Goldstein v. Hindle, 1:21-cv-03124

Plaintiffs Goldstein, Layman, and Morrissey filed a lawsuit in Maryland state court against Karl Hindle (and initially Allissa Hindle, later dismissed), alleging defamation and invasion of privacy by false light due to alleged false and damaging statements online.
Hindle removed the case to federal court based on diversity jurisdiction and later filed a counterclaim for tortious interference.
Litigation has involved significant discovery disputes, sanctions motions, and delays, with discovery close to concluding after extensions.
Hindle moved for a limited stay of proceedings and discovery, citing Fifth and Sixth Amendment concerns, and referencing an alleged ongoing FBI investigation affecting the parties.
Plaintiffs opposed, arguing the stay request lacked evidentiary and legal support and was a delay tactic, noting the investigation did not connect to the case claims and Hindle had no actual self-incrimination concerns.
The court evaluated whether a stay was justified given the parties' interests, burdens, judicial economy, and relevance of any criminal proceedings, ultimately finding for continued civil proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether to grant a stay of proceedings	Delay would prejudice plaintiffs; defendant's reasons vague	Stay warranted due to FBI investigation and constitutional rights	Stay denied; no clear basis or prejudice
Relevance of Fifth/Sixth Amendment	No substantiated self-incrimination risk for Hindle	Fifth/Sixth Amendment require a stay due to possible investigation	No valid Fifth/Sixth Amendment reason
Existence/relatedness of criminal investigation	No evidence criminal matter is related to civil claims	Investigation warrants a pause to protect parties	No sufficient relatedness or overlap
Proper handling of discovery burdens	Defendant hasn't served discovery or followed procedures	Discovery is overly burdensome; lack of participation by plaintiffs	Discovery burden not exceptional; follow normal rules

Landis v. N. Am. Co., 299 U.S. 248 (courts have inherent authority to stay proceedings to manage their dockets)
Clinton v. Jones, 520 U.S. 681 (stay requests are subject to judicial discretion)
United States v. Ga. Pac. Corp., 562 F.2d 294 (balancing factors govern stay motions)
Couch v. United States, 409 U.S. 322 (Fifth Amendment privilege is personal, not vicarious)
United States v. Kordel, 397 U.S. 1 (stay of civil cases may sometimes be warranted when interests of justice require)
Sec. & Exch. Comm'n v. Dresser Indus., Inc., 628 F.2d 1368 (simultaneous civil and criminal cases are ordinarily unobjectionable)