Epstein Secrets

Denver. Colorado 80203 PH 303.831.7364 rx 303.832.2628 www.hmflaw.corn Imenningerathmflaw.com v. Darren K Indyke, et aL On behalf of defendant Ghislaine Maxwell, I write under Judge Schofield's Individual Rules and Procedures for Civil Cases III(A)(1) and this Court's Practices II(A) to request a pre-motion

articipate in the Program and accept payment will be required to release all former employees 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 ma

v. Darren K Indyke, et aL On behalf of defendant Ghislaine Maxwell, I write under Judge Schofield's Individ

2 of 3 Hon. Debra Freeman May 13, 2020 Page 2 Ms. Maxwell has asserted her plan to undertake a vast, broa

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)) (

s%st:Nabl'AgeRMit ebc4R9d21127P, 41M5§03.13arlis§g4 iea 7 App.-0132 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, V. Ghislaine Maxwell, Defendant. X 15-cv-07433-RWS Motion to Compel Plaintiff to Disclose Alleged "On-going Criminal Investigations by Law Enforcement [sic!" or, In

S. Pagliuca GAN, AND FOREMAN, P.C. EFTA00097352 Cgsfist:i§:4-13-1UPSCRCieSt MAR T; 21Wp, Aia5i441111141P1PfiO4 e& 7 App.-0133 INTRODUCTION Ms. Maxwell, through counsel, requests, pursuant to Rules 37( a) and 26(c) of the Federal Rules of Civil Procedure that the Court enter an order requiring Plain

SOUTHERN DISTRICT OF NEW YORK X Plaintiff, V. Ghislaine Maxwell, Defendant. X 15-cv-07433-RWS Motion

5i441111141P1PfiO4 e& 7 App.-0133 INTRODUCTION Ms. Maxwell, through counsel, requests, pursuant to Rules 37(

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

imited purpose of seeking a stay of the action, and (2) stay this matter in its entirety pending the resolution of the criminal prosecution against Ghislaine Maxwell in the matter of United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN). As discussed below, the Government submits that a complete stay of this civil

nt submits that a complete stay of this civil action will serve the public interest of preserving the integrity of the criminal prosecution against Maxwell and will conserve private, public, and judicial resources; and that those interests will outweigh any delay or disruption caused to the resolution o

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,

Judge Nathan held that Maxwell is not entitled to know who the Government's trial witnesses are at this stage of the criminal case. United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN), Dkt. 49. Consistent with that ruling, the Government is not including detailed information in this letter about who thos