Epstein Secrets

The Claim Is Barred by the Statute of Limitations 19 E. The Court Does Not Have Jurisdiction Over Defendants 21 F. Venue Is Improperly Laid in the Southern District of New York 22 CONCLUSION 22 EFTA00307097 Defendants Jeffrey Epstein ("Epstein") and (a") (collectively "Defendants") submit this memorandum

itigate this matter would be in the U.S. Virgin Islands. Dated: July 2017 Respectfully submitted, STEPTOE & JOHNSON, LLP By /s/ Michael Miller Justin Y.K. Chu Attorneys for Defendants JEFFREY EPSTEIN & To: FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Brad Edwards Attorney for Plaintiff J

s to establish that the Court possesses personal jurisdiction over the Defendants; and e) the FAC fails to establish that venue is properly laid in the Southern District of New York. Finally, Plaintiff's deposition testimony, and the documents that she produced, in the action captioned v. Maxwell, No. 15 Civ. 7433

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, FISTOS & LEHRMAN, P.L. Brad Edwar

a claim which is barred by the statute of limitations; (c) fails to allege personal jurisdiction over Intervenors; and (d) improperly lays venue in the Southern District of New York. The FAC alleges a brief adult relationship between Jane Doe and Mr. Epstein beginning in October 2006. Jane Doe describes herself as a

Jane Doe Matter; and 3. Any other relief the Court deems just and proper. Dated: New York, New York October 5, 2017 ly subwitted, el C. Miller Justin Y.K. Chu Michael A. Keough STEPTOE & JOHNSON LLP 1114 Avenue of the Americas New York, New York 10036 (212) 506-3900 nuniller®steptoc.com jchu@steptoc.

s to establish that the Court possesses personal jurisdiction over the Defendants; and e) the FAC fails to establish that venue is properly 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 Ci

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, FISTOS & LEHRMAN, P.L. Brad Edwar

all times material to this cause of action 9. A substantial part of the acts, events, and omissions giving rise to this cause of action occurred in the Southern District of New York; venue is proper in that District. 28 U.S.C. section 1391(b)(2) 2 EFTA00615940 Case 1:17-cv-00616-3GK Document 45 Filed 06/05/17 Pag

n the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. STEPTOE & JOHNSON, LLP Michael C. Miller Justin Y.K. Chu Attorneys for Defendants Jeffrey Epstein & By: /s/ Bradley J. Edwards 31 EFTA00615969