EFTA00026735.pdf

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Source set: data-set-8
Extracted text

Case 1:20-cv-00484-JGK-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 Moynihan 
United States Courthouse 
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. "[T]he 
power to stay proceedings is incidental to the power inherent in every court to control 
the disposition of the causes on its docket with economy of time and effort for itself, 
for counsel, and for litigants." Louis Vuitton Malletier S.A. v. LY USA, Inc., 676 F.3d 
83, 96 (2d Cir. 2012) (citations omitted). 
The interests of the courts, the public, the other parties and Ms. Maxwell all 
will best be served by a stay of this civil case. A stay will allow Ms. Maxwell to 
vigorously contest her criminal charges, and there is little chance that any evidence 
will be lost in the interim given the age of the accusations in this case. Plaintiff 
refuses to state whether she intends to pursue a civil remedy in the Epstein Claims 
Resolution Program, yet a stay also would permit her the opportunity to do so. She is 
inexplicably the only of the numerous Epstein plaintiffs in this Court to not agree to 
such a stay. While Plaintiff's counsel refuses to state whether his client is one of the 
three accusers in the currently-pending Maxwell Indictment, there exists substantial 
overlap in the facts and issues between this civil complaint and the Indictment. The 
burden on Ms. Maxwell to proceed forward in a civil case relating to quarter-century 
old events while detained at the MDC cannot be overstated in light of the …
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