Epstein Secrets

o appear and provide testimony and evidence in accordance with the issued subpoenas at the next meeting of the Grand Jury. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United States Attorne West Palm Beach, FL 33401 Telephone: Facsimile: CERTIFICATE OF SERVICE I HEREBY

rand Jury. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United

facts to state with reasonable certainty that the privilege applies, the burden is not met." United States v. Blackburn , 538 F. Supp. 1376, 1382 (M.D. Fl. 1982) (citing Federal Trade Commission v. TRW Inc. , 628 F.2d 207, 213 (D.C. Cir. 1980); In re Katz , 623 F.2d 122, 125 (2d Cir. 1980); United Stat

not aware of any "special circumstances" that warrant staying all of the civil cases pending the "expiration" of the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United States Attorney 500 East Browar ou evard, 7th Floor Ft. Lauderdale, FL 33394 Telephone: 954-356-72

f the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United St

ceeding does not rise to the level of an unconstitutional infringement.' Id. (quoting Shell Oil Co. v. Altina Assocs., Inc. , 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regarding stays of civil actions is well-settled in the Eleventh Circuit. In United Stat

f the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: _ I I I -16- EF

not aware of any "special circumstances" that warrant staying all of the civil cases pending the "expiration" of the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: _ I I I -16- EFTA00222220 Case 9:08-cv-80119-KAM Document 121 Entered on FLSD Docket 05)29:2009 Page 17 of 17

roceeding does not rise to the level of an unconstitutional infringement.' Id. (quoting Shell Oil Co.l Altina Assocs., Inc., 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regardini stays of civil actions is well-settled in the Eleventh Circuit. In United State

not aware of any "special circumstances" that warrant staying all of the civil cases pending the "expiration" of the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United States Attorne or CERTIFICATE OF SERVICE I HEREBY CERTIFY that on May 28, 2009, I electronically fi

f the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United St

oceeding does not rise to the level of an unconstitutional infringement.' Id. (quoting Shell Oil Co. I Altina Assocs., Inc. , 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regarding stays of civil actions is well-settled in the Eleventh Circuit. In United Stat

not aware of any "special circumstances" that warrant staying all of the civil cases pending the "expiration" of the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: -16- EFTA00222776 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on May 28, 2009, I electronically filed the foregoing

f the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: -16- EFTA00222776

roceeding does not rise to the level of an unconstitutional infringement.' Id. (quoting Shell Oil Co.l Altina Assocs., Inc., 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regardini stays of civil actions is well-settled in the Eleventh Circuit. In United State

not aware of any "special circumstances" that warrant staying all of the civil cases pending the "expiration" of the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: loor CERTIFICATE OF SERVICE I HEREBY CERTIFY that on May 28, 2009, I electronically filed the foregoing document with

f the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: loor CERTIFICATE O

oceeding does not rise to the level of an unconstitutional infringement.' Id. (quoting Shell Oil Co. I Altina Assocs., Inc. , 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regarding stays of civil actions is well-settled in the Eleventh Circuit. In United Stat

not aware of any "special circumstances" that warrant staying all of the civil cases pending the "expiration" of the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: it appears from a brief review of some of Epstein's discovery responses that Epstein has simply made a blanket asserti

f the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: it appears from a b

oceeding does not rise to the level of an unconstitutional infringement.' Id. (quoting Shell Oil Co. I Altina Assocs., Inc. , 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regarding stays of civil actions is well-settled in the Eleventh Circuit. In United Stat

o appear and provide testimony and evidence in accordance with the issued subpoenas at the next meeting of the Grand Jury. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United States Attorney Florida Bar No. 0018255 500 South Australian Avenue, Suite 400 CERTIFICATE OF SERVI

rand Jury. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United St

t facts to state with reasonable certainty that the privilege applies, the burden is not met." United States I Blackburn , 538 F. Supp. 1376, 1382 (M.D. Fl. 1982) (citing Federal Trade Commission I TRW Inc. , 628 F.2d 207, 213 (D.C. Cir. 1980); In re Katz , 623 F.2d 122, 125 (2d Cir. 1980); United State

not aware of any "special circumstances" that warrant staying all of the civil cases pending the "expiration" of the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United States Attorney Florida Bar No. Ft. L 333 Telephone Facsimile: -16- EFTA00599157 Case 9:08-cv-

f the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United St

ceeding does not rise to the level of an unconstitutional infringement.' Id. (quoting Shell Oil Co. v. Altina Assocs., Inc., 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regarding stays of civil actions is well-settled in the Eleventh Circuit. In United State

not aware of any "special circumstances" that warrant staying all of the civil cases pending the "expiration" of the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: ssistant United States Attorne 500 East Broward Boulevard, 7th Floor Ft. Lauderdale, FL 33394 Telephone: Facsimile:

you and your client to agree to unconscionable contract terms cannot square with the true facts of this case. As explained in letters from Messrs. Acosta and Sloman, the indictment was postponed for more than five months to allow you and Mr. Epstein's other attorneys to make presentations to the Offi

oceeding does not rise to the level of an unconstitutional infringement.'" Id. (quoting Shell Oil Co.'. Alan° Assocs., Inc., 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regardii stays of civil actions is well-settled in the Eleventh Circuit. In United States