Epstein Secrets

ed, but Plaintiff would not, however, consent to the use of all of the Jane Doe Evidence. On October 3, 2017, we submitted a letter motion to Judge Sweet seeking permission to file under seal a motion to modify the Protective Order entered in the Giuffre matter before him. On October 4, 2017, Judge S

or both sets of Defendants have scheduling conflicts on that date. Plaintiff has not agreed to an adjournment. Respectfully submitted, vitedliCt_ Michael C. Miller Counsel for lindifisieftiey Epstein and I Once the motion to modify the Protective Order is submitted to Judge Sweet, we will provide Your Honor

produced, but Plaintiff would not, however, consent to the use of all of the Jane Doe Evidence. On October , 2017, we submitted a motion to Judge Sweet under seal for a modification of the Protective Order entered in the matter before him. Specifically, we requested Judge Sweet to modify the Prote

Michael C. Miller 212 506 3955 [email protected] 1114 Avenue of the Americas New York. NY 10036 212 506 3900 main www.steptoe.com October_, 2017 VIA ECF Hon

hat the Court deny the request for leave to file any motion regarding the protective order, as any such motion would be properly addressed to Judge Sweet—the Judge who entered the order in the first instance. Jane Doe 43 furthers requests that the Court deny the requested stay of briefmg on the Motion

tter a sworn affidavit attesting to the truth of his counsel's representation that Epstein has "no present connection to New York." See Letter from Michael C. Miller to Hon. John G. Koetlt at 2 (July 14, 2017). Counsel for Jane Doe 43 have substantial grounds for believing this representation to be untrue and, in

eek? Thank you. Brad As of this writing, no response was received to this email. However, on November 8, 2017, Ms. Menninger appeared before Judge Sweet — in this Court — to argue a confidentiality issue on behalf of defendant Maxwell including arguments as to the type of protective order that should

rgan & Foreman, P.C. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Michael C. Miller 1114 Avenue of the Americas New York, NY 10036 Counsel for Defendants, Jeffrey Epstein and Lesley Groff Isl Bradley J. Edwards 13 EFTA00792809

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

Michael C. Miller 1114 Avenue of the Americas www.steptoe.com SUBMITTED UNDER SEAL July 14, 2017 Hon. John G. Koeltl United States District Court, Southern Distr

fendants' request, and issued an Order under seal, directing (a) Defendants to make their application for relief from the Protective Order to Judge Sweet and (b) file their Motion to Dismiss within seven (7) days after Judge Sweet's decision (the "July 17 Order"). Contrary to Mr. Edwards' contention,

Michael C. Miller 212 506 3955 1114 Avenue of the Americas New York. NY 10036 212 506 3900 main October 5, 2017 VIA ECF Hon. John G. Koeltl United States Distr

ed, but Plaintiff would not, however, consent to the use of all of the Jane Doe Evidence. On October 3, 2017, we submitted a letter motion to Judge Sweet seeking permission to file under seal a motion to modify the Protective Order entered in the matter before him. Once Judge Sweet rules on the lett

be scheduled for a date other than October 10. Counsel for both sets of Defendants have scheduling conflicts on that date. Respectfully submitted, Michael C. Miller Counsel for Defendants Jeffrey Epstein and ME Once the motion to modify the Protective Order is submitted to Judge Sweet, we will provide Your Ho