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

r there are "special circumstances" warranting the imposition of a stay "`to prevent a party from suffering substantial and irreparable prejudice.'" Securites and Exchange Comm' n I. Incendy, 936 F. Supp. 952, 956 (S.D. Fl. 1996) (quoting S.E.C.I First Financial Group of Texas, Inc., 659 F.2d 660, 668 (5th Cir. 1981) (a

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

r there are "special circumstances" warranting the imposition of a stay "`to prevent a party from suffering substantial and irreparable prejudice.'" Securites and Exchange Comm'n I. Incendy, 936 F. Supp. 952, 956 (S.D. Fl. 1996) (quoting S.E.C.I First Financial Group of Texas, Inc., 659 F.2d 660, 668 (5th Cir. 1981) (

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 there are "special circumstances" warranting the imposition of a stay "to prevent a party from suffering substantial and irreparable prejudice." Securites and Exchange Comm 'n v. Incendy, 936 F. Supp. 952, 956 (S.D. Fl. 19%) (quoting S.E.C. v. First Financial Group of Texas, Inc., 659 F.2d 660, 668 (5th Cir. 1981) (