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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
1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "merely the loss of the defendant's most `effective defense.' Securities & Exchange Comm.'. Incendy, 936 F. Supp. at 955 (S.D. Fl. 1996); Shell Oil Co., 866 F. Supp. at 540-41. Court-Appointed Receiver of Lancer Mgt. Group LLCI. Lauer,
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
1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "merely the loss of the defendant's most `effective defense.' Securities & Exchange Comm.'. Incendy, 936 F. Supp. at 955 (S.D. Fl. 1996); Shell Oil Co., 866 F. Supp. at 540-41. Court-Appointed Receiver of Lancer Mgt. Group LLCI Lauer. 2
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
1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "merely the loss of the defendant's most 'effective defense.'" Securities & Exchange Comm. v. Incendy, 936 F. Supp. at 955 (S.D. F1.1996); Shell Oil Co., 866 F. Supp. at 540-41. Court-Appointed Receiver of Lancer Mgt. Group LLC v. Lauer,
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
1996); Penis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "merely the loss of the defendant's most 'effective defense.'" Securities & Exchange Comm. v. Incendy, 936 F. Supp. at 955 (S.D. F1.1996); Shell Oil Co., 866 F. Supp. at 540-41. Court-Appointed Receiver of Lancer Mgt. Group LLC v. Lauer,
Entities connected to both United States and Securities & Exchange Comm

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSONWright
PERSONS.D. Fl
LOCATIONJANE DOE NO.
PERSONThe First Circuit
ORGANIZATIONMatra
ORGANIZATIONFox Grove
LOCATIONCooke
PERSONLauer
PERSONMicrofinancial
PERSONHakim
PERSONShell Oil Co.
ORGANIZATIONSterling National Bank
ORGANIZATIONM.D. Fl
PERSONJane Doe Litigation
PERSONAlachua County
LOCATION