Court Filing: 920
The plaintiff argues that Ghislaine Maxwell has not provided sufficient information about the criminal investigation to justify staying discovery, and that the potential claims resolution program does not require staying discovery in this case. The court has previously recognized that discovery may be necessary to inform the claims resolution program.
Summary
The plaintiff argues that Ghislaine Maxwell has not provided sufficient information about the criminal investigation to justify staying discovery, and that the potential claims resolution program does not require staying discovery in this case. The court has previously recognized that discovery may be necessary to inform the claims resolution program.
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EFTA Document EFTA01654937
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
EFTA00024724
Memorandum and Order: 20cv00484 (JGK) (DF)
The document is a Memorandum and Order from U.S. Magistrate Judge Debra Freeman granting Ghislaine Maxwell's motion to stay the civil proceedings against her and others pending the resolution of her criminal trial. Maxwell is currently in custody awaiting trial on July 12, 2021. The civil case involves allegations of sexual abuse and exploitation against Maxwell and the executors of Jeffrey Epstein's estate.
EFTA00026735
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
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