Epstein Secrets

stead the document requests and the later-served requests for admissions seek documents and information pertaining to the criminal investigation of Jeffrey Epstein, including the prosecution memo and drafts of the indictment prepared in the case, which are governed by the grand jury secrecy rules. See Request f

taining to the criminal investigation of Jeffrey Epstein, including the prosecution memo and drafts of the

tion pertaining to the criminal investigation of Jeffrey Epstein, including the prosecution memo and draft

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

t requests and the later-served requests for admissions seek documents and information pertaining to the substance of the criminal investigation of Jeffrey Epstein, including any prosecution memoranda and drafts of any indictments prepared in the case, which are governed by the grand jury secrecy rules. See Re

bstance of the criminal investigation of Jeffrey Epstein, including any prosecution memoranda and drafts o

o the substance of the criminal investigation of Jeffrey Epstein, including any prosecution memoranda and

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

nt requests and the later-served requests for admissions seek documents and information pertaining to the substance of the criminal investigation of Jeffrey Epstein, including any prosecution memoranda and drafts of any indictments prepared in the case, which are governed by the grand jury secrecy rules. See Re

ubstance of the criminal investigation of Jeffrey Epstein, including any prosecution memoranda and drafts

to the substance of the criminal investigation of Jeffrey Epstein, including any prosecution memoranda and

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

nt requests and the later-served requests for admissions seek documents and information pertaining to the substance of the criminal investigation of Jeffrey Epstein, including any prosecution memoranda and drafts of any indictments prepared in the case, which are governed by the grand jury secrecy rules. See Re

ubstance of the criminal investigation of Jeffrey Epstein, including any prosecution memoranda and drafts

to the substance of the criminal investigation of Jeffrey Epstein, including any prosecution memoranda and

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

ests for documents go well beyond the issues pending in this litigation. Petitioners seek many documents pertaining to the criminal investigation of Jeffrey Epstein, including the prosecution memo prepared in the case. Request for Production No. 1. Petitioners rely upon a comment made by the Court, in its Septe

, 2011 Order, where this Court referenced petitioners' assertion that the FBI and U.S. Attorney's Office had developed a strong case for prosecuting Epstein, based on "overwhelming" evidence. Request for Production at 2. The Court, according to petitioners, stated that this was an allegation that needed

ments pertaining to the criminal investigation of Jeffrey Epstein, including the prosecution memo prepared

Court can resolve the issue of subject matter jurisdiction, without discovery being conducted by the parties, since it involves a legal question. In Chudasama v. Mazda Motor Corporation , 123 F.3d 1353 (11 ih Cir. 1997), the Eleventh Circuit observed that "[fJacial challenges to the legal sufficiency of a

to the EFTA00205483 criminal investigation of Jeffrey Epstein, including the prosecution memo and draft

elief they seek and that, because Petitioners still have the opportunity to confer with an attorney for the government and to pursue charges against Jeffrey Epstein in other Districts, their claim is not ripe. F2 Pursuant to Eleventh Circuit law, Respondent respectfully requests that the Court stay discovery in

the U.S. Attorney, asking for an investigation of various alleged improprieties occurring in the negotiation of the non-prosecution agreement with Epstein (Request for Production No. 17). This allegation of misconduct was referred to the Department of Justice's Office of Professional Responsibility. Ho

the parties, including significant public resources. Under such circumstances, a stay of proceedings is warranted and appropriate. See, generally , Chudasama v. Mazda Motor Corp. , 123 F.3d 1353, 1367-68 (11th Cir. 1997) (approving judicial intervention and resolution of claims-dispositive issues before p