Epstein Secrets

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

nihan United States Courthouse 500 Pearl Street New York, New York 10007-1312 RE: Jane Doe 43 v. Epstein, et al.,No.17 Civ. 616 (JGK) Dear Judge Koeltl: Steptoe STEPTOS E JOHNSON LIP We represent defendants Jeffrey Epstein and ("Defendants") in the above- referenced lawsuit ("Action"). The Defend

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 District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, New York

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

w Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, P.L. Bradley J. Edwards [email protected] July 17, 2017 SUBMITTED UNDER SEAL Hon. John G. Koeltl United States District Court for the Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, N

k Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 RE: Jane Doe 43 v. Epstein et al., No. 17 Civ. 616 (JOK) Dear Judge. Koeltl: We represent Plaintiff Jane Doe 43 in the above-captioned action. We write in response to a letter that Defense counsel for Jeffrey Epstein et al.

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,

ted States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Judge Koeltl: We represent Defendants Jeffrey Epstein and Lesley Groff ("Defendants") and write to respond to Bradley J. Edwards' letter of October 5, 2017. Mr.

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 District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civi

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

October 4, 2017 VIA ECF Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Jane Doe 43 v. Jeffrey E stein, et al. Civi

rict Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Jane Doe 43 v. Jeffrey E stein, et al. Civil Actio Dear Judge Koeltl: We are counsel for Defendants Jeffre E stein and in the above-referenced matter. We write jointly with Defendant (together, the "Defendants") to

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

ted States Courthouse 500 Pearl Street New York, NY 10007.1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Judge Koeltl: Steptoe ......... ji b. We are counsel for Defendants Jeffit E stein and In the above-referenced matter. We write jointly with Defendant (toge

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

ice wherein you state that Jane Doe 43 does not have a basis for alleging jurisdiction in New York. Specifically you stated 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, un

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

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. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civi

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

ice wherein you state that Jane Doe 43 does not have a basis for alleging jurisdiction in New York. Specifically you stated 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, un

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

to litigate on behalf of defendant Maxwell in this very Court and, thus, presumably has an effective way of communication with Maxwell. This Court (Koeltl, J.), has previously allowed service to be made through an attorney that was representing a client, explaining that the attorney "must know how to c

D.N.Y. Feb. 27, 1998) (citing Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 743 (2d Cir. 1987) and Martindell, 594 F.2d at 297). Judge Sweet, the same judge who approved the civil protective order upon which Ms. Maxwell relied, held that the defendant's "continuing need for the EFTA00088

uash. Similar cases in this district demonstrate the "non-standard" nature of the government's conduct regarding these subpoenas. For example, Judge Koeltl observed when considering whether to release a single deposition transcript to the government: "the Second Circuit has made clear that the Governme