed in his efforts to rescind the NP A and seek to expose Mr Epstein to potential criminal liability in the Southern District of Florida See FIGHT TO REOPEN TEEN SEX CASE AGAINST JEFF EPSTEIN MAY statements which would furnish a link in the chain of evidence needed to prosecute the claimant for a federal crime Rajah Mukasey F.3d 2d Cir quoting United States Hubbell U.S See e.g United States Greenfield WL at 2d Cir Aug the Fifth Amendment privilege has been found to extend not only to answers that are directly incriminatory but also to those that while not themselves inculpatory would furnish a link in the chain of evidence needed to prosecute the claimant internal quotation marks omitted In assessing the validity of an assertion of Fifth Amendment privilege the Court must look to all of the circumstances of the case and be governed as much by personal perceptions of the peculiarities of the case as by the facts actually in evidence SEC Militano WL at S.D N.Y Dec quoting Hoffman United States A witness may be compelled to answer only if it clearly appears he is mistaken as to the justification for the privilege or is advancing his claim as a subterfuge Camelot Group Ltd A Krueger Co Supp S.D.N.Y Hoffman U.S To sustain the privilege it need only be evident from the implications of the question in the setting in which it is asked that a responsive answer to the question or an explanation of why it cannot be answered might be dangerous because injurious disclosure could result see also Raass Borgia So 2d Fla Dist Ct App following Hoffman to preclude discovery concerning defendant dentists chemical dependency Appel Bard So 3d Fla Dist Ct App ONeal Sun Bank N.A So 2d Fla Dist Ct App The privilege may be invoked in a civil action during a discovery proceeding if the civil litigant has reasonable grounds to believe that direct answers to deposition or interrogatory would furnish a link in the chain of evidence needed to prove a crime against him citing Hoffman Mr Epsteins potential assertion of his Fifth Amendment privilege in the instant case is more than amply justified by a well-founded fear of prosecution prosecution that Mr Edwards has been seeking in the Doe Case for almost a decade Any statements made by Mr Epstein as to matters relating to allegations of abuse or relating to Mr Epsteins monetary and financial transactions and/or his financial assets and resources could provide the impetus for possible future prosecution based on such alleged conduct or at minimum a link in the chain that could be exploited to develop additional evidence against him for crimes including those that are within the scope of the NPA In a previous matter Guiffre Maxwell No S.D.N.Y where the unsealed record reflects Mr Epstein asserted his Fifth Amendment privilege motions to compel were brought and Mr Epstein was not required to testify based on his assertion of the Fifth Amendment privilege see Dkt and As a non-party Mr Epstein suffered no prejudice from his principled and upheld assertion of the Fifth Amendment in that matter by contrast however in this matter the prejudice from the potential finding of adverse inferences against a Party asserting the Fifth Amendment in a civil proceeding and from being foreclosed from pursuing affirmative defenses that rely upon his testimony will be immense While it is Mr Epsteins position that he has a valid privilege to topics extending beyond the subject matter of the NP A which is venue specific and does not preclude prosecution in other districts the risk of any invalidation of the NP A creates more comprehensive Fifth Amendment concerns carries the most significant risk of criminal prosecution and requires the broadest invocation of the Fifth Amendment as to predictable subjects in the pending civil litigation Thus while Mr Edwardss efforts to impair Mr Epsteins NPA are ongoing and vigorous the Doe United States litigation has been ongoing for over nine years with well over a hundred pages of recent filings in support of Mr Edwards request for partial Summary Judgment Mr Epstein has a Fifth Amendment privilege that he must assert to abate a significant risk that if Mr Edwards is successful and the NP A is invalidated and criminal charges are thereafter returned in the Southern District of Florida that Mr Epstein will not have The Government has argued in Doe United States Dkt at that by its express terms the NP A binds only the United States Attorneys Office for the Southern District of Florida is venue and subject matter specific and does not accordingly preclude prosecution in any other district nor prosecution for offenses that were not within the statutes specifically enumerated in the NP A or the subject of the joint investigation of the Federal Bureau of Investigation and the U.S Attorneys Office in the Southern District of Florida NPA at waived his principled Fifth Amendment rights regarding the subject matter of such a potential prosecution and will not have testified without immunity in a manner that may be used to further any potential future criminal prosecution Such risks that are