Case 9:08-cv-80994-KAM Document 44 Entered on FLSD Docket 05/13/2009 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80994-MARRA/JOHNSON JANE DOE NO. 6, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant. Jeffrey Epstein's Reply to Plaintiff's Response In Opposition To Defendant's Motion To Stay And/Or Continue Action For Time Certain With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby files his Reply to Plaintiffs Response In Opposition to Defendant's Motion to Stay and/or Continue Action, and states: I. Introduction and Argument Plaintiffs Response in Opposition challenging the stay should not prevail when 5th Amendment principles are at issue and when there exists a real, substantial and not remote possibility that Epstein may face criminal prosecution by the United States Attorneys' Office ("USAO") if the USAO unilaterally determines that Epstein somehow violated that certain Non-Prosecution Agreement dated June 30, 2008 ("NPA") and/or if Epstein is forced to waive those e Amendment rights and participate in civil discovery in order to defend this civil action. Epstein should not be confronted with the substantial risk of loosing this civil action by virtue of asserting his 5th Amendment privileges. Despite Plaintiffs contention, Epstein's Motion does not concentrate solely on the fact that the pleadings are not at EFTA02742867