Case 1 20-cv-00484-3GK-DCF Document 80 Filed 09/09/20 Page 1 of 4 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mello Building One Saint Andrew's Plaza New York, New York 10007 The Clerk of Court is directed to file this letter on the Docket September 4, 2020 of Case No. 20cv00484. BY EMAIL' Dated: 09/09/2020 The Honorable Debra Freeman United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 SO ORDERED Re: DEBRA FREEMAN United States Magistrate Judge Jane Doe v. Darren K. lndyke, et at, 20 Civ. 484 (DCF) (JCK) Dear Judge Freeman: The Government respectfully submits this letter to request that the Court: (1) permit the Government to intervene in the above-referenced matter for the limited purpose of seeking a stay of the action, and (2) stay this matter in its entirety pending the resolution of the criminal prosecution against Ghislaine Maxwell in the matter of United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN). As discussed below, the Government submits that a complete stay of this civil action will serve the public interest of preserving the integrity of the criminal prosecution against Maxwell and will conserve private, public, and judicial resources; and that those interests will outweigh any delay or disruption caused to the resolution of this civil action. On June 29, 2020, a federal grand jury in this District returned a sealed indictment (the "Indictment") charging Ghislaine Maxwell with one count of conspiracy to entice minors to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 371; one count of enticing a minor to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 2422 and 2; one count of conspiracy to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371; one count of transporting minors to participate in illegal sex acts, in violation of 18 U.S.C. § 2423 and 2; a