Epstein Secrets

ble Debra C. Freeman May 18, 2020 Page 2 Further, Maxwell has provided no information about the subject matter of the criminal investigation into Epstein's co-conspirators, the status of the investigation, or even disclosed whether she herself is a target of the Southern District's investigation. When

gh her criminal conduct would be directly at issue in that case, and the case would require discovery concerning such conduct. Maxwell v. Estate of Jeffrey E. Epstein, et at, ST-20-CV-155 (V.I. Super. Ct.); Willie v. Amerada Hess Corp., 66 V.I. 23, 92 (Super. Ct. 2017) (common law indemnification is only available

ry concerning such conduct. Maxwell v. Estate of Jeffrey E. Epstein, et at, ST-20-CV-155 (V.I. Super. Ct.);

ry concerning such conduct. Maxwell v. Estate of Jeffrey E. Epstein, et at, ST-20-CV-155 (V.I. Super. Ct.); W

ivil 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) (internal quotation marks omitted). In this Circuit, courts balance the following six factors when considering whet

413 United States Court of Appeals for the Second Circuit Plaintlff-Appelke, —against— GHISLA1NE MAXWELL, Defendant-Appellant, SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA Intervenors. ON APPEAL FROM TH

and sexual trafficking of minors. Her lawyers intended to prove the defamation claim solely by, in effect, "prosecuting" Ms. Maxwell as a proxy for Epstein. App. p 116, ¶ffil 8-10; p 119 9¶ 27; p 122, ¶ 12; p 123, 51114, 16; p 124,9120. 3 EFTA00075485 Case 20-2413, Document 40, 08/20/2020, 2913550, P

MAXWELL, Defendant-Appellant, SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD

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

a stay will "harm plaintiff's interests," she fails to explain why. Ipse dixit aside, Plaintiff correctly explains that she can participate in the Epstein claims program while simultaneously pursuing this civil action and (apparently) advancing her interests through the Criminal Case. But she does not

Maxwell, and the truth, from participating. With Mr. Epstein dead and Ms. Maxwell, literally, handcuffed, the

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

e in order to "pursue a civil remedy in the Epstein Claims Resolution Program." She argues that Plaintiff is "inexplicably the only of the numerous Epstein plaintiffs in this Court to not agree to such a stay" and that "a stay also would permit [Plaintiff] the opportunity to [participate in the Epstein

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

damaging effects that abuse has had and continue to have on Plaintiff. Simply put, a stay would harm—not benefit—Plaintiffs interests. For too long Jeffrey Epstein and Ghislaine Maxwell skirted the consequences of their vile acts. Now, Plaintiff brings this suit, as is her right by law, to hold the Epstein Esta

rm—not benefit—Plaintiffs interests. For too long Jeffrey Epstein and Ghislaine Maxwell skirted the conseq

20 Cr. 330 (MN) Haddon, Morgan and Foreman, t.c Jeffrey Paglloca 150 East 10th Avenue Denver, Colorado

nying as "untrue" and "obvious lies'as allegations that Ms. Maxwell participated in a scheme causing her to be "sexually abused and trafficked" by Jeffrey Epstein. Given the amount of personal, confidential material and information sought in discovery, the district court entered a stipulated Protective Order

arrested Ms. Maxwell. On July 8, the government filed a superseding indictment alleging that Ms. Maxwell "assisted, facilitated, and contributed" to Epstein's abuse of minors. Regarding the civil action, the indictment alleges that in 2016 Ms. Maxwell made "efforts to conceal her conduct" by "repeatedly