Epstein Secrets

or both sets of Defendants have scheduling conflicts on that date. Plaintiff has not agreed to an adjournment. Respectfully submitted, vitedliCt_ Michael C. Miller Counsel for lindifisieftiey Epstein and I Once the motion to modify the Protective Order is submitted to Judge Sweet, we will provide Your Honor

erning the Ili on and documents Plaintiff produced as a non-party witness in an action captioned v. Mayen, 15 Civ. 7433 (RWS), pending before Judge Robert Sweet ("July 17 Order" and "Jane Doe Evidence", respectively). Pursuant to the July 17 Order, we have sought consent from Plaintiff's counsel to use the

Michael C. Miller 212 506 3955 [email protected] 1114 Avenue of the Americas New York. NY 10036 212 506 3900 main www.steptoe.com October_, 2017 VIA ECF Hon

ning the /l ion and documents Plaintiff produced as a non-party witness in an action captioned v. Maxwell, 15 Civ. 7433 (RWS), pending before Judge Robert Sweet ("July 17 Order" and "Jane Doe Evidence", respectively). Pursuant to the July 17 Order, we have sought consent from Plaintiff's counsel to use the

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

tion that Plaintiff be allowed to depose Mr. Epstein on the ground that Defendants have been engaging in discovery from another matter before Judge Robert Sweet is baseless. Defendants have not engaged in any discovery; rather, it is the Plaintiff who is seeking to engage in a one-sided and premature fishin

be scheduled for a date other than October 10. Counsel for both sets of Defendants have scheduling conflicts on that date. Respectfully submitted, Michael C. Miller Counsel for Defendants Jeffrey Epstein and ME Once the motion to modify the Protective Order is submitted to Judge Sweet, we will provide Your Ho

July 17, 2017 concerning the de l ion and documents Plaintiff roduced as a non-party witness in an action captioned v. Maxwell nding before Judge Robert Sweet ("July 17 Order" and "Jane Doe Evidence", respectively). Pursuant to the July 17 Order, we have sought consent from Plaintiff's counsel to use the