Epstein Secrets

e #1 and Jane Doe #2. SE Jane Does 1 and 2 1 United States Case No. 08-80736-CIV-MARRA United States District Court, Southern District of Florida Bradley Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman Paul G. Cassell EFTA00205480 Attorneys for Jane Doe # I and Jane Doe # 2 Although the Respo

rict Court, Southern District of Florida Bradley Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehr

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

ICE LIST Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA EFTA00205491 United States District Court, Southern District of Florida Bradley Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman Fort Lauderdale, FL 33301-3268 Paul G. Cassell S.J. Quinney College of Law at the Salt Lake

rict Court, Southern District of Florida Bradley Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehr

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

ATTORNEY SERVICE LIST Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA United States District Court, Southern District of Florida Bradley Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 [Service via CM/ECF] Paul G. Cassell S

rict Court, Southern District of Florida Bradley Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrm

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

ATTORNEY SERVICE LIST Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA United States District Court, Southern District of Florida Bradley Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 [email protected] 954-524-2820 F

rict Court, Southern District of Florida Bradley Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrm

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

pondent's motion to dismiss is both meritorious and potentially case-dispositive. On November 7, 2011, Respondent's counsel attempted to confer with Brad Edwards, Petitioners' counsel, regarding Petitioners' position on this motion, but was unable to do so. DATED: November 7, 2011 Respectfully submitted, WI

espondent's counsel attempted to confer with Brad Edwards, Petitioners' counsel, regarding Petitioners' po

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