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

of discovery. "[A] stay of a civil 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

eople who achieve great power and wealth, JeffIre]y Epstein exploited the Halo effect to surround himself wi

eliable evidence through a witness plainly incompetent to do so. None of the charges in this case relate in any way to the defendant's appraisal of Jeffrey Epstein's character or whether the defendant did or did not view him in the manner suggested by the Halo effect. Simply put, if every word that Dr. Dietz said

notes that "Dr. Dietz is also prepared to address Jeffrey Epstein's sexual behavior should it prove releva

, 2015)28 LaSalle Bank Nat'l ASS)! v. CIBC Inc., No. 08 Civ. 8426 (WHP) (HBP), 2012 WL 466785 (S.D.N.Y. Feb. 14, 2012) 8 LVL XIII Brands, Inc. v. Louis Vuitton Malletier S.A., 209 F. Supp. 3d 612 (S.D.N.Y. 2016)8, 21, 23 Marx & Co. v. Diners Club, Inc., 550 F.2d 505 (2d Cir. 1977) 8 Nimely v. City of New York, 414 F.3d

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

k Times Co., 828 F.2d 110 (2d Cir. 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 Y

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

an "absolute right to stay this 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

y in the Epstein Claims Resolution Program, yet a stay also would permit her the opportunity to do so. She is inexplicably the only of the numerous Epstein plaintiffs in this Court to not agree to such a stay. While Plaintiff's counsel refuses to state whether his client is one of the three accusers in

an "ongoing" criminal investigation into alleged Jeffrey Epstein co-conspirators and on that plaintiff's s

esting a stay of discovery as to her, based on the U.S. Attorney's Office's public proclamation of an "ongoing" criminal investigation into alleged Jeffrey Epstein co-conspirators and on that plaintiff's stated intent to participate in the Voluntary Claims Resolution Program in the U.S. Virgin Islands. v. Indy

in every court to control the disposition of the causes on its docket with economy of time and effort for itself, for counsel, and for litigants." Louis Vuitton Malletier S.A. v. LY USA, Inc., 676 F.3d 83, 96 (2d Cir. 2012) (citations omitted). Courts in this District balance the following six factors when considering whe