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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
in has asked the Court -11- EFTA00222215 Case 9:08-cv-80119-KAM Document 121 Entered on FLSD Docket 05/29/2009 Page 12 of 17 Unlike Wright and Incendy, Epstein also has not been criminally indicted. In some districts, this alone is virtually dispositive. See, e.g., Sterling Nat'l Bank'. A-1 Hotels haernat'
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
money from the defendant. In the context of some of the civil suits currently pending, Epstein has asked the Court EFTA00222771 Unlike Wright and Incendy, Epstein also has not been criminally indicted. In some districts, this alone is virtually dispositive. See, e.g., Sterling Nat'l Bank'. A-1 Hotels Internat
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
n has asked the Court -11- EFTA00602063 Case 9:08-cv-80119-KAM Document 121 Entered on F LSD Docket 05/29/2009 Page 12 of 17 Unlike Wright and Incendy, Epstein also has not been criminally indicted. In some districts, this alone is virtually dispositive. See, e.g., Sterling Nat'l Bank v. A-1 Hotels Interna
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
in has asked the Court -11- EFTA00599152 Case 9:08-cv-80119-KAM Document 121 Entered on FLSD Docket 05/29/2009 Page 12 of 17 Unlike Wright and Incendy, Epstein also has not been criminally indicted. In some districts, this alone is virtually dispositive. See, e.g., Sterling Nat'l Bank v. A-I Hotels Interna
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
pstein has asked the Court -11- EFTA00185216 Case 9:09-cv-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 12 of 17 Unlike Wright and Incendy, Epstein also has not been criminally indicted. In some districts, this alone is virtually dispositive. See, e.g., Sterling Nall Bank'. A-I Hotels Internal
Entities connected to both United States and Incendy, Epstein

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSONWright
PERSONS.D. Fl
LOCATIONFLSD Docket
ORGANIZATIONJANE DOE NO.
PERSONThe First Circuit
ORGANIZATIONMatra
ORGANIZATIONFox Grove
LOCATIONCooke
PERSONMicrofinancial
PERSONLauer
PERSONHakim
PERSONM.D. Fl
PERSONShell Oil Co.
ORGANIZATIONJane Doe Litigation
PERSONSterling National Bank
ORGANIZATION