Epstein Secrets

scovery in this matter ends in less than two months, and we respectfully submit that her delay tactics should end now. Respectfully submitted, /s/ David Boies David Boies, Esq. cc: Counsel of Record (via ECF) 2 Maxwell also argues that the fact that Plaintiff's sister (and a few other victims) have volun

ment 72 Filed 05/18/20 Page 1 of 3 BSF VIA ECF BOIES SCHILLER FLEXNER The Honorable Debra C. Freema

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

Defendant. x 9 New York, N.Y. 10 July 23, 2020 11:30 a.m. 11 Before: 12 HON. LORETTA A. PRESKA, 13 District Judge 14 APPEARANCES 15 BOIES, SCHILLER & FLEXNER, LLP 16 Attorney for Plaintiff BY: SIGRID S. MCCAWLEY 17 HADDON, MORGAN, AND FOREMAN, P.C. 18 Attorney for Defendant BY:

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

cally the 90,000 pages of documents received from Boies Schiller & Flexner, which appears to include the

gs when related criminal proceedings are imminent or pending, and it will sometimes be prudential to do so" (quoting Louis Vuitton Ma!leder S.A. v. LY USA, Inc., 676 F.3d 83, 98 (2d Cir. 2012))). Among other things, the stay vindicates the Fifth Amendment and guards against witnesses learning information in