Epstein Secrets

s, the Court should allow a one-deposition of Epstein on all issues associated with jurisdiction, including all questions regarding his residence in New York City and his use of that residence for sex trafficking of Jane Doe 43 and others, as well as information about Ghislaine Maxwell evading service of proce

BSF BOIES SCHILLER FLEXNER Sigrid S. • Telephon Email: smccaw ey to s p.com November 29, 2017 VIA ECF Honorable John G. Koeltl Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 Re: Jane Doe 43. v. Epstein, et al. Case No.: 17-CIV-0061

nihan United States Courthouse 500 Pearl Street New York, NY 10007 Re: Jane Doe 43. v. Epstein, et al. Case No.: 17-CIV-00616 (JGK) Dear Judge Koeltl: We represent Plaintiff Jane Doe 43 in the above-referenced matter. The Defendants Jeffrey Epstein and Lesley Groff (hereinafter referred to simply

ounsel again unilaterally served a deposition notice for October 25, 2018, in New York, knowing that counsel and Ms. Maxwell are not available for a New York deposition on that date. Given the thrice-served notices for Ms. Maxwell's depositions, each for dates and locations that either she or her counsel

H A D D O N MORGAN FOREMAN October 4, 2018 Via ECF Hon. John G. Koeltl United States District Judge United States District Court Daniel Patrick Moynihan Courthouse Southern District of New York 500 Pearl Street New

A. MennInger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831/364 DC 303.832.2628 VAVW .hmil ow c o m Imenningergithmflaw.com Dear Judge Koeltl: This is a letter motion requesting a pre-motion discovery conference regarding the need for a protective order pursuant to Fed. R. Civ. P. 26(c)(1

vel records between 2000 and the present reflecting your presence in: (a) Palm Beach, Florida or immediately surrounding areas; (b) 9 E. 71m Street, New York, NY 10021; (c) New Mexico; (d) U.S. Virgin Islands; (e) any jet or aircraft owned or controlled by Jeffrey Epstein. You indicate that you are withh

rovide corroborating testimony to Plaintiff as well as destruction of documents and other evidence regarding what they had done." FAC at 65. Judge Koeltl has already recognized the breadth of the allegations in denying a motion to strike a part of the complaint dealing with earlier events. In particul

2018 under undisclosed terms.K481671[681 Affidavit filed by (2019) On 16 April 2019, went public and filed a sworn affidavit in federal court in New York, alleging that she and her 15-year-old had been sexually assaulted by Epstein and Maxwell in se arate locations in 1 6. affidavit was filed in sup

xwell has a history of b ii tachable during legal proceedings.[81][98][9O100] During the lawsuit filed in 2017 from against Maxwell, District Judge John G. Koeltl granted a motion for "alternative service" on the grounds that the plaintiffs efforts to reach Maxwell were persistently thwarted; these included h

under undisclosed terms.Q44-82 6-711-§8) Affidavit filed by (2019) On 16 April 2019, went public and filed a sworn affidavit in federal court in New York, alleging that she and her 15-year-ol had been sexually assaulted by Epstein and M ' separate locations in 1996. affidavit was filed in suppo fa

Maxwell has a history of bil achable during legal proceedings.1M198i199}1imi During the lawsuit filed in 2017 from against Maxwell, District Judge John G. Koeltl granted a motion for "alternative service" on the grounds that the plaintiffs efforts to reach Maxwell were persistently thwarted; these included h

D ON: 10/26/2016 12:00:00 AM *** THIS DATA IS FOR INFORMATION PURPOSES ONLY *** Page 108 CIVIL SUMMONS NASSAU COUNTY SUPREME COURT, NASSAU COUNTY, NEW YORK EPSTEIN JEFFREY v. FLORAL PARK Plaintiff: EPSTEIN JEFFREY Defendant: FLORAL PARK Tax ID: 000000000 Docket Number: 20140304779 Filing Date: 5/8/

, Lesley Groff; Jeffrey Epstein; Ghislaine Maxwell DOCKET CASE NUMBER: 1:17cv616 FILING DATE: 1/26/2017 JURISDICTION: Federal Question JUDGE: John G. Koeltl NATURE OF SUIT: 890 Other Statutory Actions FILING TYPE: Civil CAUSE: Fed. Question28 USC 1331 JURY DEMAND: Plaintiff PLAINTIFF ATTORNEY(S): Si