Epstein Secrets

istrict 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. Epstein, el at, No. 17 Civ. 616 (JGK) Dear Judge Koeltl: Steptoe STEPTOE E JOHNSON LIP I am writing to advise that we inadvertently sent yo

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

R August 7, 2017 VIA EMAIL Michael Miller, Esq. Steptoe & Johnson, LLP 1114 Avenue of the Americas New York NY 10036 [email protected] Re: Jane Doe 43 v. Jeffrey Epstein, et al. Case No.: 17-cv-616 Dear Mr. Miller, We are in receipt of you Rule 11 notice wherein you state that Jane Doe 43 does

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

istrict 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. Epstein, et al.,No.17 Civ. 616 (JGK) Dear Judge Koeltl: Steptoe STEPTOS E JOHNSON LIP We represent defendants Jeffrey Epstein and ("Defend

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"

IES SCHILLER FLEXNER August 7, 2017 VIA EMAIL Michael Miller, Esq. Steptoe & Johnson, LLP 1114 Avenue of the Americas New York NY 10036 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Case No.: 17-cv-616 Dear Mr. Miller, We are in receipt of you Rule 11 notice wherein you state that Jane Doe 43 does

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

ctober 5, 2017 VIA ECF 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. Civil Action No. 17-cv-616 Dear Judge Koeltl: We represent Defendants Jeffrey Epstein and Lesley Groff ("Defendants"

rsuant to the Protective Order in the action. Mr. Epstein, through his counsel, as a non-party witness in the action, was provided with a copy of the Plaintiff's Evidence. The Plaintiff's Evidence is dispositive of the Motion to Dismiss that Defendants plan to file, and particularly on the issue of whether the Court l