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Case
Case 9:09-cv-80656-KAM
9:08-cv-8 Document
0811-KAM Docume 11-1Entered
nt 51-1 EnteredononFLSD
FLSDDocket
Docket03/24/2009 Page
05/14/2009 of 15
Page 11 of 24
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80811-MARRA/JOHNSON
C.M.A.,
Plaintiff,
v.
JEFFREY EPSTEIN and SARAH
KELLEN,
Defendants,
---- ---- ---- --I
Defendant, Jeffrey Epstein's Motion To Stay And Or Continue Action For Time Certain Based On
Parallel Civil And Criminal Proceedings With Incorporated Memorandum Of Law
Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his
undersigned attorneys, hereby moves this Court for the entry of an order staying or continuing
this action for a time certain (i.e., until late 2010 when the NP A expires), pursuant to the
application of the Fifth Amendment of the U.S. Constitution and the fact that a parallel
proceeding is ongoing and being investigated. In support of his motion, EPSTEIN states:
I. Introduction
At the outset, EPSTEIN notes this Court's prior Order, dated December 16, 2008,
(Document 28), in which this Court denied a motion for stay brought by Defendant's prior
counsel. In that instance, Defendant's counsel requested a mandatory stay under 18 U.S.C.A.
§3509(k) which the court denied. In denying the request for the stay, this Court stated that a
discretionary stay was not appropriate at t
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