DOJ-OGR-00019317.jpg
873 KB
Extraction Summary
6
People
3
Organizations
2
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal correspondence (response to pre-motion conference request)
File Size:
873 KB
Summary
This is a legal letter from attorney David Boies representing plaintiff Annie Farmer, addressed to Judge Debra C. Freeman on May 18, 2020. The letter argues against Defendant Ghislaine Maxwell's request to stay discovery in the civil case pending a criminal investigation, citing case law that characterizes such stays as extraordinary remedies when no indictment has yet been issued. Boies asserts that Maxwell's motion is an unjustified attempt to delay litigation.
People (6)
| Name | Role | Context |
|---|---|---|
| David Boies | Attorney/Sender |
Attorney for Plaintiff Annie Farmer, writing to Judge Freeman.
|
| Debra C. Freeman | Judge/Recipient |
Honorable Judge presiding over the matter at the US Courthouse.
|
| Annie Farmer | Plaintiff |
Plaintiff in the civil case against Maxwell, Indyke, and Kahn.
|
| Ghislaine Maxwell | Defendant |
Defendant seeking to stay discovery due to a pending criminal investigation.
|
| Darren K. Indyke | Defendant |
Named as a co-defendant in the case caption.
|
| Richard D. Kahn | Defendant |
Named as a co-defendant in the case caption.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Boies Schiller Flexner LLP |
Law firm representing the Plaintiff.
|
|
| United States Courthouse |
Venue for the legal proceedings.
|
|
| DOJ-OGR |
Department of Justice Office of Government Relations (indicated by footer stamp).
|
Timeline (1 events)
May 18, 2020
Plaintiff Annie Farmer files opposing response to Ghislaine Maxwell's request for pre-motion conference regarding a stay of discovery.
New York, NY
Locations (2)
Relationships (2)
Plaintiff Annie Farmer hereby responds to Defendant Ghislaine Maxwell’s request
David Boies signing the letter on behalf of Plaintiff Annie Farmer
Key Quotes (3)
"The Court should deny Maxwell’s motion for a pre-motion conference and deny her anticipated motion in its entirety because... each of Maxwell’s reasons for staying discovery is meritless and the motion is simply another attempt to unjustifiably delay this litigation."Source
DOJ-OGR-00019317.jpg
Quote #1
"“[A] stay of a civil case to permit conclusion of a related criminal prosecution has been characterized as an extraordinary remedy.”"Source
DOJ-OGR-00019317.jpg
Quote #2
"The Court should deny Maxwell’s motion for a stay without prejudice to her ability to renew her application if she is arrested. Until that happens, however, there are no grounds for a stay."Source
DOJ-OGR-00019317.jpg
Quote #3
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