Epstein Secrets

o Dismiss [DE129] and Response in Opposition to Petitioners' Protective Motion to Compel [DE 130]. For the following reasons, the Court should grant the United States' Motion to Stay Discovery pending the Court's decision on the United States' Motion to Dismiss for Lack of Subject Matter Jurisdiction and, similarl

including significant public resources. Under such circumstances, a stay of proceedings is warranted and appropriate. See, generally , Chudasama v. Mazda Motor Corp. , 123 F.3d 1353, 1367-68 (11th Cir. 1997) (approving judicial intervention and resolution of claims-dispositive issues before proceedings continue

to Dismiss; and (2) deny Petitioners' Protective Motion to Compel. If the Court should deny either the United States' Motion to Stay Discovery or the United States' Motion to Dismiss, then the United States respectfully requests that it be allowed thirty (30) days following the entry of the earlier of any such o

client as to which documents should be disclosed and which ones withheld, and determining whether certain information is privileged. Chudasama v. Mazda Motor Corp., 123 F.3d 1353, 1367 (11th Cir. 1997) (citations omitted). See also Moore v. Potter, 141 Fed. Appx. 803, 807-08 (11th Cir. 2005) (quoting Chudasama

to Dismiss; and (2) deny Petitioners' Protective Motion to Compel. If the Court should deny either the United States' Motion to Stay Discovery or the United States' Motion to Dismiss, then the United States respectfully requests that it be allowed thirty (30) days following the entry of the earlier of any such o

client as to which documents should be disclosed and which ones withheld, and determining whether certain information is privileged. Chudasama v. Mazda Motor Corp., 123 F.3d 1353, 1367 (11th Cir. 1997) (citations omitted). See also Moore v. Potter, 141 Fed. Appx. 803, 807-08 (11th Cir. 2005) (quoting Chudasama