Epstein Secrets

nihan United States Courthouse 500 Pearl Street New York, New York 10007-1312 RE: Jane Doe 43 v. Epstein, et al.,No.17 Civ. 616 (JGK) Dear Judge Koeltl: Steptoe STEPTOS E JOHNSON LIP We represent defendants Jeffrey Epstein and ("Defendants") in the above- referenced lawsuit ("Action"). The Defend

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 District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, New York

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

w Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, 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, N

k Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 RE: Jane Doe 43 v. Epstein et al., No. 17 Civ. 616 (JOK) Dear Judge. Koeltl: We represent Plaintiff Jane Doe 43 in the above-captioned action. We write in response to a letter that Defense counsel for Jeffrey Epstein et al.

. 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 New York. NY 10036 January 3, 2018 Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civi

ted States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Judge Koeltl: We represent Defendants Jeffrey Epstein and Lesley Groff ("Defendants") in the above- referenced matter. Defendants have been attempting to reach a

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

"Defendants"), upon the pleadings and prior proceedings had herein, and on the grounds stated below, intend to move this Court before the Honorable John G. Koeltl at the United States Courthouse, 500 Pearl Street, New York, New York, for an Order pursuant to Fed.R.Civ.P. 11(c), sanctioning Plaintiff and Plain

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