Court Filing: 20-10495
The plaintiff's attorney, David Boies, argues that Ghislaine Maxwell's motion to stay discovery is unwarranted and should be denied. Boies contends that Maxwell's motion to dismiss is not strong and that the court has previously stated that dispositive motions do not typically stay discovery. The plaintiff requests that the court deny Maxwell's anticipated motion to stay discovery.
Summary
The plaintiff's attorney, David Boies, argues that Ghislaine Maxwell's motion to stay discovery is unwarranted and should be denied. Boies contends that Maxwell's motion to dismiss is not strong and that the court has previously stated that dispositive motions do not typically stay discovery. The plaintiff requests that the court deny Maxwell's anticipated motion to stay discovery.
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Case 1:20-cr-00330-AJN Document 191 Filed 03/30/21 Page 1 of 7
Case 1:20-cr-00330-AJN Document 191 Filed 03/30/21 Page 1 of 7 BSF Sigrid S. McCawley BOIES SCHILLER FLEXNER March 22, 2021 VIA EMAIL (FILED UNDER SEAL) The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Rule 17 Subpoena to Boies Schiller Flexner LLP Dear Judge Nathan: I write on behalf of Boies Schiller Flexner LLP ("BSF") with respect to Defendant Ghislaine Maxwell's motion for an order authorizing a subpoena on BSF pursuant to Rule 17(c)(3) of the Federal Rules of Criminal Procedure (the "Subpoena") and the Court's March 12, 2021, Sealed and Ex Pane Order requiring BSF to file a letter indicating (1) whether service on BSF can be deemed adequate notice on victims whose personal or confidential information the Subpoena is aimed at obtaining and (2) whether the victims object to or seek modification of the Subpoena. First, BSF
EXHIBIT C
EXHIBIT C EFTA00095331 Case 1:19-cv-10475-LGS-DCF Document 72 Filed 05/18/20 Page 1 of 3 BSF VIA ECF BOIES SCHILLER FLEXNER The Honorable Debra C. Freeman Daniel Patrick Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: May 18, 2020 v. Darren K. Indyke, Richard D. Kahn, & Ghislaine Maxwell, 19-10475-LGS-DCF Dear Judge Freeman: Pursuant to Individual Rule I.D, Plaintiff hereby responds to Defendant Ghislaine Maxwell's request for a pre-motion conference in connection with her anticipated motion to stay discovery in this matter. The Court should deny Maxwell's motion for a pre-motion conference and deny her anticipated motion in its entirety because, as explained below, each of Maxwell's reasons for staying discovery is meritless and the motion is simply another attempt to unjustifiably delay this litigation. First, a pending criminal investigation of Maxwell does not justify a stay of discovery. "[A] stay of a civil case to permit conc
EFTA00023053
EFTA00011452
Case 1:15-cv-07433-RWS Document 92 Filed 04/11/16 Page 1 of 22
EFTA00024724
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