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ce in its entirety is probative of the issues which will be raised in the Motion to Dismiss, including whether the statute of limitations has run on Jane Doe's claim, whether the Court in the Jane Doe Matter has personal jurisdiction over the defendants, and whether the Motion to Dismiss should be granted
vance of the Jane Doe Evidence to the Jane Doe Matter, Jane Doe should not be permitted to limit Intervenors' legal arguments by dictating which of the Jane Doe Evidence Intervenors should be allowed to include in their pleadings in that matter. Finally, Mr. Epstein already possesses the Jane Doe Evidence,
ter ("Motion to Dismiss"). The Jane Doe Evidence is highly probative of the issues the Intervenors intend to raise in the Motion to Dismiss. To use the Jane Doe Evidence to support the Motion to Dismiss, however, the Intervenors need relief from the Protective Order. Judge Koeltl instructed the Intervenors
orney's Office for violating Jane Doe #1 and Jane Doe #2's rights; • A monetary sanction imposed against the U.S. Attorney's Office, to be paid to Jane Doe #1 and Jane Doe #2 directly or to any other appropriate person or entity;; • An order establishing the precise rule regarding the timing of the obli
Yet Would Otherwise Evade Review. For all the reasons just explained, the Court clearly is in a position to address the CVRA violations alleged by the Jane Doe #1 and Jane Doe #2. Even assuming for sake of argument it was not, however, the Court would still clearly possess the ability to review the Governme
orney's Office for violating Jane Doe #1 and Jane Doe #2's rights; • A monetary sanction imposed against the U.S. Attorney's Office, to be paid to Jane Doe #1 and Jane Doe #2 directly or to any other appropriate person or entity;; • An order establishing the precise rule regarding the timing of the obli
Yet Would Otherwise Evade Review. For all the reasons just explained, the Court clearly is in a position to address the CVRA violations alleged by the Jane Doe #1 and Jane Doe #2. Even assuming for sake of argument it was not, however, the Court would still clearly possess the ability to review the Governme
ctive Order as it applies to the Jane Doe Evidence. Mr. Edwards advised that he was generally supportive of the notion that we should get access to Jane Doe's deposition transcript, but needed to re-read the transcript. Mr. Doc. # DC-10276358 v 1 EFTA00583038 Sigrid McCawley, