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 Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 Re: Doe v. Indyke, el al., 1:20-cv-000484-JGE-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 Maxwell appears to want to gain an