EFTA00016286.pdf

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Source set: data-set-8
Extracted text

Case 1:20-cv-00484-JGK-DCF Document 78 Filed 08/27/20 Page 1 of 6 
PANISH 
SHEA & 
BOYLE, I, 
August 27, 2020 
VIA ECF 
Hon. Debra C. Freeman 
Daniel Patrick Moynihan 
United States Courthouse 
500 Pearl Street 
New York, NY 10007 
Re: 
Doe v. Indyke, et al., 1:20-cv-000484-JGK-DCF 
Plaintiff's Opposition Letter to Defendant Ghislaine Maxwell's Letter Motion 
to Stay Proceedings 
Dear Judge Freeman: 
On behalf of plaintiff Jane Doe in the above-referenced litigation, we hereby submit this 
opposition to defendant Ghislaine Maxwell's Motion to Stay. 
INTRODUCTION 
On August 19, 2020, defendant Maxwell wrote to this Court requesting that it stay this 
case until the conclusion of her pending criminal case in which she is accused of recruiting and 
enticing minors to travel to engage in illegal sex acts. The trial in that case is not currently 
scheduled to commence until July of 2021. 
Defendant Maxwell's leading argument in support of her request is that she is unable to 
defend herself in this case while she is in jail and awaiting trial in the criminal case. Prior to 
filing her request to halt these proceedings, however, defendant Maxwell, through her counsel, 
filed her answer to Plaintiffs complaint over one month ago, participated in a case management 
conference with the Court on August 5 and has engaged in numerous email exchanges and phone 
calls with the other parties concerning setting depositions and case deadlines. Moreover, even 
after asking the Court to stay this case on August 19 because it would purportedly be a "burden" 
on her to defend this case under her current circumstances, defendant Maxwell propounded 
discovery on Plaintiff just two days later on August 21 seeking a wide variety of information and 
documents from her. Defendant Maxwell's thinly veiled argument that her criminal case is 
somehow preventing her from doing what she needs or wants to do in this case is undermined by 
the record of what has actually occurred. Rather, defendant M…
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