Epstein Secrets

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

. Koelti July 17, 2017 Page 2 With regard to Epstein's request that he be given leave to move for modification of the protective order entered in Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS), any issues related to the protective order are properly addressed to Judge Sweet. See, e.g., Daniels v. City of N. Y., 200

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

way of additional background information, shortly after Plaintiff initiated the Action, she was deposed in another matter pending in this District, Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS) (the "Giuffre action"). During that deposition, Plaintiff gave sworn testimony which relates in large measure to the claims

Michael C. Miller 1114 Avenue of the Americas New York. NY 10036 January 3, 2018 Hon. John G. Koeltl United States District Court United States Courthouse 500 P

to use materials in addition to her deposition and the documents marked at the deposition (collectively, the "Transcript") in the matter captioned Giuffre v. Maxwell, Case No. 15-cv-07433(RWS) ("Giuffre Action"). We agreed to Plaintiff's request, and in return we proposed that should Plaintiff decide to use mater

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

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 Civ. 7433 (RWS) (the "Giuffre action") further demonstrate that the FAC should be dismissed for the reasons set forth above and in the Defi