Epstein Secrets

-DCF Document 69 Filed 08/19/20 Page 1 of 6 H A D D O N MORGAN FOREMAN Haddon, Morgan and Foreman, r.c Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FR 303.832.2628 August 19, 2020 VIA ECF Hon. Debra Freeman United States Magistrate Judge Daniel Patrick Moynih

500 Pearl St. New York, NY 10007-1312 Re: Letter Motion to Stay Proceedings 20-cv-484 (JGK-DCF), Jane Doe v. Darren K. Indyke, et aL Dear Judge Freeman: On behalf of defendant Ghislaine Maxwell, I write to Move to Stay proceedings in this matter until the conclusion of her pending criminal case. "[

[email protected] Counsel for Defendants Darren K. Indyke and Richard D. Kahn Laura Menninger, Esq. HADDON MORGAN FOREMAN P.C. 150 E. 10in Avenue Denver, CO 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: [email protected] Counsel for Defendant Ghislaine Maxwell I7 3514-045 Page 17 of

ent from those imposed by the Federal Rules of Civil Procedure, the Local Rules of the Southern District of New York, or Judge Schofield's or Judge Freeman's Individual Rules and Practices. 3. Any objection to any of the Interrogatories is not an admission that Plaintiff has any information or documen

New York, NY 10007-1312 Re: 19-cv- 10475 (LGS-DCF) Dear Judge Freeman: Haddon, Morgan and Foreman. r.c Laura A. MannInger ISO East 10th Avenue 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 Ghislain

Magistrate Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: 19-cv- 10475 (LGS-DCF) Dear Judge Freeman: Haddon, Morgan and Foreman. r.c Laura A. MannInger ISO East 10th Avenue Denver. Colorado 80203 PH 303.831.7364 rx 303.832.2628 www.hmflaw.corn

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counsel for information about the criminal investigation during their meet and confer, Maxwell's counsel refused to provide any details," he added. Freeman agreed Maxwell could potentially incriminate herself by giving a deposition and ordered that she not be required to sit for one as part of the suit.

0 alleged members of Tren de Aragua, a Venezuelan gang with prison origins that has expanded throughout the Americas. According to the article, the Denver field office of U.S. Immigration and Customs Enforcement said on social media that it partnered with the FBI, Drug Enforcement Agency, Bureau of Alc

ack against a Houston Jewish installation. Opinion: Trump's Plan for the Cartels Isn't Tough Enough An opinion piece by the New York Times (02/05, Freeman) stated that Trump is right about the immense power of Mexico's transnational drug cartels and the grave threat they pose to American lives. The aut

tatute 'on its face' does not in itself justify an injunc- EFTA00191804 STOLT-NIELSEN, SA. U.S. 185 Clicas442 Pad 177 Pratte. Circuit noted in Denver, in the absence of a chilling effect on constitutional rights, the adversary system "afford(s) defen- dants, after indictment, a federal forum in

im- ited to post-indictment matters, but also include "lijnvestigative functions carried out pursuant to the preparation of a prose- cutor's case." Freeman on Behalf of the Sanctuary a little, 708 F.2d 442, 443 (9th Cir.1983) (per euriam). See also Atkins v. tanning, 656 F.2d 485, 488-89 (10th Cir. 1