Epstein Secrets

submits that it should be as to the entire action and not just as to discovery directed to defendant Maxwell as counsel pointed out was the case in Farmer v. Indyke, 19-cv-10475-LGS-DCF. Otherwise, defendant Maxwell would be given the unfair advantage of collecting evidence from others and taking par

pectfully requests that the Court deny defendant Maxwell's request to stay this case. Respectfully submitted, PANISH SHEA & BOYLE /s/ Robert Glassman Robert Glassman cc: All counsel of record Case 1:20-cv-00484-JGK-DCF Document 78 Filed 08/27/20 Page 6 of 6 PANISH

other lawsuits, including a case brought by Annie Farmer, were EFTA01654942 scheduled to depose him, bu

hip with Plaintiff while she was a minor and even acted on Jeffrey Epstein's behalf to communicate with Plaintiff on several occasions," the lawyer Robert Glassman wrote to U.S. District Judge Debra Freeman, responding to the estate's push to delay the under-oath grilling. Doe also plans to depose Kahn. In an

submits that it should be as to the entire action and not just as to discovery directed to defendant Maxwell as counsel pointed out was the case in Farmer v. Indyke, 19-cv-10475-LGS-DCF. Otherwise, defendant Maxwell would be given the unfair advantage of collecting evidence from others and taking part

laintiff respectfully requests that the Court deny defendant Maxwell's request to stay this case. Respectfully submitted, PANISH SHEA & BOYLE /s/ Robert Glassman Robert Glassman cc: All counsel of record EFTA00016291