directly derivative of Mr Edwards litigation in the Doe case can only be reduced if Mr Edwards withdraws the remedy of invalidating the NP A which is but one of many remedies he is seeking in his Doe Case petition or upon the court ruling and denying his request to invalidate the NP A or upon this Honorable Court granting the request for a stay until after the Doe case concludes I THIS HONORABLE COURT SHOULD TEMPORARILY STAY PROCEEDINGS PENDING THE OUTCOME OF THE DOE CASE Trial courts have long had the discretion to manage their dockets and stay proceedings when circumstances require it See United States Kordel U.S noting that courts have deferred civil proceedings pending the completion of parallel criminal prosecutions when the interests of justice seemed to require such action Landis North Am Co U.S the power to stay proceedings is incidental to the power inherent in every court to control the disposition of the causes on its docket with the economy of time and effort for itself for counsel and for litigants Texaco Inc Borda F.2d 3d Cir affirming stay in civil case pending determination of parallel criminal Case proceeding While there is no constitutional right to a stay of civil proceedings pending resolution of a related criminal proceeding circumstances such as the ones sub Judice frequently warrant a stay See e.g Afro-Lecon Inc United States 2d Fed Cir it has long been the practice to freeze civil proceedings when a criminal prosecution involving the same facts is warming up or under way Texaco 2d at affirming stay Brock Tolkow F.R.D E.D.N.Y Fact that indictment had not yet been returned did not preclude stay of discovery in civil action pending outcome of criminal action which might be brought against defendants as result of Justice Department investigation Kashi Gratsos F.2d 2d Cir No abuse of discretion where District court granted motion to stay and delayed the trial until the U.S Attorneys office announced that it had declined prosecution Courts commonly stay civil cases where a party under criminal indictment is also required to defend a civil suit involving the same matter because denying a stay may undermine a partys Fifth Amendment privilege against self-incrimination or may otherwise prejudice the criminal case Am Express Bus Fin Corp RW Prof Leasing Servs Corp Supp 2d E.D.N.Y Given the risks inherent if the NPA is invalidated in the Doe litigation Mr Epsteins position is comparable In considering whether a stay is warranted this Court should consider the following six factors the extent to which the issues in the criminal case overlap with those presented in the civil case the status of the case including whether the defendants have been indicted the private interests of the plaintiffs in proceeding expeditiously weighed against the prejudice to plaintiffs caused by the delay the private interests of and burden on the defendants the interests of the courts and the public interest Louis Vuitton Malletier S.A LY USA Inc 3d 2d Cir citing to Trustees of Plumbers Pipefitters Nat Pension Fund Transworld Mechanical Inc F.Supp S.D.N.Y ordering stay of civil proceedings Square Bank Lo No WL at N.D Cal Dec granting stay pending Defendants sentencing Volmar Distributors Inc New York Post Co F.R.D S.D.N.Y granting stay Walsh Sec Inc Cristo Prop Mgmt Ltd Supp 2d D.N.J stay warranted by similarity of issues in civil and criminal proceedings serious Fifth Amendment concerns about self-incrimination if civil trial continued absence of prejudice to mortgagee from delay burden on defendants without stay and public interest in favor of stay Colombo Bd of Educ for the Clifton Sch Dist WL at D.N.J Nov stay pending the resolution of the criminal charges granted S.E.C Nicholas Supp 2d C.D Cal complete stay of civil enforcement action by Securities and Exchange Commission in favor of parallel criminal actions was warranted as being in best interest of justice criminal case was of primary importance to public defendants and the court discovery in civil action would almost certainly cause delay in criminal action specter of parties and witnesses likely to invoke their Fifth Amendment rights would render civil discovery largely one-sided and civil and criminal cases were inextricably intertwined and could not reasonably proceed independent of each other Florida courts have similarly followed national precedent allowing the defendants to stay civil proceedings when their Fifth Amendment privilege against self-incrimination is implicated Klein Royale Grp Ltd So 2d Fla Dist Ct App affirming eight month stay of civil proceedings based on defendants assertion of their Fifth Amendment rights McCreery Fernandez So 2d Fla Dist Ct App denial of motion for continuance of the trial in the civil case pending felony charges which will require defendant to invoke his Fifth Amendment privilege against self-incrimination may well have been a departure from the essential requirements of law Kanji Valli So 2d Fla Dist Ct App Defendant sought and received two orders abating and staying the proceedings pending the outcome of potential criminal