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

ave 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, under Rule 12(b)(2) for lack of personal jurisdiction. Because the D

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

uments, i.e., the Plaintiff's Evidence. Mr. Epstein, through his counsel, as a non-party witness in the Giuffre action, was provided with a copy of the Plaintiff's Evidence. These materials were marked "Confidential" pursuant to the Protective Order in that case.' Under the terms of the Protective Order, "Confidential"

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

ave 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, under Rule 12(b)(2) for lack of personal jurisdiction. Because the D

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,

rsuant to the Protective Order in the action. Mr. Epstein, through his counsel, as a non-party witness in the action, was provided with a copy of the Plaintiff's Evidence. The Plaintiff's Evidence is dispositive of the Motion to Dismiss that Defendants plan to file, and particularly on the issue of whether the Court l