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iminal proceeding is ever commenced is entirely within the Defendant’s control, by complying with the terms of his Non-Prosecution Agreement with the U.S. Attorney’s Office. Defendant relies upon an amorphous Case 9:08-cv-80994-KAM Document 30 Entered on FLSD Docket 04/23/2009 Page 2 of 9 - 3 - possible br
t “ ‘special circumstances’ so require in the ‘interests of justice.’ ” United States v. Lot 5, Fox Grove, 23 F.3d 359, 365 (11th Cir. 1994). In the Eleventh Circuit, the “special circumstances” which may support a stay are limited. The fact that the Defendant may “risk a non-criminal disadvantage by remaining
iminal proceeding is ever commenced is entirely within the Defendant’s control, by complying with the terms of his Non-Prosecution Agreement with the U.S. Attorney’s Office. Defendant relies upon an amorphous Case 9:08-cv-80119-KAM Document 82 Entered on FLSD Docket 04/23/2009 Page 2 of 9 - 3 - possible br
t “ ‘special circumstances’ so require in the ‘interests of justice.’ ” United States v. Lot 5, Fox Grove, 23 F.3d 359, 365 (11th Cir. 1994). In the Eleventh Circuit, the “special circumstances” which may support a stay are limited. The fact that the Defendant may “risk a non-criminal disadvantage by remaining
ot performing under the terms of the NPA. This tips the balance of equities even further in favor of the plaintiffs. Epstein makes allegations that the U.S. Attorney’s Office has unfettered discretion in determining breaches of the NPA, but this is no different than in any contractual setting. If one party believes that t
, Inc., 866 F. Supp. 536, 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 v. Lot 5, Fox Grove, Alachua County, Fla, 23 F.3d 359, 363- 65 (11th Cir. 1994) (“Lot 5"), the Court articulated the following prin
f the plaintiffs. Epstein makes allegations that the U.S. Attorney’s Office has unfettered discretion in determining breaches
garding stays of civil actions is well-settled in the Eleventh Circuit. In United States v. Lot 5, Fox Grove, Alachua Co
dditional briefs regarding the appropriate remedies. After the court’s order, the Department recused the USAO from the CVRA litigation and assigned the U.S. Attorney’s Office for the Northern District of Georgia to handle the case for the government. Among the remedies sought by the petitioners, and opposed by the gover
Page: 2020_11_OPR_Report_Executive_Summary_p5 →September 30, 2019, CVRA petitioner “Jane Doe 1” filed in her true name a petition for a writ of mandamus in the United States Court of Appeals for the Eleventh Circuit, seeking review of the district court’s order denying all of her requested remedies. In its responsive brief, the government argued that “as a mat
Page: 2020_11_OPR_Report_Executive_Summary_p6 →Entities connected to both the U.S. Attorney’s Office and the Eleventh Circuit

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Bradley Edwards
PERSONJack Goldberger
PERSON
Paul Cassell
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSON
A. Marie Villafana
PERSONMaria Farmer
PERSONFBI
ORGANIZATIONMartin Weinberg
PERSON
Jay Lefkowitz
PERSON
Alan Dershowitz
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSONRobert D. Critton
PERSON
Prince Andrew
PERSON
Adam D. Horowitz
PERSON