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