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                                                            IN THE CIRCUIT COURT OF THE
                                                            15TH JUDICIAL CIRCUIT IN AND
                                                            FOR PALM BEACH COUNTY, •
                                                            FLORIDA




                                                                            PY
                                                                   CO
 STATE,

 vs.

 EPSTEIN, JEFFREY E,




                                                            D
                        Defendant.
                                                     IE
                                              IF
 -------------"--------'/

                    INTERVENER'S RESPONSE TO MOTION TO STAY
                                     RT

                      AND SUPPORTING MEMORANDUM OF LAW

         COMES NOW, Intervener-and files this Response to Defendant Jeffrey Epstein's
                                CE



, Motion to Stay, and states:

        In their motion, Defendant asks the Court to stay its ruling on the production of the NPA
                      A




 agreement pending review by the Fourth DCA. Since this NPA was never properly sealed in the
            T




.first place, a Stay is improper because this document is a public record until such time as it has
           O
       N




been properly sealed. Furthermore, as Defendant EPSTEIN has failed to demonstrate that he is

likely to succeed on .the merits of his appeal or describe how he will be harmed by this

disclosure, Intervenerllll respectfully requests the Court deny their Motion.

        Pursuant to Florida Rule of Appellate Procedure 9.310(a), a trial court has the discretion

to enter a stay pending interlocutory review of a non-final order. The burden to satisfy the
 requirements for a stay rests with the party requesting the stay. A trial court is not obligated, or.

 even encour

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