Epstein Secrets

E IN OPPOSITION TO INTERVENORS' MOTION TO STAY Intervenors' Motion for Stay Pending Appeal should be granted. Contrary to plaintiffs' contentions, the Eleventh Circuit will have jurisdiction over their appeal from the Court's disclosure order, and the standard for granting a stay pending appeal is amply satisfied i

nors have already fully addressed this issue, including this Court's reasoning, in their Motion at . As they pointed out there, in United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement, not to state charges as here, renderin

he communications at issue; the plaintiffs will suffer no harm fro Voe granting of a stay until these critically important issues can be resolved by the Eleventh Circuit; and to the extent that the public has an interest in the matter, it would favor considered appellate resolu of the issues presented prior to the r

counsel and the government led to Epstein's plea of guilty in state court. In the sole case cited by the Court for this proposition, United States'. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement. That Mr. Epstein entered into a plea i

he communications at issue; the plaintiffs will suffer no harm fro Voe granting of a stay until these critically important issues can be resolved by the Eleventh Circuit; and to the extent that the public has an interest in the matter, it would favor considered appellate resolu of the issues presented prior to the r

counsel and the government led to Epstein's plea of guilty in state court. In the sole case cited by the Court for this proposition, United States'. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement. That Mr. Epstein entered into a plea i

The CVRA at §3771(e) defines a "crime victim" as " a person directly and proximately harmed as a result of the commission of a Federal offense." In the Eleventh Circuit, a two-part test is employed to determine whether an individual qualifies as a crime victim under this statute: First, the court must identify the

ounsel and the government led to Epstein's plea of guilty in state court. In the sole case cited by the Court for this proposition, United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement. That Mr. Epstein entered into a plea i

e communications at issue; the plaintiffs will suffer no harm from the granting of a stay until these critically important issues can be resolved by the Eleventh Circuit; and to the extent that the public has an interest in the matter, it would favor considered appellate resolution of the issues presented prior to t

ounsel and the government led to Epstein's plea of guilty in state court. In the sole case cited by the Court for this proposition, United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement. That Mr. Epstein entered into a plea i

E IN OPPOSITION TO INTERVENORS' MOTION TO STAY Intervenors' Motion for Stay Pending Appeal should be granted. Contrary to plaintiffs' contentions, the Eleventh Circuit will have jurisdiction over their appeal from the Court's disclosure order, and the standard for granting a stay pending appeal is amply satisfied i

rs have already fully addressed this issue, including this Court's reasoning, in their Motion at 6-9. As they pointed out there, in United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement, not to state charges as here, renderin