Case 1:20-cv-00484-JGK-DCF Document 115 Filed 11/22/21 Haddon, Page 1 of 2 and c Laura A. Menninger 150 Eost 10th Avenue Denver. Colorado 80203 PH 303.831.7364 DC 303.832.2628 www.hmflaw.com [email protected] H A D D O N N November 22, 2021 VIA ECF The Honorable John G. Koeltl United States District Court Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Doe v. Indyke, et at, 1:20-cv-000484-JGK-DCF Dear Judge Koeltl: I write pursuant to this Court's order of dismissal, dated March 19, 2021, granting plaintiff's motion for dismissal with prejudice on the condition that she provide to Ms. Maxwell an authentic, unredacted, and signed copy of the General Release she executed with the Epstein Victims' Compensation Program (EVCP). Dkt. No. 102. This Court explained that production of the Release was subject to the Order on Plaintiffs' Anonymity and that Ms. Maxwell could not disclose the Release except pursuant to an order of this Court. Ms. Maxwell now seeks authorization from this Court to disclose the Release as part of her criminal defense. As this Court knows, Ms. Maxwell is facing a multi-count indictment in Case No. 20cr-330-AJN, which is scheduled to go to trial beginning on November 29, 2021. As explained in the briefing on plaintiff's motion to dismiss this case, and as this Court recognized in granting that motion subject to the condition that plaintiff provide Ms. Maxwell with the Release, Ms. Maxwell's constitutional rights to present a defense and to confrontation require that she be able to use the Release in her defense of the criminal case. U.S. Const. amends. V, VI. The Release is material to her defense, and it shows plaintiff's bias and motive in alleging that Ms. Maxwell was involved in alleged abuse. A criminal defendant "states a violation of the Confrontation Clause by showing that (s)he was prohibited from engaging in otherwise appropriate cross-examination designed to show a prototypical form of