Case 1:19-cv-10475-LGS-DCF Document 73 Filed 05/19/20 Haddon, Page 1 of 4 and r.c Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com Imenningeahmflaw.com HADDON AN N May 19, 2020 VIA ECF Hon. Debra Freeman United States Magistrate Judge Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: 19-cv- 10475 (LGS-DCF), v. Darren K. lndyke, et al. Dear Judge Freeman: I write to reply in further support of Ms. Ghislaine Maxwell's request for a pm-motion conference to discuss a Motion to Stay Discovery in this matter. Plaintiff's ad hominem attacks notwithstanding, this Court has the power pursuant to Rule 26(c) to stay discovery "for good cause shown," regardless of whether the opposing party consents to the stay or whether a claims program requires that she do so. Spencer Trask Software & Info. Servs., LLC v. RPost Intl Ltd., 206 F.R.D. 367, 368 (S.D.N.Y. 2002). Good cause in this case exists for three independent reasons, balanced against the expansive discovery Plaintiff seeks against Ms. Maxwell (and the other Defendants). First, Plaintiff's intended imminent participation in the U.S.V.I. Voluntary Claims Program likely will, contrary to her counsel's claim, render this lawsuit moot. Plaintiff's counsel asserts "it is not clear that Maxwell would be released for her torts against Plaintiff" (Resp. at 2); in fact, Mr. Boies approved the release covering all Epstein employees (including Ms. Maxwell) for legal actions such as Plaintiff's which falsely accuse Ms. Maxwell of sexual assault. See Co-Executors' Corrections to Attorney General's Status Report on Voluntary Compensation Program and Renewed Request for Ruling at 2 & Ex. B, Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Apr. 14, 2020, V.I. Super. Ct) (attached as Exhibit A). Plaintiff concededly intends to participate in the Program; she recently asked the U.S.V.I. Probate Court for a status conference to help