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he Court in this matter, it shall be accompanied by a Motion to Scal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. 11. A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating th
on she was denoted in another atter pending in this District During that deposition, Plaintiff gave sworn testimony and produced documents i.e. the Plaintiff's Evidence. Mr. Epstein, through his counsel, as a non- party witness in the action, was provided with a copy of the Plaintiff's Evidence. These materials wer
ll of the questions that you have raised. We would also intend to explore your earlier representation to the Court that Epstein lacks contacts with the Southern District of New York. Please let us know a date that works for you and your client in the next two weeks for a one hour deposition of Jeffrey Epstein. BOIE
ave a basis for alleging jurisdiction in New York. Specifically you stated in your letter to Judge Koeltl as follows: "We respectfully submit that the Plaintiff's Evidence provides grounds for this Court to dispose of the Action entirely, inter alia, under Rule 12(b)(2) for lack of personal jurisdiction. Because the D
he Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. 11. A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating th
uments, i.e., the Plaintiff's Evidence. Mr. Epstein, through his counsel, as a non-party witness in the Giuffre action, was provided with a copy of the Plaintiff's Evidence. These materials were marked "Confidential" pursuant to the Protective Order in that case.' Under the terms of the Protective Order, "Confidential"
ll of the questions that you have raised. We would also intend to explore your earlier representation to the Court that Epstein lacks contacts with the Southern District of New York. Please let us know a date that works for you and your client in the next two weeks for a one hour deposition of Jeffrey Epstein. BOIE
ave a basis for alleging jurisdiction in New York. Specifically you stated in your letter to Judge Koeltl as follows: "We respectfully submit that the Plaintiff's Evidence provides grounds for this Court to dispose of the Action entirely, inter alia, under Rule 12(b)(2) for lack of personal jurisdiction. Because the D
Entities connected to both the Southern District and the Plaintiff's Evidence

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Virginia Giuffre
PERSON
Paul Cassell
PERSON
United States District Court
ORGANIZATION
David Boies
PERSON
Lesley Groff
PERSONSigrid McCawley
PERSONBates
PERSONSweet
PERSON
Michael Milken
PERSON
NEW YORK NY
LOCATIONJohn G. Koeltl
PERSON
Daniel Patrick Moynihan
PERSONAction
ORGANIZATIONthe Protective Order
ORGANIZATION
Steptoe
ORGANIZATION