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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
no breach, it has a remedy at law or equity. In this situation, Epstein would be entitled to seek dismissal of the indictment. See United States v. Beeks, 167 Fed. Appx 777 (11th Cir. 2006); United States v. Diaz, 138 Fed. Appx. 965 (9th Cir. 2005); United States v. Davis, 393 F.3d 540 (5th Cir. 2004).
[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
ismissal of the indictment. See United States v. Beeks, 167 Fed. Appx 777 (11th Cir. 2006); United State
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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 Def
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 States, Lot 5, Fox Grove, Alachua County, Fla , 23 F.3d 359, 363-65 (11th Cir. 1994) (" Lot S "), the Court articulated the following principles of law wit
en no breach, it has a remedy at law or equity. In this situation, Epstein would be entitled to seek dismissal of the indictment. See United States' Beeks , 167 Fed. Appx 777 (11th Cir. 2006); United States' Diaz , 138 Fed. Appx. 965 (9th Cir. 2005); United States Davis , 393 F.3d 540 (5th Cir. 2004).
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 Def
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 States, Lot 5, Fox Grove, Alachua County, Fla , 23 F.3d 359, 363-65 (11th Cir. 1994) (" Lot S "), the Court articulated the following principles of law wit
en no breach, it has a remedy at law or equity. In this situation, Epstein would be entitled to seek dismissal of the indictment. See United States' Beeks , 167 Fed. Appx 777 (11th Cir. 2006); United States' Diaz , 138 Fed. Appx. 965 (9th Cir. 2005); United States Davis , 393 F.3d 540 (5th Cir. 2004).
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
en no breach, it has a remedy at law or equity. In this situation, Epstein would be entitled to seek dismissal of the indictment. See United States. Beeks, 167 Fed. Appx 777 (1 I th Cir. 2006); United States. Diaz, 138 Fed. Appx. 965 (9th Cir. 2005); United States'. Davis, 393 F.3d 540 (5th Cir. 2004)
Entities connected to both United States and Beeks

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSON
A. Marie Villafana
PERSONthe Eleventh Circuit
ORGANIZATIONWright
PERSON
the United States Government
ORGANIZATIONS.D. Fl
LOCATION
Lauderdale
LOCATIONJANE DOE NO.
PERSONThe First Circuit
ORGANIZATIONFox Grove
LOCATIONCooke
PERSONJenne
PERSONLauer
PERSON