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ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa
f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an
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es the United States take any position regarding Defendant Epstein's performance of hi s obligations pursuant to th
have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push
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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
ASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/
n Agreement [“NPA”] between the United States and Epstein? By filing this response, the United States does
oes the United States take any position regarding Defendant Epstein’s performance of his obligations pursuant to the
ng the position of the United States on Defendant Jeffrey Epstein’s Motion to Stay Proceedings [DE 99]. Fo
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
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ___
of the civil proceedings in the “interests of justice” until the “expiration” of the Non- Prosecution Agreement [“NPA”] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of any
oes the United States take any position regarding Defendant Epstein’s performance of his obligations pursuant to the
ng the position of the United States on Defendant Jeffrey Epstein’s Motion to Stay Proceedings [DE 99]. Fo
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
ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa
f the civil proceedings in the "interests of justice" until the "expiration" of the Non-Prosecution Agreement ["NPA"] between the United States and Epstein? EFTA00222779 By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to th
es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the
NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / JANE DOE NO. 3, CASE N
ntly pending, Epstein has asked the Court to unseal the victims' names so that he may make use similar press efforts to impugn their credibility. a tEpstein points to provisions requiring him to maintain certain evidence "inviolate" as proof that the grand jury investigation is still active. These provis
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. EFTA00222784 As the Court aptly noted in its Order denying Epstein's fir
ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa
oceedings in the "interests of justice" until the "expiration" of the Non-Prosecution EFTA00213025 Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an
es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the
NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / JANE DOE NO. 3, CASE N
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
es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the
NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:
spondence or oral communications between the parties in these civil suits. Based on the information presented by the Court and a review of Defendant Jeffrey Epstein's Motion to Stay and/or Continue Action for Time Certain Based on Parallel Civil and Criminal Proceedings with Incorporated Memorandum of Law (Court
f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an
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
ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa
oceedings in the "interests of justice" until the "expiration" of the Non-Prosecution EFTA00222789 Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an
es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the
NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / JANE DOE NO. 3, CASE N
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. EFTA00222794 As the Court aptly noted in its Order denying Epstein's fir
spondence or oral communications between the parties in these civil suits. Based on the information presented by the Court and a review of Defendant Jeffrey Epstein's Motion to Stay and/or Continue Action for Time Certain Based on Parallel Civil and Criminal Proceedings with Incorporated Memorandum of Law (Court
f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an
es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the
NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:
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
ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa
oceedings in the "interests of justice" until the "expiration" of the Non-Prosecution EFTA00222799 Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an
es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the
NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / JANE DOE NO. 3, CASE N
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. EFTA00222804 As the Court aptly noted in its Order denying Epstein's fir
ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa
f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ("NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an
es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the
NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:
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 Jeffrey Epstein and Microfinancial

United States
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSON
A. Marie Villafana
PERSON
Scarlett Johansson
PERSON
Lauderdale
LOCATIONthe Eleventh Circuit
ORGANIZATIONWright
PERSONJANE DOE NO.
PERSONFLSD Docket
ORGANIZATIONS.D. Fl
LOCATIONThe First Circuit
ORGANIZATIONJenne
PERSONFox Grove
LOCATIONCooke
PERSONMatra
ORGANIZATIONLauer
PERSONShell Oil Co.
ORGANIZATIONJane Doe Litigation
PERSON