Epstein Secrets

r. 1987) 37, 40 In re Teligent, Inc., 640 F.3d 53 (2d Cir. 2011) 1 Joy v. North, 692 F.2d 880 (2d Cir. 1982) 22 Louis Vuitton Malletier S.A. v. LY USA, Inc., 676 F.3d 83 (2d Cir. 2012) 34 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) 19, 21 Maldanado v. City of New York, Case No. 17

ation in opposition. That 11 can be unsealed in full because there is no material included 12 in the caveats in the document. 13 185-2. Copy of Jane Doe's no. 3 and 4 corrected 14 joinder motion. Already filed in public. 15 185-3. Response to the motion to intervene. Already 16 filed in public. 1

ed in full because there are no -- there is no material within the caveat in the document. 165-3. Exhibit C. This is a copy of a motion to join in Jane Doe 1 and Jane Doe 2 files in court. That document is SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00075533 Case 20-2413, Document40,08/20/202

case simply because she has been indicted." Resp. at 6. The Second Circuit has a litany of factors, articulated in Louis Vuitton Malletier S.A. v. LY USA, Inc., 676 F.3d 83, 96 (2d Cir. 2012), and applied numerous times since. Plaintiff has not identified any case applying the Louis Vuitton factors in which

n United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: Reply in Support of Letter Motion to Stay Proceedings 20-cv-484 (JGK-DCF), Jane Doe v. Darren K. Indyke, et at Dear Judge Freeman: On behalf of defendant Ghislaine Maxwell, I write in further support of a Motion to Stay Proceeding

K-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 Stay. INTRODUCTION On August 19, 2

vil case to permit conclusion of 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 bu

July 2016. A year later and literally days before trial, the parties agreed to a settlement of the defamation claim and the case was dismissed. The Jane Doe 43 matter On January 26, 2017, plaintiff Jane Doe 43 sued various individuals including Ms. Maxwell. A Protective Order substantially similar to th

gs when related criminal proceedings are imminent or pending, and it will sometimes be prudential to do so" (quoting Louis Vuitton Ma!leder S.A. v. LY USA, Inc., 676 F.3d 83, 98 (2d Cir. 2012))). Among other things, the stay vindicates the Fifth Amendment and guards against witnesses learning information in