charges based on the same acts giving rise to the civil litigation third applications denied based on defendants response to requests for admissions requ1nng question-by-question objection detailing the Fifth Amendment objection in regard to each challenged question As further set forth herein application of the six factors warrants a stay of the instant case pending the outcome of the Doe Case The issues in the potential criminal and civil cases overlap Overlap between the issues in parallel civil and criminal proceedings is the most important factor in deciding whether to stay civil proceedings Walsh Supp 2d at citing and quoting Milton Pollack Parallel Civil and Criminal Proceedings F.R.D Perfect symmetry between criminal and civil proceedings is not however required to stay a civil case pending the resolution of a criminal case See Peterson Matlock WL D.N.J Nov granting stay despite lack of complete overlap in issues Rather greater overlap between the issues strengthens the case for a stay because greater overlap increases the risk of self-incrimination Trustees Supp at Here overlap between the issues in this case and the criminal case is substantial and the risks to Mr Epstein are significant if the case is not stayed If the petitioners in the Doe Case undo Mr Epsteins NP A he is at risk of being criminally prosecuted for allegations of violations of conspiracy to violate U.S.C violations of conspiracy to violate U.S.C violations of U.S.C violations of and violations of a stemming from conduct alleged to have occurred over the span of many years Additionally Mr Epstein would also be at risk of potential prosecution for allegations of money laundering and other related offenses that were also encompassed by the United States Attorneys Office investigation Indeed in the Doe case Mr Edwards alleged that Mr Epstein repeatedly sexually assaulted more than forty young girls on numerous occasions and that Southern District of Florida prosecutors had prepared a draft indictment of Mr Epstein which is strongly indicative of the charges Mr Epstein may face if Mr Edwards successfully rescinds the NP A See Plaintiffs Statement of Undisputed Facts Doe United States No Doc at and In the instant case Mr Edwards has marked as witnesses not any witnesses to establish a malicious prosecution claim but rather witnesses such as Alexandra Hall who was a central witness in the Governments criminal investigation of Mr Epstein one of the two Jane Does from Doe United States as well as Ms Giuffre aka Virginia Roberts who was the litigant in Giuffre Maxwell where Mr Epsteins Fifth Amendment assertion as a witness was upheld see Fifth Amended and Supplemental Witness List of Defendant/Counter-Plaintiff Bradley Edwards By identifying just these three witnesses each a person who will clearly claim based on their prior testimony and on their allegations in the Doe Case itself that Mr Epstein violated federal criminal statutes in his relationship with them Mr Edwards himself is asserting into this litigation the overlap between this case and the criminal case showing that the overlap weighs in favor of a stay Mr Edwards has also identified a large number of exhibits that relate to the underlying criminal investigation of Mr Epstein These exhibits and testimony regarding the allegations that Mr Epstein engaged in criminal conduct including those which are squarely within the core of the NPA protections are the subject of Mr Epsteins Omnibus Motion in Limine filed on September Absent this Honorable Court granting Epsteins Omnibus Motion in Limine in all respects there is a striking and encompassing overlap of issues that strongly favors the requested stay Further Mr Epsteins potential criminal exposure for money laundering charges at the threat of Mr Edwards impairs his ability to respond to questions relevant to Mr Edwards request for punitive damages including questions about finances net worth financial and monetary transactions see infra at Support for a stay of civil proceedings is strongest after a criminal indictment has been handed down Walsh Supp 2d at It is at this point that the possible harm of self incrimination is greatest However lack of pending criminal charges does not extinguish the risk of self-incrimination especially when the potential for criminal charges is warming up Afro Lecon Inc 2d at see also Brock F.R.D Kashi F.2d As detailed above Mr Edwards and his clients have been working towards Mr Epsteins criminal prosecution for nearly a decade It is solely a result of their efforts that Mr Epstein is now at significant risk of losing his NP A and finding himself facing further criminal prosecution The potential of a further criminal prosecution of Mr Epstein is real not speculative See Doe Case Dkt Doe Supp 2d and thus this factor should weigh heavily in his favor Further neither the Government nor the public are prejudiced by the stay as ordinarily they would be if a criminal prosecution is delayed despite speedy trial interests that the Government protects and that are designed to serve the public see U.S.C et seq Here