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rivilege and risk loosing this case by virtue of not being able to present evidence, or waive that right and risk a potential criminal prosecution. Eastwood v. U.S., 2008 WL 5412857, *1 (ED. Tenn.))("Vvien a party to a civil action is subject to criminal proceedings and/or investigations that relate to s
al discovery beyond the limits of Fed.R.Crim.Pro. 16(b). Epstein satisfies the requirements to stay this action as set forth in St. Paul Fire and in Eastwood, including the similarity of issues underlying the civil litigation and ongoing criminal investigation. As such, a stay should be entered in the ins
nvestigation. As such, a stay should be entered in the instant matter. See also U.S. v. $75,020.00 In United States Funds, et al., 2009 WL 1010359 (M.D. G.a. 2009). 5 EFTA00201288 Case 9:08-cv-80811-KAM Document 81 Entered on FLSD Docket 05/13/2009 Page 6 of 7 Page 6 HI. Conclusion and Request for
rivilege and risk loosing this case by virtue of not being able to present evidence, or waive that right and risk a potential criminal prosecution. Eastwood v. U.S. 2008 WL 5412857, *1 (E.D. Tenn.)X"When a party to a civil action is subject to criminal proceedings and/or investigations that relate to suc
al discovery beyond the limits of Fed.R.Crim.Pro. 16(b). Epstein satisfies the requirements to stay this action as set forth in St. Paul Fire and in Eastwood, including the similarity of issues underlying the civil litigation and ongoing criminal investigation. As such, a stay should be entered in the in
investigation. As such, a stay should be entered in the instant matter. See also U.S. v. $75,020.00 In United States Funds, et al., 2009 WL 1010359 (M.D. G.a. 2009). III. Conclusion and Request for Relief Based upon the foregoing, Epstein is entitled to a full stay of this proceeding (and other related m
rivilege and risk loosing this case by virtue of not being able to present evidence, or waive that right and risk a potential criminal prosecution. Eastwood v, U.S., 2008 WL 5412857, *1 (E.D. Tenn.))("When a party to a civil action is subject to criminal proceedings and/or investigations that relate to s
al discovery beyond the limits of Fed.R.Crim.Pro. 16(b). Epstein satisfies the requirements to stay this action as set forth in St. Paul Fire and in Eastwood, including the similarity of issues underlying the civil litigation and ongoing criminal investigation. As such, a stay should be entered in the in
investigation. As such, a stay should be entered in the instant matter. 5se also U.S. v. $75,020.00 in United States Funds, et al., 2009 WL 1010359 (M.D. G.a. 2009). 5 EFTA00175355 Case 9:08-cv-80811-KAM Document 81 Entered on FLSD Docket 05/13/2009 Page 7 of 7 Page 7 served this day on all counsel
Entities connected to both Eastwood and M.D. G.a.

Jeffrey Epstein
PERSONJack Goldberger
PERSONJane Doe
PERSONSt. Paul Fire
ORGANIZATION
Alan Dershowitz
PERSONthe United States Attorneys' Office
LOCATION
Scarlett Johansson
PERSONMarine Insurance Company
ORGANIZATION
Kenneth Marra
PERSONNational Association of Letter Carriers
ORGANIZATIONMichael J. Pike
PERSONRichard Horace Willits
PERSON
Searcy Denney
PERSONJack Scarola
PERSONFLSD Docket
ORGANIZATIONBURMAN
PERSONthe Epstein's Motion to Stay
ORGANIZATION
Lake Worth
LOCATIONId. Courts
ORGANIZATIONRobert D. Critton
PERSON