The following excerpt is from In re Zinnel, Bankruptcy No. 05-28800-C-7, No. 2:12-cv-00249-MCE (E.D. Cal. 2013):
Next, courts consider "the interests of persons not parties to the civil litigation." Keating, 45 F.3d at 325 (citations and internal quotations omitted). The United States, a third party to the bankruptcy appeal, has an interest in an unimpeded criminal investigation that favors a stay. Additionally, it is conceivable that discovery may touch on the Fifth Amendment rights of witnesses who are not parties to the bankruptcy appeal but who may be targets of the criminal investigation. This factor also favors a stay in this case. See Ashworth v. Albers Med., Inc., 229 F.R.D. 527, 532 (S.D.W. Va. 2005).
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