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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
erning the Ili on and documents Plaintiff produced as a non-party witness in an action captioned v. Mayen, 15 Civ. 7433 (RWS), pending before Judge Robert Sweet ("July 17 Order" and "Jane Doe Evidence", respectively). Pursuant to the July 17 Order, we have sought consent from Plaintiff's counsel to use the
P. 9(b) and 12(b)(6). I. PRELIMINARY STATEMENT: MULTIPLE SDNY JUDGES WARNED THE PERSON DRIVING THIS ACTION AGAINST SUCH FRIVOLOUS LAWSUITS Judges Sweet, Berman and Castel warned Steven Hoffenberg ("Hoffenberg"), whom Plaintiffs identify as the "Non-Party Affiant" (Compl. 15) and whose affidavit for
94, Hoffenberg was indicted on various fraud charges, in multiple jurisdictions, including the SDNY. (Comp!. ¶¶ 51-52). • On March 4, 1997, "Judge Robert Sweet issued a Sentencing Opinion ("Sentencing Opinion") which lays bare the fraudulent conduct that resulted in Hoffenberg's conviction and which was im
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
ning the /l ion and documents Plaintiff produced as a non-party witness in an action captioned v. Maxwell, 15 Civ. 7433 (RWS), pending before Judge Robert Sweet ("July 17 Order" and "Jane Doe Evidence", respectively). Pursuant to the July 17 Order, we have sought consent from Plaintiff's counsel to use the
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,
tion that Plaintiff be allowed to depose Mr. Epstein on the ground that Defendants have been engaging in discovery from another matter before Judge Robert Sweet is baseless. Defendants have not engaged in any discovery; rather, it is the Plaintiff who is seeking to engage in a one-sided and premature fishin
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
July 17, 2017 concerning the de l ion and documents Plaintiff roduced as a non-party witness in an action captioned v. Maxwell nding before Judge Robert Sweet ("July 17 Order" and "Jane Doe Evidence", respectively). Pursuant to the July 17 Order, we have sought consent from Plaintiff's counsel to use the
Entities connected to both Sweet and Robert Sweet

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Bradley Edwards
PERSONJane Doe
PERSON
Southern District of New York
ORGANIZATION
Steven Hoffenberg
PERSONJohn G. Koeltl
PERSON
New York
LOCATION
the United States District Court
ORGANIZATION
Michael C. Miller
PERSON
Financial Trust Company
ORGANIZATIONTowers Financial
ORGANIZATION