Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. RESPONDENT'S REPLY TO PETITIONERS' RESPONSE TO RESPONDENT'S SEALED MOTION TO STAY DISCOVERY PE

otor Corp. , 123 F.3d 1353, 1367 (11th Cir. 1997) (citations omitted). See also Moore, Potter , 141 Fed. Appx. 803, 807-08 (11th Cir. 2005) (quoting Chudasama at 1367, 1368) (affirming district court's decision to stay proceedings, including all discovery, pending ruling on defendant's 12(b)(6) motion to

e need to resolve a facially challenged claim before discovery is based on the extent to which the claim expands discovery). The concerns raised in Chudasama and its progeny are present here. The motion to dismiss for lack of subject matter jurisdiction is dispositive of the entire case. Thus, staying dis

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. RESPONDENT'S REPLY TO PETITIONERS' RESPONSE TO RESPONDENT'S SEALED MOTION TO STAY DISCOVERY PE

or Corp. , 123 F.3d 1353, 1367 (11th Cir. 1997) (citations omitted). See also Moore v. Potter , 141 Fed. Appx. 803, 807-08 (11th Cir. 2005) (quoting Chudasama at 1367, 1368) (affirming district court's decision to stay proceedings, including all discovery, pending ruling on defendant's 12(b)(6) motion to

e need to resolve a facially challenged claim before discovery is based on the extent to which the claim expands discovery). The concerns raised in Chudasama and its progeny are present here. The motion to dismiss for lack of subject matter jurisdiction is dispositive of the entire case. Thus, staying dis

tered on FLSD Docket 01/24/2012 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. RESPONDENT'S REPLY TO PETITIONERS' RESPONSE TO RESPONDENT'S SEALED MOTION TO STAY DISCOVERY PE

advising the client as to which documents should be disclosed and which ones withheld, and determining whether certain information is privileged. Chudasama v. Mazda Motor Corp., 123 F.3d 1353, 1367 (11th Cir. 1997) (citations omitted). See also Moore v. Potter, 141 Fed. Appx. 803, 807-08 (11th Cir. 2005

otor Corp., 123 F.3d 1353, 1367 (11th Cir. 1997) (citations omitted). See also Moore v. Potter, 141 Fed. Appx. 803, 807-08 (11th Cir. 2005) (quoting Chudasama at 1367, 1368) (affirming district court's decision to stay proceedings, including all discovery, pending ruling on defendant's 12(b)(6) motion to

tered on FLSD Docket 01/24/2012 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. RESPONDENT'S REPLY TO PETITIONERS' RESPONSE TO RESPONDENT'S SEALED MOTION TO STAY DISCOVERY PE

advising the client as to which documents should be disclosed and which ones withheld, and determining whether certain information is privileged. Chudasama v. Mazda Motor Corp., 123 F.3d 1353, 1367 (11th Cir. 1997) (citations omitted). See also Moore v. Potter, 141 Fed. Appx. 803, 807-08 (11th Cir. 2005

otor Corp., 123 F.3d 1353, 1367 (11th Cir. 1997) (citations omitted). See also Moore v. Potter, 141 Fed. Appx. 803, 807-08 (11th Cir. 2005) (quoting Chudasama at 1367, 1368) (affirming district court's decision to stay proceedings, including all discovery, pending ruling on defendant's 12(b)(6) motion to

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. RESPONDENT'S MOTION TO STAY DISCOVERY PENDING RULING UPON RESPONDENT'S MOTION TO DISMISS Respo

Court can resolve the issue of subject matter jurisdiction, without discovery being conducted by the parties, since it involves a legal question. In Chudasama v. Mazda Motor Corporation , 123 F.3d 1353 (11 ih Cir. 1997), the Eleventh Circuit observed that "[fJacial challenges to the legal sufficiency of a

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. RESPONDENT'S REPLY TO PETITIONERS' OPPOSITION TO RESPONDENT'S SEALED MOTION TO STAY DISCOVERY

the parties, including significant public resources. Under such circumstances, a stay of proceedings is warranted and appropriate. See, generally , Chudasama v. Mazda Motor Corp. , 123 F.3d 1353, 1367-68 (11th Cir. 1997) (approving judicial intervention and resolution of claims-dispositive issues before p