Epstein Secrets

sq. Steptoe& Johnson, LLP August 7, 2017 Page 2 In addition, you submitted a motion to Judge Koeltl requesting leave to file a Motion with Judge Sweet for the release of Jane Doe 43's transcript in the Guiffre v. Maxwell matter. It was our understanding you were going to be filing your motion with

in your letter to Judge Koeltl as follows: "We respectfully submit that the Plaintiff's Evidence provides grounds for this Court to dispose of the Action entirely, inter alia, under Rule 12(b)(2) for lack of personal jurisdiction. Because the Defendants have no present connection to New York upon whi

S-cv-07433 United States District Court For the Southern District of New York March 17, 2016 Protective Order by United States District Court Judge Sweet The undersigned acknowledges that he has read the above-referenced Protective Order, a copy of which is attached, and agrees to be bound by the prov

We represent defendants Jeffrey Epstein and ("Defendants") in the above- referenced lawsuit ("Action"). The Defendants intend to move to dismiss the Action based on, inter alia, the failure of Jane Doe 43 ("Plaintiff") to establish personal jurisdiction over the Defendants ("Motion to Dismiss"). The Pl

nel's August 2008 Order, the MDL Panel has transferred all related actions filed against Bear Steams to the Southern District of New York and Judge Sweet. See, e.g., Wang v. The Bear Stearns Companies Inc., et at, No. 09 Civ. 1200 (RWS) (S.D.N.Y. Feb. 10, 2009); Rand v. The Bear Stearns Companies Inc

D.N.Y. Feb. 10, 2009); Rand v. The Bear Stearns Companies Inc., et at, No. 08 Civ. 8194 (RWS) (S.D.N.Y. Sept. 23, 2008). 6. The Complaint in this Action shares numerous questions of fact with the Related Actions. Namely, all of the actions center on allegations that Bear Stearns made material missta

Esq. Steptoe& Johnson, LLP August 7, 2017 Page 2 In addition, you submitted a motion to Judge Koeltl re uestin leave to file a Motion with Judge Sweet for the release of Jane Doe 43's transcript in th Maxwell matter. It was our understanding you were going to be filing your motion with Judge Sweet

in your letter to Judge Koeltl as follows: "We respectfully submit that the Plaintiff's Evidence provides grounds for this Court to dispose of the Action entirely, inter alia, under Rule 12(b)(2) for lack of personal jurisdiction. Because the Defendants have no present connection to New York upon whi

rn District of New York to investigate and prosecute Epstein and Maxwell. Ex. J. Then, two months after the meeting with AUSA attorneys told Judge Sweet—who was presiding over defamation against Maxwell—that there was an 4 EFTA00028937 --- PAGE BREAK --- "ongoing criminal investigation" into Max

or Boies Schiller had anything to do with the Government's decision to convene a grand jury to look into the matters that were the subject of the Action. On the contrary—the Government has advised the Court that it contacted Boies Schiller as part of its search for parties who might have been victim