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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? 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
itigation in deference to parallel criminal proceedings is discretionary. . . . A movant must carry a heavy burden to succeed in such an endeavor." Microfinancial, Inc. I Premier Holidays Internatt Inc. , 385 F.3d 72, 77 (1st Cir. 2004) (citations omitted). When a defendant facing possible criminal liability invokes
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
a heavy burden to succeed in such an endeavor.” Microfinancial, Inc. v. Premier Holidays Internat’l, Inc., 385 F.3d 72
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
litigation in deference to parallel criminal proceedings is discretionary. . . . A movant must carry a heavy burden to succeed in such an endeavor.” Microfinancial, Inc. v. Premier Holidays Internat’l, Inc., 385 F.3d 72, 77 (1st Cir. 2004) (citations omitted). When a defendant facing possible criminal liability invok
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
itigation in deference to parallel criminal proceedings is discretionary. . . . A movant must carry a heavy burden to succeed in such an endeavor." Microfinancial, Inc. I. Premier Holidays Internal?, Inc., 385 F.3d 72, 77 (1st Cir. 2004) (citations omitted). When a defendant facing possible criminal liability invoke
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
itigation in deference to parallel criminal proceedings is discretionary. . . . A movant must carry a heavy burden to succeed in such an endeavor." Microfinancial, Inc. I Premier Holidays Internatt Inc. , 385 F.3d 72, 77 (1st Cir. 2004) (citations omitted). When a defendant facing possible criminal liability invokes
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.:
itigation in deference to parallel criminal proceedings is discretionary. . . . A movant must carry a heavy burden to succeed in such an endeavor." Microfinancial, Inc. I. Premier Holidays Internal?, Inc., 385 F.3d 72, 77 (1st Cir. 2004) (citations omitted). When a defendant facing possible criminal liability invoke
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
itigation in deference to parallel criminal proceedings is discretionary. . . . A movant must carry a heavy burden to succeed in such an endeavor." Microfinancial, Inc. I Premier Holidays Internatt Inc. , 385 F.3d 72, 77 (1st Cir. 2004) (citations omitted). When a defendant facing possible criminal liability invokes
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.:
l litigation in deference to parallel criminal proceedings is discretionary.... A movant must carry a heavy burden to succeed in such an endeavor." Microfinancial, Inc. v. Premier Holidays Internal?, Inc., 385 F.3d 72, 77 (1st Cir. 2004) (citations omitted). When a defendant facing possible criminal liability invoke
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 ofhis obligations pursuant to the
NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / JANE DOE NO. 3, CASE NO
l litigation in deference to parallel criminal proceedings is discretionary.... A movant must carry a heavy burden to succeed in such an endeavor." Microfinancial, Inc. v. Premier Holidays Internal?, Inc., 385 F.3d 72, 77 (1st Cir. 2004) (citations omitted). When a defendant facing possible criminal liability invoke
Entities connected to both Jeffrey Epstein and Microfinancial, Inc.

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.
PERSONS.D. Fl
LOCATIONThe First Circuit
ORGANIZATIONJenne
PERSONFox Grove
LOCATIONMatra
ORGANIZATIONCooke
PERSONLauer
PERSONShell Oil Co.
ORGANIZATION
the U.S. Attorney’s Office
ORGANIZATIONJane Doe Litigation
PERSON