Epstein Secrets

mply compounding Mr. Edwards' failure to promptly participate in and complete the meet and confer we started over two weeks ago. Sincerely yours, Michael C. Miller EFTA00788396

ter and the defendants' motion to dismiss the FAC. In fact, the July 17 Order does not set any deadline for submission of the motion for relief from the Protective Order; it only requires the parties to meet and confer before filing that motion — which the defendants attempted to do with Mr. Edwards. Moreover, the J

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

that case.' Under the terms of the Protective Order, "Confidential" documents "shall not be disclosed or used for any purpose except the A copy of the Protective Order is attached hereto as Exhibit A. Out of respect for the provisions of the Protective Order, we are submitting this letter under seal. EFTA00793037

Michael C. Miller 212 506 3955 1114 Avenue of the Americas New York. NY 10036 212 506 3900 main August 8, 2017 Sigrid McCawley, Esq. Boles Schiller & Flexner LL

ter and the defendants' motion to dismiss the FAC. In fact, the July 17 Order does not set any deadline for submission of the motion for relief from the Protective Order; it only requires the parties to meet and confer before filing that motion — which the defendants attempted to do with Mr. Edwards. Moreover, the J

Michael C. Miller 212 506 3955 1114 Avenue of the Americas New York. NY 10036 212 506 3900 main October 5, 2017 VIA ECF Hon. John G. Koeltl United States Distr

ed for any deposition of Mr. Epstein. We respectfully submit that there is no reason to deviate from the July 17 Order. The motion for relief from the Protective Order has been submitted to Judge Sweet. Once Judge Sweet rules on the motion, Defendants will submit their Motion to Dismiss within seven (7) days. The