Epstein Secrets

542075 E-mail: GG5cc EFTA00722655 Case 9:08-cv-80893-KAM Document 30 Entered on FLSD Docket 04/09/2009 Page 2 of 3 Case No.: 08-CIV-80893 — MARRA/JOHNSON DATED: April 9, 2009 Respectfully Submitted, Plaintiff, by One of Her Counsel, s/ Bradley J. Edwards Bradley J. Edwards IN ROSENFELDT A

ion for Time Certain Based on Parallel Civil and Criminal Proceedings with Incorporated Memorandum of Law. DONE AND ORDERED this day of , 2009. KENNETH A. MARRA United States District Judge Copies to all Counsel of Record EFTA00722686 Barbara McKenna From: Sent: .ay, l'Alltiblitaliklattlic To: fisd_

Doe. Such risk and speculation about possible criminal charges does not establish a real need for a stay. See Securities and Exchange Commission v. Dresser Industries, Inc., 628 F.2d 1368, 1376 (D.C. Cir. 1980) (refusing to grant a stay a civil proceeding before any indictment was returned because Fifth Amendment conce

ERN DISTRICT OF FLORIDA Case No.: 08-CIV-80893 - MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTE

Doe. Such risk and speculation about possible criminal charges does not establish a real need for a stay. See Securities and Exchange Commission v. Dresser Industries, Inc., 628 F.2d 1368, 1376 (D.C. Cir. 1980) (refusing to grant a stay a civil proceeding before any indictment was returned because Fifth Amendment conce

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, Vs.

al transcripts, `the strategy or direction of the investigation, the deliberations or questions of jurors, and the like."' Id. at 500, citin SEC v. Dresser Industries, Inc., 628 F.2d 1368, 1382 (D.C. Cir. I SDFL lOP 8.01.00 provides: "Grand jury matters, and all matters reasonably related to the original grand jury mat

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioner

on by the court in the internal affairs of the Justice Department would clearly constitute a violation of the Separation of Powers doctrine." Id. In Dresser Industries, Inc. v. United States, 596 F.2d 1231, 1237 (51h Cir. 1979), the court of appeals observed that "[t]he decision to prosecute is largely unreviewable by t

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioner

n by the court in the internal affairs of the Justice Department would clearly constitute a violation of the Separation of Powers doctrine." Id. In Dresser Industries, Inc. v. United States, 596 F.2d 1231, 1237 (511' Cir. 1979), the court of appeals observed that "[t]he decision to prosecute is largely unreviewable by

UTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 I. UNITED S

n by the court in the internal affairs of the Justice Department would clearly constitute a violation of the Separation of Powers doctrine." Id. In Dresser Industries, Inc." United States, 596 F.2d 1231, 1237 (5' Cir. 1979), the court of appeals observed that "[t]he decision to prosecute is largely unreviewable by the