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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
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 proceedings continue
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
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) (quoting Chudasama
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
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) (quoting Chudasama
Entities connected to both Jeffrey Epstein and Mazda Motor Corp.
Leon Black
PERSON
Bradley Edwards
PERSON
United States
LOCATIONSouthern District
LOCATIONJane Doe
PERSONMaria Farmer
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONRoy Black
PERSON
Salt Lake City
LOCATION
Dexter Lee
PERSON
United States District Court
ORGANIZATION
the University of Utah
ORGANIZATION
S.J. Quinney College of Law
ORGANIZATIONFLSD Docket
ORGANIZATIONAdmissions
ORGANIZATIONthe Federal Rules of Civil
ORGANIZATIONThe Eleventh Circuit
ORGANIZATION
Tom Cotton
PERSONFarmer Jaffe Weissing Edwards
PERSON