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

d improperly, he could file a motion to suppress or to dismiss the indictment in that criminal action. See, e.g., United States, ex. rel. Westrickl Second Chance, 2007 WL 1020808 *4 (D.D.C. Mar. 31, 2007) (Defendant in civil False Claims Act suit moved to stay civil action pending criminal -10- EFTA00222770

[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

. See, e.g., United States, ex. rel. Westrick v. Second Chance, 2007 WL 1020808 *4 (D.D.C. Mar. 31, 2007) (Defen

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

improperly, he could file a motion to suppress or to dismiss the indictment in that criminal action. See, e.g., United States, ex. rel. Westrick v. Second Chance, 2007 WL 1020808 *4 (D.D.C. Mar. 31, 2007) (Defendant in civil False Claims Act suit moved to stay civil action pending criminal Case 9:08-cv-80119-K