the Government opposes any invalidation of the NP A in the Doe United States proceedings and has no interest on behalf of itself or the public in speedy civil litigation The Plaintiffs interest in proceeding expeditiously is outweighed by the risk of harm to Mr Epstein The third factor considers a plaintiffs interest in proceeding expeditiously against the prejudice caused by the delay A plaintiff must come forward with more than speculative assertions of prejudice or claims of spoliation due to the requested delay of their monetary litigation to avoid a stay See Government Employees Ins Co Zuberi WL D.N.J Oct declining to infer that defendants would destroy evidence or dissipate assets Neither the hypothetical risk of loss of evidence due to the passage of time nor any other argument to advance the civil proceeding at a time when Mr Epstein cannot fully defend himself are sufficient justifications to outweigh Mr Epsteins interests in protecting his constitutional rights and obtaining a stay Id The prejudice to plaintiff caused by a stay of this case will be minimal and is a direct result of the plaintiffs own actions Edwards attempts to rescind the NPA Clearly Mr Edwards prosecutorial goals and Mr Epsteins well-founded fear of the possibility of future allegations in criminal prosecutions are the reason for a need to stay these proceedings Mr Edwards should not be allowed to attack through the CVRA litigation that he himself delayed for years to pursue monetary damages for his individual clients see Doe Case Dkt at Doe Supp 2d at and now argue that a stay would cause an undue delay in litigating his own claims The plaintiff seeks money damages for acts that have already occurred Plaintiffs monetary interests are fully protected by the ability to recover pre-judgment interest Walsh Supp 2d at and Mr Edwards faces no risk of Mr Epstein avoiding any unfavorable judgment See Government Employees Ins Co WL at cf also Citibank N.A Hakim WL at S.D.N.Y Mr Edwards damage claims would suffer no prejudice due to a delay given that he enjoys a successful life as a lawyer but more importantly because he is the architect of the current tension between the pending civil litigation he has brought and Mr Epsteins principled Fifth Amendment rights which are at their quintessence when he will be asked about the subject matter that is currently within the immunity provisions of the NP A The burdens on Mr Epstein warrant a stay Here the burdens on Mr Epstein of litigating in a civil forum are significant Notably the Fifth Amendment does not forbid adverse inferences against parties to civil actions when they refuse to testify in response to probative evidence offered against them the Amendment does not preclude the inference where the privilege is claimed by a party to a civil cause Baxter Palmigiano U.S Mr Epstein should not be compelled to choose between waiving his Fifth Amendment rights and defending himself in the civil lawsuit or asserting the privilege and risking an adverse inference in a monetary civil case Even were the plaintiff Edwards through counsel to agree which they have not that no adverse inference should arise from Mr Epsteins assertion of his Fifth Amendment rights a position contrary to his current position where he is fully intending to seek adverse inferences from Fifth Amendment assertions Mr Epstein would nevertheless suffer the consequences of being unable to advance affirmative defenses to the civil allegations thus absent a stay his ability to defend himself will be deeply jeopardized Currently pending before this Court are the parties Motions for Summary Judgment and Mr Edwardss Motion to Compel Mr Epsteins responses to discovery requests Mr Edwards through his counsel has refused Mr Epsteins offer to stipulate to his net worth as evidenced by portions of his tax returns See Email September Email from Jack Scarola attached hereto as Exhibit Instead Mr Edwards is attempting to force Mr Epstein to stipulate to an uncorroborated overinflated net worth figure or for Mr Epstein to waive his Fifth Amendment rights and respond to discovery requests for additional net worth information Likewise Mr Edwards is attempting to preclude Mr Epstein from defending against the pending claims including asking this Court as a result of Mr Epsteins assertion of his Fifth Amendment rights to strike his affidavit in support of his summary judgement request Given that the NPA protects against charges which would require as an essential element proof of monetary and financial transactions and resources Mr Epsteins Indeed Mr Edwards has been actively pursuing an adverse inference as a result of Mr Epsteins assertion of his Fifth Amendment rights MR SCAROLA He faces potential criminal liability We are not trying to overrule the Fifth Amendment privilege But I want to overrule all the other privileges I want them eliminated so that when we are before a jury the single privilege that has been asserted is a Fifth Amendment privilege and as I have explained to the Court before its our position that that will enable us to draw adverse