Epstein Secrets

esting 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 necessary and was not contemplated by the Non-Prosecution Agreement between the United States and De

ted States, by and through the undersigned 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 o

this standard, Movants must show that invocation of the privilege in the instant matter will result in certain loss by automatic summary judgment. United Stalest Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "me

her unfair injury; or (4) any other special circumstances indicating unconstitutionality or even impropriety. Incendy at 956 (citing United States. Kordel, 397 U.S. 1, 11 (1970)). See also Securities and Exchange Comm' n I Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o `special circumstanc

esting 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 necessary and was not contemplated by the Non-Prosecution Agreement between the United States and De

ted States, by and through the undersigned 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 o

this standard, Movants must show that invocation of the privilege in the instant matter will result in certain loss by automatic summary judgment. United Stalest Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "me

her unfair injury; or (4) any other special circumstances indicating unconstitutionality or even impropriety. Incendy at 956 (citing United States. Kordel, 397 U.S. 1, 11 (1970)). See also Securities and Exchange Con:nen, Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o `special circumstances'

questing 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 necessary and was not contemplated by the Non-Prosecution Agreement between the United States and Defe

forth in the contract. If the other party believes that Case 9:08-cv-80119-KAM Document 121 Entered on FLSD Docket 05/29/2009 Page 13 of 17 5The United States also notes that this finite termination to Epstein’s exposure to potential criminal consequences is illusory. The NPA addresses only certain victims

659 F.2d 660, 668 (5th Cir. 1981) (add’l citations omitted). Examples of “special circumstances” provided by the Supreme Court in [United States v. Kordel] are: (1) if the Government brought the civil action solely to obtain evidence for its criminal prosecution, (2) if the Government failed to advise t

[DE 99]. For the reasons set forth below, it is the United States’ position that a stay of the proceedings is not ne

tered on FLSD Docket 05/29/2009 Page 13 of 17 5The United States also notes that this finite termination to Epstei

rovided by the Supreme Court in [United States v. Kordel] are: (1) if the Government brought the civil act

uesting 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 necessary and was not contemplated by the Non-Prosecution Agreement between the United States and De

ted States, by and through the undersigned 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

her unfair injury; or (4) any other special circumstances indicating unconstitutionality or even impropriety. Incendy at 956 (citing United States' Kordel, 397 U.S. I, 11 (1970)). See also Securities and Exchange Comm'nl. Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o 'special circumstances'

ar that the 2008 deal in Florida did not apply. "The agreement, by its terms, only binds the Southern District of Florida," Geoffrey S. Berman, the United States attorney in Manhattan, said on Monday. The indictment marked the downfall of a man who had, until then, been dogged for years by allegations that he

evidence for its criminal prosecution," or (2) "fail to advise the defendant in its civil proceeding that it contemplates his criminal prosecution." Kordel, 397 U.S. at 11-12 (emphasis added). In Kordel, a corporate executive was convicted of violating the Food, Drug, and Cosmetic Act partly on the basi

ar that the 2008 deal in Florida did not apply. "The agreement, by its terms, only binds the Southern District of Florida," Geoffrey S. Berman, the United States attorney in Manhattan, said on Monday. The indictment marked the downfall of a man who had, until then, been dogged for years by allegations that he

evidence for its criminal prosecution," or (2) "fail to advise the defendant in its civil proceeding that it contemplates his criminal prosecution." Kordel, 397 U.S. at 11-12 (emphasis added). In Kordel, a corporate executive was convicted of violating the Food, Drug, and Cosmetic Act partly on the ba