Epstein Secrets

804698 Michael C. Miller 212 506 3955 1114 Avenue of the Americas New York, NY 10036 main wontsteptoe.com 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 10007-1312 RE: Jane Doe 43 v

" Exhibit A at ¶ 4. Further, any documents marked "Confidential" must be returned or destroyed at the conclusion of the case. Id. at1 12. A copy of the Protective Order is attached hereto as Exhibit A. Out of respect for the provisions of the Protective Order, we are submitting this letter to the Court under seal.

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 10007-1312 RE: Jane Doe 43 v

that case.' Under the terms of the Protective Order, "Confidential" documents "shall not be disclosed or used for any purpose except the A copy of the Protective Order is attached hereto as Exhibit A. Out of respect for the provisions of the Protective Order, we are submitting this letter under seal. EFTA00793037

ed via CM/ECF a copy of this Appellee Maxwell's Response to Order to Show Cause on the following persons: The Hon. Robert W. Sweet District Judge United States District Court for the Southern District of New York (via United States mail) Christine N. Walz ([email protected]) Madelaine J. Harrington (madelaine.

c disclosure of any sealed or redacted summary judgment materials. The OTSC is, however, incomplete because the dozens of individuals who relied on the Protective Order had no notice of the Order and have had no opportunity to respond. We interpose the following general objections: 1. All sealed and redacted summa

if any of the victims identified in the federal investigation file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the U.S. District Court for the Southern District of Florida over his person and the subject matter. Epstein will not contest that the identified victims arc persons who,

s they agreed to be bound by a Protective Order. Each victim (or her attorney) was provided with notice of the Court's ruling, and several executed the Protective Order and were provided with copies of the Non-Prosecution Agreement. From the beginning, Epstein has "vigorously defended" the suits, and has filed seve

ents and criminal prosecution commensurate with the crimes Mr. Epstein has committed.” On July 7, 2008, Edwards filed his emergency petition in the U.S. District Court for the Southern District of Florida on behalf of Courtney Wild, who was then identified only as “Jane Doe.” She was soon joined by a second petit

d by a Protective Order entered by the Court. If [the victim] would like to review the Agreement, please let me know, and I will forward a copy of the Protective Order for her signature. The government shared draft versions of the September letter with Epstein’s counsel and responded to criticism of the content o