Epstein Secrets

ys following the Court's denial of the Motion to Stay, the United States must serve any responses and/or objections to the Petitioners' Requests for Admissions and First Request for Production. CONCLUSION For the foregoing reasons, the United States respectfully requests that the Court: (1) grant the Uni

ion that the Court should order the United States to produce discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has clearly and repeatedly stated that dispositive motions should be decided before discovery begins: Facial challenges to the legal sufficiency of

r, alternatively, the denial of the Motion to Stay), i he United States must serve any responses and/or objections to the Petitioners' Requests for Admissions and First Request for Production. CONCLUSION For the foregoing reasons, the United States respectfully requests that the Court: (1) grant the Unit

ion that the Court should order the United States to produce discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has clearly and repeatedly stated that dispositive motions should be decided before discovery begins: Facial challenges to the legal sufficiency of

For example, Jane Doe has asked Epstein to admit that he committed sexual assault against Jane Doe when she was minor. Plaintiffs First Request for Admissions to Defendant Epstein 11. In response, Epstein asserted his Fifth Amendment privilege not to incriminate himself. For all these reasons, directing

hoosing among incrimination, perjury, or contempt." United States ex rel. DRC, Inc. v. Custer Battles, LLC, 415 F.Supp.2d 628, 633 (E.D. Va. 2006). The Eleventh Circuit has not hesitated to support district courts that draw an adverse inference from silence. For example, in United States v. Two Parcels of Real Prop

by this Rule. 5 EFTA00601812 Case 9:08-cv-80736-KAM Document 140 Entered on FLSD Docket 01/24/2012 Page 6 of 7 to the Petitioners' Requests for Admissions and First Request for Production within 30 days following the entry of such order. CONCLUSION For the foregoing reasons, the United States respect

on that the Court should order the United States to produce discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has clearly and repeatedly stated that dispositive motions should be decided before discovery begins: EFTA00601808 Case 9:08-cv-80736-KAM Documen

by this Rule. 5 EFTA00660799 Case 9:08-cv-80736-KAM Document 140 Entered on FLSD Docket 01/24/2012 Page 6 of 7 to the Petitioners' Requests for Admissions and First Request for Production within 30 days following the entry of such order. CONCLUSION For the foregoing reasons, the United States respect

on that the Court should order the United States to produce discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has clearly and repeatedly stated that dispositive motions should be decided before discovery begins: EFTA00660795 Case 9:08-cv-80736-KAM Documen