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e, et al., 1:20-cv-000484-JGK-DCF Plaintiff's Opposition Letter to Defendant Ghislaine Maxwell's Letter Motion to Stay Proceedings Dear Judge Freeman: On behalf of plaintiff Jane Doe in the above-referenced litigation, we hereby submit this opposition to defendant Ghislaine Maxwell's Motion

a related criminal prosecution has been characterized as an "extraordinary remedy." Louis Vuitton Malletier S.A. v. LY USA, Inc., 676 F.3d 83, 98 (2d Cir. 2012) (emphasis added). As a result, a civil defendant urging a stay pending a parallel criminal prosecution bears the burden of establishing its n

Plaintiff's claims against defendant Maxwell—the only actively litigated claims against her currently—to proceed in full public view. Courts in the Second Circuit recognize that the public benefits from civil litigation not only when it advances the justifiable interests of the Plaintiff, but also when the lit

im- ited to post-indictment matters, but also include "lijnvestigative functions carried out pursuant to the preparation of a prose- cutor's case." Freeman on Behalf of the Sanctuary a little, 708 F.2d 442, 443 (9th Cir.1983) (per euriam). See also Atkins v. tanning, 656 F.2d 485, 488-89 (10th Cir. 1

ers, Inc., Petitioners-Ap- pellees, v. UNITED STATES of America, Respondent-Appellant. No. 474, Docket 95-6119. United States Court of Appeals, Second Circuit. Argued Aug. 81, 1996. Decided Oct. 17, 1996. Government appealed from order en- tered in the United States District Court for the Eastern Distri

Indyke, et al., 1:20-cv-000484-JGK-DCF Plaintiff's Opposition Letter to Defendant Ghislaine Maxwell's Letter Motion to Stay Proceedings Dear Judge Freeman: On behalf of plaintiff Jane Doe in the above-referenced litigation, we hereby submit this opposition to defendant Ghislaine Maxwell's Motion to St

a related criminal prosecution has been characterized as an "extraordinary remedy." Louis Vuitton Malletier S.A. v. LY USA, Inc., 676 F.3d 83, 98 (2d Cir. 2012) (emphasis added). As a result, a civil defendant urging a stay pending a parallel criminal prosecution bears the burden of establishing its ne

wing Plaintiffs claims against defendant Maxwell—the only actively litigated claims against her currently—to proceed in full public view. Courts in the Second Circuit recognize that the public benefits from civil litigation not only when it advances the justifiable interests of the Plaintiff, but also when the lit

09/09/2020 SO ORDERED DEBRA FREEMAN United States Magistrate Judge Re: Jane Doe v. Darren It Indyke, et aL, 20 Civ. 484 (DCF) (JGK) Dear Judge Freeman: The Government respectfully submits this letter to request that the Court: (1) permit the Government to intervene in the above-referenced matter f

stice pending the completion of criminal prosecution. See Landis v. North Am. Co., 299 U.S. 248, 255 (1936); Kashi v. Gratsos, 790 F.2d 1050, 1057 (2d Cir. 1986). Courts routinely grant applications to stay civil proceedings in order to protect a pending criminal case. See, e.g., Johnson v. New York Cit

R-330. On September 14, 2020, Magistrate Judge EFTA00029956 --- PAGE BREAK --- Case 1:20-cv-00484-JGK-DCF Document 98 Filed 03/08/21 Page 2 of 8 Freeman issued an order staying this case, pending the outcome of the criminal prosecution of Ms. Maxwell. See ECF No. 8. After the complaint was filed, th

s—including attorney's fees incurred in this action—for the torts of abuse of process and malicious prosecution. Ms. Maxwell is correct that under Second Circuit law, she is the prevailing party for the purposes of Rule 54(d). See Carter v. Inc. Vill. of Ocean Beach, 759 F.3d 159, 165-66 (2d Cir. 2014) (hold