EPSTEIN - 5-31-09 I JE has attempted to fulfill his obligations under the NPA, intends not to commit a "breach" of the NPA, yet there remains an imminent risk that any defense to the pending 2255 claims will result in an attempt by the USAO to indict him for breach of the NPA thus a stay should be granted so JE is not forced to forego his rights as a civil litigant in order to avoid the irreparable injury of a federal criminal indictment A. JE has faithfully complied with his obligations under the NPA I. JE has waived all motions and appeals and plead guilty to State criminal charges and their concomitant, mandatory registration as a sex offender, all as required by par 1 and 5 of the NPA, none of which he would have agreed to absent the benefits and protections conferred by the NPA; 2. JE was sentenced in conformity with par 2 of the NPA and has been in the custody of the Sheriff of Palm Beach County since June 30, 2008, serving a county jail sentence as required by par 2(a) of the NPA, to be followed by a successive period of community control as required by par 2(b) of the NPA; 3. JE was required by the NPA to convinceurge that-the State to charge him with an additional felony, though facts were never provided that would require sex registration and, to conform with the NPA, he did so and was so charged 4. JE has paid 163 ,992 $ towards the fees and costs of an attorney representative, and has been billed an additional 223000 by Robert Josefsburg, as required by par 7B of the Addendum to the NPA; 5. JE has settled 3 cases brought by persons who were, on a secret list given to Espteins counsel to be disclosed only after he was already in jail. with neither substantion nor details, with women identified by the Government as "victims" as defined by 18 USC 2255, each for the statutory damage amount of $50,000 even though at least one of the three, Ms S.P., was unknown to JE. The settlement with S.P. ( we were told she did not want