inferences from those assertions and argue those adverse inferences before the jury Epstein Rothstein Edwards et al No Tr at r,r emphasis added At the September status conference Mr Edwardss attorney asked this Court to strike Mr Epsteins affidavit and renewed his requests to compel Mr Epsteins answer to interrogatories and document production requests Epstein Rothstein Edwards et al No Tr at responses to questions concerning his finances could lead to potential criminal exposure exposure due solely to Mr Edwardss efforts to rescind the NPA See Parallel Proceedings F.R.D at noting that courts in civil matters can exclude evidence withheld by party on Fifth Amendment grounds Temporarily staying the proceedings in this case avoids placing Mr Epstein in the untenable position of either waiving his rights and exposing himself to criminal liability or foregoing a full defense to the instant allegations The interests of the court support a stay The convenience of the Court in the management of its cases and efficient use of judicial resources support a limited stay pending the resolution of the Doe Case Expeditious resolution of cases is as a general matter preferable to delay of the Courts docket S.E.C Alexander No WL at N.D Cal Dec However a number of courts have concluded that staying a related civil proceeding in its early stages may prove more efficient in the long run in part because the stay will allow civil discovery to proceed unobstructed by concerns regarding self-incrimination Id internal quotation marks and citation omitted Mr Edwards has identified Mr Epstein as a witness he intends to depose and call see Fifth Amended and Supplemental Witness List of Counter Plaintiff Edwards at Assuming Mr Epstein were to assert the Fifth Amendment there would be complex litigation over when an answer would warrant an adverse inference Assuming he answered some but not all questions inevitable litigation will occur regarding waiver and the legitimacy of upholding his Fifth Amendment while not striking the answers that will likely require the parties to bring question-by-question challenges to the Courts attention for resolution The Court would thus be forced to decide a constant stream of privilege issues Walsh Supp 2d at Staying the proceedings until the resolution of the Doe Case will potentially avoid many of these objections and allow Mr Epstein to consider his privilege objections on a subject-by-subject basis The public interest supports a stay The final factor balances the publics interest if any in achieving expeditious resolution of the civil proceeding versus the harm to defendants if a stay is denied Here there is no compelling public interest that justifies denial of a stay This case is not brought by a government agency or in a parens patriae capacity See United States Certain Real Property Supp E.D.N.Y distinguishing between enforcement action brought to enforce consumer protection or other statutes and less impactful civil matters Likewise this is a not a securities matter or drug labeling case where the operation of a market or labeling of a drug is at issue Cf Parallel Proceedings F.R.D at This is a private civil action and the plaintiff seeks only money damages There is no ongoing injury that plaintiff seeks to cure on behalf of the public Pursuing monetary damage claims are not in the public interest Furthermore the public has an interest in ensuring that the criminal process is not subverted by ongoing civil cases Douglas United States WL at N.D Cal July internal citation omitted Indeed courts have reasoned that where there are parallel criminal and civil proceedings the criminal case is of primary importance to the public whereas the civil case which will result only in monetary damages is not of an equally pressing nature Alexander WL at citations omitted Thus this factor too supports Mr Epsteins request for a stay of civil proceedings until the Doe Case is fully resolved IV CONCLUSION Based on all of the foregoing Mr Epstein hereby respectfully requests this Honorable Court to temporarily stay the above-captioned proceedings pending the outcome of the Doe Case Isl Jack Goldberger Esq Jack Goldberger Esq Atterbury Goldberger Weiss PA Australian Ave South Suite West Palm Beach FL jgoldberger agwpa.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list this 4th of October Isl Jack Goldberger Esq Jack Goldberger Esq SERVICE LIST CASE NO Jack Scarola Esq jsx searcylaw.com mep searcylaw.com Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach FL Jack Goldberger Esq jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss PA Australian Ave South Suite West Palm Beach FL Marc Nurik Esq East Broward Blvd Suite Fort Lauderdale FL Bradley Edwards Esq brad pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman Andrews Avenue Suite Fort Lauderdale Florida Fred Haddad Esq Dee FredHaddadLaw.com SE 7th Street Suite Fort Lauderdale FL Tonja Haddad Coleman Esquire Tonj a tonj ahaddad com efiling tonj ahaddad com Law Offices of Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Attorneys for Jeffrey Epstein
