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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
y, 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 United States' Motion to Stay Discove
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
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 respectfully requests that the Court: (
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
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 respectfully requests that the Court: (
Entities connected to both The Eleventh Circuit and First Request for Production

Jeffrey Epstein
PERSON
Kenneth Marra
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Paul Cassell
PERSONMaria Farmer
PERSONLeon Black
PERSON
Salt Lake City
LOCATION
United States District Court
ORGANIZATION
S.J. Quinney College of Law
ORGANIZATIONRoy Black
PERSON
the University of Utah
ORGANIZATION
Dexter Lee
PERSONSouthern District
LOCATIONthe Federal Rules of Civil
ORGANIZATIONFLSD Docket
ORGANIZATIONAdmissions
ORGANIZATIONChudasama
ORGANIZATIONCheshire v. Bank of America
ORGANIZATION