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Case 1:20-cv-00484-DG-KAM Document 60 Filed 09/14/20 Page 3 of 13
having to divulge anything about herself or the bad conduct she is alleged to have committed." (Id., at 1; see also id., at 4-5 (arguing that Maxwell had already demonstrated her ability to participate actively in this action from jail).) Plaintiff also noted that, under the terms of the Compensation Program, she is not required to agree to a stay of her lawsuit in order to participate in that program. (Id., at 2.) As for the prejudice that Plaintiff would purportedly suffer from a stay of these proceedings, Plaintiff asserted that, "[f]or too long[,] Jeffrey Epstein and Ghislaine Maxwell skirted the consequences of their vile acts," and that she should not have to wait "even longer for justice." (Id., at 4.)
Maxwell filed a reply on September 4, 2020 (see Letter to the Court from Laura A. Menninger, Esq., dated Sept. 4, 2020 ("9/4/20 Menninger Reply Ltr.") (Dkt. 79)), contending that Plaintiff had not adequately demonstrated how the requested stay would harm her interests, and taking issue with Plaintiff's assertions that Maxwell could reasonably litigate this case from the MDC (see id.).
On September 4, 2020, this Court additionally received a letter from Acting United States Attorney Audrey Strauss, on behalf of the Government, requesting leave to intervene in this matter for the limited purpose of - like Maxwell - seeking a stay of this case, in its entirety, pending the resolution of the Government's criminal prosecution against Maxwell. (See Letter to the Court from Audrey Strauss, Acting United States Attorney, by Maurene Comey, Alison Moe, and Lara Pomerantz, Assistant United States Attorneys, dated Sept. 4, 2020 ("9/4/20 Gov't Ltr.") (Dkt. 80).) In its letter, the Government urged this Court to stay this action on the grounds that "a complete stay of this civil action [would] serve the public interest of preserving the integrity of the criminal prosecution against Maxwell and [would] conserve private, public, and judicial
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