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ilege, the defendant faces certain loss of the civil proceeding on summary judgment if the civil proceeding were to continue. Lot 5, 23 F.3d at 364; Pervis v. State Farm Fire & Casualty Co., 901 F.2d 944 (11th Cir. 1990). Under this standard, Movants must show that invocation of the privilege in the inst
matter will result in certain loss by automatic summary judgment. United States v. Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not “merely the loss of the defendant’s most ‘effective defense.’” Securities & Ex
e interests is a situation-specific task, and an inquiring court must take a careful look at the idiosyncratic circumstances of the case before it.” Microfinancial, supra, 385 F.3d at 78. Epstein’s case is more idiosyncratic than most. As the Court aptly noted in its Order denying Epstein’s first motion to stay
third parties; . . . (v) the public interest[;] . . . (vi) the good faith of the litigants (or the absence of it) and (vii) the status of the cases.” Microfinancial, 385 F.3d at 78 (citations omitted). In considering those factors, the United States respectfully recommends to the Court that all of the factors wei
ceeding were to continue. Lot 5, 23 F.3d at 364; Pervis v. State Farm Fire & Casualty Co., 901 F.2d 944 (
osyncratic circumstances of the case before it.” Microfinancial, supra, 385 F.3d at 78. Epstein’s case is more i
bsence of it) and (vii) the status of the cases.” Microfinancial, 385 F.3d at 78 (citations omitted). In consideri
tter will result in certain loss by automatic summary judgment. United States v. Two Parcels of Real Property, 92 F.3d 1123, 1129 (1Ith Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "merely the loss of the defendant's most 'effective defense.'" Securities & E
interests is a situation-specific task, and an inquiring court must take a careful look at the idiosyncratic circumstances of the case before it." Microfinancial, supra, 385 F.3d at 78. Epstein's case is more idiosyncratic than most. As the Court aptly noted in its Order denying Epstein's first motion to sta
ant faces certain EFTA00213026 loss of the civil proceeding on summary judgment if the civil proceeding were to continue. Lot 5 , 23 F.3d at 364; Pervis v. State Farm Fire & Casualty Co. , 901 F.2d 944 (11th Cir. 1990). Under this standard, Movants must show that invocation of the privilege in the i
e interests is a situation-specific task, and an inquiring court must take a careful look at the idiosyncratic circumstances of the case before it." Microfinancial, supra , 385 F.3d at 78. Epstein's case is more idiosyncratic than most. EFTA00213030 As the Court aptly noted in its Order denying Epstein's fir
matter will result in certain loss by automatic summary judgment. United Stalest Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "merely the loss of the defendant's most `effective defense.' Securities & Ex
interests is a situation-specific task, and an inquiring court must take a careful look at the idiosyncratic circumstances of the case before it." Microfinancial, supra, 385 F.3d at 78. Epstein's case is more idiosyncratic than most. As the Court aptly noted in its Order denying Epstein's first motion to sta
matter will result in certain loss by automatic summary judgment. United Stalest Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "merely the loss of the defendant's most `effective defense.' Securities & Ex
interests is a situation-specific task, and an inquiring court must take a careful look at the idiosyncratic circumstances of the case before it." Microfinancial, supra, 385 F.3d at 78. Epstein's case is more idiosyncratic than most. As the Court aptly noted in its Order denying Epstein's first motion to sta
atter will result in certain loss by automatic summary judgment. United States'. Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "merely the loss of the defendant's most `effective defense."' Securities & E
interests is a situation-specific task, and an inquiring court must take a careful look at the idiosyncratic circumstances of the case before it." Microfinancial, supra, 385 F.3d at 78. Epstein's case is more idiosyncratic than most. As the Court aptly noted in its Order denying Epstein's first motion to sta
Entities connected to both Pervis and Microfinancial

Jeffrey Epstein
PERSONJane Doe
PERSON
United States
LOCATION
Kenneth Marra
PERSONThe First Circuit
ORGANIZATION
Alexander Acosta
PERSONFox Grove
LOCATIONWright
PERSONCooke
PERSONAlachua County
LOCATIONLauer
PERSONShell Oil Co.
ORGANIZATIONMicrofinancial, Inc.
ORGANIZATION
Scarlett Johansson
PERSONJANE DOE NO.
PERSONJane Doe Litigation
PERSONS.D. Fl
LOCATIONSterling National Bank
ORGANIZATIONWestrick
PERSONJOHNSON DE 51-1
ORGANIZATION