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

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

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

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

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

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

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

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