Epstein Secrets

Claims Resolution Program in the U.S. Virgin Islands (the "Program"), under which the Estate will make compensatory payments to alleged victims of Jeffrey Epstein. Plaintiffs who participate in the Program and accept payment will be required to release all former employees or potential indemnitees of the Esta

or potential indemnitees of the Estate, including Ms. Maxwell, from any and all claims or causes of action that concern acts of sexual abuse by Mr. Epstein. We understand that, if the Program is approved, it may begin making payments as early as August 2020. Hence, Plaintiff's participation in the Prog

make compensatory payments to alleged victims of Jeffrey Epstein. Plaintiffs who participate in the Progr

s of action that concern acts of sexual abuse by Mr. Epstein. We understand that, if the Program is approved,

announced its "ongoing" criminal investigation into alleged Epstein "co-conspirators" on the same topic as Plaintiff alleges in this case. Kashi v. Gratsos, 790 F.2d 1050, 1057 (2d Cir.1986) (citing SEC v. Dresser Industries, 628 F.2d 1368, 1375 (D.C.Cir.) (en banc), cert. denied, 449 U.S. 993 (1980)) (

ein's properties in New York, Florida, and New Mexico, between approximately 1994 and 1997. As the Indictment details, Maxwell played a key role in Epstein's abuse of minors by helping Epstein to identify, groom, and ultimately abuse underage girls. ' While the Government understands that letters from

rom a scheme to sexually abuse underage girls at Jeffrey Epstein's properties in New York, Florida, and Ne

2015 WL 8207496, at *24 (E.D.N.Y. Dec. 7, 2015). The complaint in this civil action alleges that Maxwell facilitated the sexual abuse of a minor by Jeffrey Epstein in the 1990s. Those allegations will, by definition, touch on matters relating to the pending Indictment. Indeed, based on a review of the civil com

l cases in the interests of justice 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,

ng Ms. Maxwell. Ms. Maxwell is not aware of any such investigation. Indeed, a review of the now more than a decade old police reports involving Mr. Epstein reflects that Ms. Maxwell was not a suspect in any of the activity which resulted in any prosecution of Mr. Epstein. Counsel for Ms. Maxwell have a

rnative, to Stay Proceedings Laura A. Menninger Jeffrey S. Pagliuca GAN, AND FOREMAN, P.C. EFTA00097352

more than a decade old police reports involving Mr. Epstein reflects that Ms. Maxwell was not a suspect in a

civil proceedings pending the completion of parallel criminal prosecutions when the interests of justice seem[ ] to require such action"); Kashi v. Gratsos, 790 F.2d 1050, 1057 (2d Cir. 1986) ("IA] court may decide in its discretion to stay civil proceedings when the interests of justice seem to require