Epstein Secrets

ection with the Complaint and the FAC and directing Plaintiff and her counsel to pay the same. Dated: July 21, 2017 STEPTOE & JOHNSON, LLP By /s/ Michael C. Miller Michael C. Miller Justin Y.K. Chu Michael Keough Attorneys for Defendants JEFFREY EPSTEIN & LESLEY GROFF To: FARMER, JAFFE, WEISSING, EDWARDS

s to establish that the Court possesses personal jurisdiction over the Defendants; and e) the FAC fails to establish that venue is properly laid in the Southern District of New York. Finally, Plaintiff's deposition testimony, and the documents that she produced, in the action captioned v. Maxwell, No. 15 Civ. 7433

tter a sworn affidavit attesting to the truth of his counsel's representation that Epstein has "no present connection to New York." See Letter from Michael C. Miller to Hon. John G. Koetlt at 2 (July 14, 2017). Counsel for Jane Doe 43 have substantial grounds for believing this representation to be untrue and, in

hrman, 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, NY 10007-1312 RE: Jane Doe 43 v. Epstein et al., No. 17 C

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 Distr

he Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. 11. A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating th

g served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. STEPTOE & JOHNSON, LLP Michael C. Miller Justin Y.K. Chu Attorneys for Defendants Jeffrey Epstein & By: /s/ Bradley J. Edwards 31 EFTA00615969

all times material to this cause of action 9. A substantial part of the acts, events, and omissions giving rise to this cause of action occurred in the Southern District of New York; venue is proper in that District. 28 U.S.C. section 1391(b)(2) 2 EFTA00615940 Case 1:17-cv-00616-3GK Document 45 Filed 06/05/17 Pag

ection with the Complaint and the FAC and directing Plaintiff and her counsel to pay the same. Dated: July 21, 2017 STEPTOE & JOHNSON, LLP By /s/ Michael C. Miller Michael C. Miller Justin Y.K. Chu Michael Keough Attorneys for Defendants JEFFREY EPSTEIN & LESLEY GROFF To: FARMER, JAFFE, WEISSING, EDWARDS

s to establish that the Court possesses personal jurisdiction over the Defendants; and e) the FAC fails to establish that venue is properly laid in the Southern District of New York. Finally, Plaintiff's deposition testimony, and the documents that she produced, in the action captioned Giuffre v. Maxwell, No. 15 Ci

e foregoing requests with you when convenient. We reserve the right to request further discovery and additional particulars as the case progresses. Michael C. Miller Martin G Weinberg EFTA00096247

but not limited to communications with the United States Attorney's Offices for the Northern District of Georgia, Southern District of Florida, and the Southern District of New York. EFTA00096236 August 1, 2019 Page 6 Steptoe SIDON & JOHNSON LIP 27. Relating to any investigation undertaken by the Department o

reasons, we respectfully submit that there is good cause to stay discovery tmtil the Court has resolved the motions to dismiss the 4nded complain. Michael C. Miller Counsel for De endants Jeffrey Epstein and EFTA00286405

b) is barred by the applicable statutes of limitations; (c) fails to allege jurisdiction; and (d) fails to establish that venue is properly laid in the Southern District of New York. We respectfully request that the Court waive its page limitation on letter motions to permit us to provide the Court with a copy of the

mim Michael C. Miller May 15, 2017 Brad Edwards, Esq. Re: v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Brad: Steptoe stenos • JOHNSON 1.0 In accordan

barred by the statute of limitations; (c) the Complaint fails to allege personal jurisdiction over Defendants; and (d) venue is improperly laid in the Southern District of New York. Because the Plaintiff's Section 1595 claim turns solely on whether the Defendants engaged in fraud and coercion, as you admitted durin

Case 1:17-cv-00616-JGK Document 43 Filed 05/22/17 Page 1 of 2 Michael C. Miller VIA ECF Hon. John G. Koeltl Re: May 22, 2017 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Steptoe STEPTOE i JOHNSON LIP Dear Judge

b) is barred by the applicable statutes of limitations; (c) fails to allege jurisdiction; and (d) fails to establish that venue is properly laid in the Southern District of New York. We respectfully request that the Court waive its page limitation on letter motions to permit us to provide the Court with a copy of the

Michael C. Miller 1114 Avenue of the Americas New York. NY 10036 main www.steploe.com May 2017 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Le

s barred by the statute of limitations; (c) the Complaint fails to allege personal jurisdiction over Defendants; and (d) venue is improperly laid in the Southern District of New York. Because the claim turns on whether there was fraud and coercion, as you admitted in open court during the initial case management conf