Case 1:19-cv-10475-LGS-DCF Document 68 Filed 05/13/20 Page 1 of 3 H A D D O N MORGAN FOREMAN May 13, 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: 19-cv- 10475 (LGS-DCF) Dear Judge Freeman: Haddon, Morgan and Foreman. r.c Laura A. MannInger ISO East 10th Avenue Denver. Colorado 80203 PH 303.831.7364 rx 303.832.2628 www.hmflaw.corn Imenningerathmflaw.com v. Darren K Indyke, et aL On behalf of defendant Ghislaine Maxwell, I write under Judge Schofield's Individual Rules and Procedures for Civil Cases III(A)(1) and this Court's Practices II(A) to request a pre-motion conference concerning our anticipated Motion to Stay Discovery under Fed.R.Civ.P. 26(c)(1). Counsel conferred in good faith with both Plaintiff and Defendant Co-Executors of the Estate. Plaintiff does not consent to a stay as indicated on a telephonic conferral conference on April 28. The Co-Executors of the Estate consent to the requested stay. Three separate and independent grounds justify a protective order staying discovery in this matter. First, Plaintifl intends to participate in the Voluntary Claims Resolution Program in the U.S. Virgin Islands (the "Program"), under which the Estate will make compensatory payments to alleged victims of Jeffrey Epstein. Plaintiffs who participate in the Program and accept payment will be required to release all former employees or potential indemnitees of the Estate, including Ms. Maxwell, from any and all claims or causes of action that concern acts of sexual abuse by Mr. Epstein. We understand that, if the Program is approved, it may begin making payments as early as August 2020. Hence, Plaintiff's participation in the Program, if successful, will render this lawsuit moot and will result in its dismissal with prejudice in a few short months. If unsuccessful, Plaintiff will be able to resume this litigation at that t