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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 Def
540 (M.D. Fl. 1994)). As this Court has previously explained: The law regarding stays of civil actions is well-settled in the Eleventh Circuit. In United States, Lot 5, Fox Grove, Alachua County, Fla , 23 F.3d 359, 363-65 (11th Cir. 1994) (" Lot S "), the Court articulated the following principles of law wit
s that there has been no breach, it has a remedy at law or equity. In this situation, Epstein would be entitled to seek dismissal of the indictment. See United States I Beeks , 167 Fed. Appx 777 (11th Cir. 2006); United States' Diaz , 138 Fed. Appx. 965 (9th Cir. 2005); United States Davis , 393 F.3d 540 (5th Cir.
ty from suffering substantial and irreparable prejudice."' Securites and Exchange Comm'rz 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) (add'I citations omitted). Examples of "special circumstances" provided by the Supreme Court in
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 Def
540 (M.D. Fl. 1994)). As this Court has previously explained: The law regarding stays of civil actions is well-settled in the Eleventh Circuit. In United States, Lot 5, Fox Grove, Alachua County, Fla , 23 F.3d 359, 363-65 (11th Cir. 1994) (" Lot S "), the Court articulated the following principles of law wit
rty from suffering substantial and irreparable prejudice."' Securites and Exchange Comm'n 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) (add'I citations omitted). Examples of "special circumstances" provided by the Supreme Court in
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 Def
540 (M.D. Fl. 1994)). As this Court has previously explained: The law regarding stays of civil actions is well-settled in the Eleventh Circuit. In United States, Lot 5, Fox Grove, Alachua County, Fla , 23 F.3d 359, 363-65 (11th Cir. 1994) (" Lot S "), the Court articulated the following principles of law wit
rty from suffering substantial and irreparable prejudice."' Securites and Exchange Comm'n 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) (add'I citations omitted). Examples of "special circumstances" provided by the Supreme Court in
Entities connected to both United States and S.E.C.I First Financial Group

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSONthe Eleventh Circuit
ORGANIZATIONWright
PERSONS.D. Fl
LOCATIONJANE DOE NO.
PERSONThe First Circuit
ORGANIZATIONFox Grove
LOCATIONCooke
PERSONLauer
PERSONShell Oil Co.
ORGANIZATIONM.D. Fl
PERSONMicrofinancial
PERSONAlachua County
LOCATIONMicrofinancial, Inc.
ORGANIZATIONJane Doe Litigation
PERSONJOHNSON DE 51-1
ORGANIZATION