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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
es certain loss of the civil proceeding on summary judgment if the civil proceeding were to continue. EFTA00222780 Lot 5 , 23 F.3d at 364; Penis. State Farm Fire & Casualty Co. , 901 F.2d 944 (11th Cir. 1990). Under this standard, Movants must show that invocation of the privilege in the instant matter will result in certa
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
re to continue. Lot 5, 23 F.3d at 364; Pervis v. State Farm Fire & Casualty Co., 901 F.2d 944 (11th Cir. 1990). Under this standa
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
defendant faces certain loss of the civil proceeding on summary judgment if the civil proceeding were to continue. Lot 5, 23 F.3d at 364; Pervis v. State Farm Fire & Casualty Co., 901 F.2d 944 (11th Cir. 1990). Under this standard, Movants must show that invocation of the privilege in the instant matter will result in certain
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
certain EFTA00213026 loss of the civil proceeding on summary judgment if the civil proceeding were to continue. Lot 5 , 23 F.3d at 364; Pervis v. State Farm Fire & Casualty Co. , 901 F.2d 944 (11th Cir. 1990). Under this standard, Movants must show that invocation of the privilege in the instant matter will result in certa
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
defendant faces certain loss of the civil proceeding on summary judgment if the civil proceeding were to continue. Lot 5, 23 F.3d at 364; Penis v. State Farm Fire & Casualty Co., 901 F.2d 944 (11th Cir. 1990). Under this standard, Movants must show that invocation of the privilege in the instant matter will result in certai
Entities connected to both Jeffrey Epstein and State Farm Fire & Casualty Co.

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
LOCATIONCooke
PERSONLauer
PERSON
the U.S. Attorney’s Office
ORGANIZATIONHakim
PERSONSterling National Bank
ORGANIZATIONShell Oil Co.
ORGANIZATION