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, Plaintiff respectfully requests that she be allowed to move forward. The sixteen cases currently pending against the Estate of Jeffrey Epstein in the Southern District of New York are all in very different stages of litigation. Two cases have already been stayed by agreement of the parties. Doe 1 et a! v. Jeffrey E
States District Court Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 The Honorable Debra Freeman United States District Court Southern District of New York Daniel Patrick Moynihan Courthouse 500 Pearl Street New York, NY 10007 Re: Doe v. I
ty of perjury the truth of the facts set forth herein: 1. I am an Assistant United States Attorney in the Office of the United States Attorney for the Southern District of New York and am familiar with the investigation underlying this request. I respectfully submit this application under 18 U.S.C. § 2705(b) for an
closure obligations in any prmentions related to this matter. Dated: New York, New York cfp, )2Ui8 SiDebra UNITED STATES MAOISMATE JUDGE I , Debra Freeman United States Magistrate Judge sonihurn District of Now York EFTA00152436 Grand Jury Subpoena Prtitekratatez jai strict Gaud SOUTHERN DISTRICT
iled by Earlier this month, Maxwell's lawyer, Laura Menninger, asked the federal judge to stay Maxwell's deposition. `The U.S. Attorney's Office in the Southern District of New York has publicly and repeatedly announced its "ongoing" criminal investigation into alleged Epstein "co-conspirators" on the same topic as
riminal case against her in the future. `I'm permitting her not to respond to (written questions) and not to have her deposition,' Magistrate Judge Debra Freeman said during her ruling. `Not forever, but at least long enough to let us know whether the claims process is likely to go forward.' Fox News adds, "T
will impose undue burden and expense on Ms. Maxwell and may well be wholly unnecessary in just a few months. Second, the U.S. Attorney's Office in the Southern District of New York has publicly and repeatedly announced its "ongoing" criminal investigation into alleged Epstein "co-conspirators" on the same topic as
Case 1:19-cv-10475-LGS-DCF Document 68 Filed 05/13/20 Page 1 of 3 H A D D O N MORGAN FOREMAN May 13, 2020 VIA ECF Hon. Debra Freeman United States Magistrate Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: 19-cv- 10475 (LGS-DC
Entities connected to both the Southern District and Debra Freeman

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
New York
LOCATIONLeon Black
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSON
Donald Trump
PERSON
Bill Clinton
PERSON
U.S. Virgin Islands
LOCATION
Marc Rich
PERSON
Michael Cohen
PERSON
Audrey Strauss
PERSON
David Boies
PERSONFederal Bureau of Prisons
ORGANIZATION
Harvey Weinstein
PERSON
William Barr
PERSON