Case 1:15-cv-07433-LAP Document 102 Filed 04/19/16 Page 1 of 9 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S OPPOSITION TO DEFENDANT'S MOTION TO DISCLOSE CRIMINAL INVESTIGATIONS BY LAW ENFORCEMENT OR, IN THE ALTERNATIVE, TO STAY PROCEEDINGS Plaintiff by and through her undersigned counsel, hereby files this Opposition to Defendant's Motion to Disclose Criminal Investigations by Law Enforcement or, in the Alternative, to Stay Proceedings. Defendant offers no good reason why the Court should compel the disclosure of non-public, on-going law enforcement investigations. Nor is there any good reason for the Court to grant a last-minute "stay" of this case (including Defendant's longdelayed deposition, which is currently scheduled for Friday). Defendant has made no showing that such extraordinary relief is warranted, particularly while representing to the Court that such an investigation is "likely nonexistent." (Defendant's Mtn. at 2). Defendant will certainly be entitled to invoke her Fifth Amendment right to remain silent when asked questions about her involvement in sex trafficking. But neither an investigation nor her invocations provide any basis for staying this case. Defendant suffers no prejudice going into her deposition not knowing the name of the law enforcement entity because truthful testimony should not change. Accordingly, the Court should deny Defendant's motion in its entirety. If the Court believes that EFTA02781477