Epstein Secrets

rk October 5, 2017 ly subwitted, el C. Miller Justin Y.K. Chu Michael A. Keough STEPTOE & JOHNSON LL

Court Should Modify the Protective Order I I CONCLUSION 15 CONFIDENTIAL - FILED UNDER SEAL EFTA00805390 TABLE OF AUTHORITIES Page(s) Cases Abarca v. Little, 54 F. Supp. 3d 1064 (D. Minn. 2014) 4 Charter Oak Fire Ins. Co. v. Electrolux Home Prods., Inc., 287 F.R.D. 130 (E.D.N.Y. 2012) 11, 1

STEPTOE & JOHNSON, LLP By /s/ Michael Miller Justin Y.K. Chu Attorneys for Defendants JEFFREY EPSTE

menced until January 27, 2017, more than four years after any of the events alleged in the FAC occurred. Plaintiff's claim is therefore time-barred. Abarca v. Little, 54 F.Supp.3d 1064, 1068 (Minn. 2014). As the Court stated in Abarca, a claim under Section 1595 had a four-year of statute of limitation

ndants Jeffery Epstein, and BY: MICHAEL MILLER JUSTIN CHU DARREN K. INDYKE LLC Attorney for Defendant

that analysis has been applied to conclude that the ten year statute of limitations applies. We cited a case out of the District of Minnesota, the Abarca case, that takes a different view, and the thinking in the Abarca case -- which we think is the correct thinking -- THE COURT: So far the thinking