Case 1:20-cv-00484-JGK-DCF Document 99 Filed 03/11/21 Page 1 of 2 PANISH SHEA & BOIR, ,, March II, 2021 VIA ECF Hon. John G. Koeltl Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 Re: Doe v. Indyke, et aL, 1:20-cv-000484-JGK-DCF Dear Judge Koeltl: Plaintiff Jane Doe hereby responds to the Court's Memorandum Opinion and Order ("Opinion") dated March 8, 2021 (ECF 98). As the Court indicated in its Opinion, Defendant Ghislaine Maxwell refused to sign the proposed stipulation to dismiss this action with prejudice following Plaintiffs acceptance of the Epstein Victims' Compensation Program's offer of compensation'. Plaintiff was then compelled to file her motion to dismiss with prejudice pursuant to FRCP Rule 41(aX2). The U.S. Court of Appeals for the Second Circuit, in the case of Paysys Intl, Inc. v. Atos IT Servs. Ltd., 901 F.3d 105, 108 (2d Cir. 2018), as cited to by this Court in its Opinion, states that once the district court articulates its terms for dismissal, "plaintzff ... has the choice between accepting the conditions and obtaining dismissal and, if [the plaintiff] feels that the conditions are too burdensome, withdrawing [the plaintiff's] dismissal motion and proceeding with the case on the merits." Paysys, 901 F.3d at 109 (emphasis added). Indeed, that was the recent choice Judge Schofield gave another Epstein/Maxwell sex abuse victim plaintiff in the case of v. Indyke et al., 19-cv10475-LGS-DCF, following a nearly identical motion to dismiss filed by the plaintiff after Ms. Maxwell refused to stipulate to a dismissal in that case as well. In her Opinion and Order, Judge Schofield stated that: "Plaintiff shall file a letter no later than February 12, 2021, stating whether she consents to the Court's entry of the Proposed Order modified by striking the language "with each party to bear its own ' Defendant Maxwell is a willing and compulsory "Releasee" in the general release agreement executed by Plaintiff in connection to