Epstein Secrets

P By: Is/ Michael C. Miller Michael C. Miller Justin Y.K. Chu Attorn s or De endants Je re E stein,

N DISTRICT OF NEW YORK CASE NO. 17 Civ 616 (JGK) DEFENDANT INITIAL RULE 26(a)(1)(A) DISCLOSURE STATEMENT Defendant by and through her attorneys, Steptoe & Johnson LLP, hereby submits her Initial Disclosures pursuant to Rule 26(aXI)(A) of the Federal Rules of Civil Procedure based upon information currently known

rd for all parties appearing in this matter. /s/ Justin Y.K. Chu -4- EFTA00310347

ff, VS. JEFFREY EPSTEIN, GHISLAINE Defendants. DEFENDANT INITIAL RULE 26(a)(I)(A) DISCLOSURE STATEMENT Defendant by and through her attorneys, Steptoe & Johnson LLP, hereby submits her Initial Disclosures pursuant to Rule 26(a)( I )(A) of the Federal Rules of Civil Procedure based upon information currently kno

raise this issue on April 6, 2017, so we should discuss in advance your preferences. Chronology and Background of Other Matters We recommend that Justin and Mike Keough meet with Darren to expand our knowledge about other proceedings, past and present, which might have a bearing on our case. We belie

any problems by acknowledging that we are in receipt of the transcript. Mike Michael C. Miller Partner www.steptoe.comimmiller Steptoe direct Steptoe & Johnson LLP fax 1114 Avenue of the Americas cell New York, NY 10036 www.steptoe.com EFTA00672335 This message and any attached documents contain informat

From: Lesley Groff < To: "Chu, Justin" <1 Cc: "Miller, Michael" < Subject: Re: Jane Doe 43 v. Epstein et al., No. 17 Civ. 616 Date: Wed, 26 Jul 2017 11:19:37 +0000 did you send the fo

, No. 17 Civ. 616 Dear All, Please see the attached letter from Michael Miller. Best, Sara Sara Gilbert wrote: Steptoe EFTA00456703 direct Steptoe & Johnson LLP mobile 1114 Avenue of the Americas fax New York, NY 10036 This message and any attached documents contain information from the law firm Steptoe

From: Lesley Groff < To: "Gilbert, Sara" < Cc: "Miller, Michael" < >, "Chu, Justin" < Subject: Re: Jane Doe 43 v. Epstein et al., No. 17 Civ. 616 Date: Fri, 21 Jul 2017 21:08:13 +0000 Thank you Sent from my iPhone On Jul 21, 20

hnson LLP 1114 Avenue of the Americas New York. NY 10036 '; Miller, This message and any attached documents contain information from the law firm Steptoe & Johnson LLP that may be confidential and/or privileged. If you are not the intended recipient. please do not read, copy, distribute. or use this information. If

bursement for costs. My hourly rate is $895, and Justin Chu's hourly rate is $735. An associate and para

New York 10022 Dear Mr. Epstein: This letter and the attached General Terms and Conditions of Engagement set forth the basis for the engagement of Steptoe & Johnson LLP ("Steptoe") to represent you ("You") in connection with a lawsuit filed in the United States District Court, Southern District of New York, caption

bursement for costs. My hourly rate is $895, and Justin Chu's hourly rate is $735. An associate and para

: Steptoe STEPTOL & JOHNSON ll• This letter and the attached General Terms and Conditions of Engagement set forth the basis for the engagement of Steptoe & Johnson LLP ("Steptoe") to represent you ("You") in connection with a lawsuit filed in the United States District Court, Southern Dis rict of rk .oned lar s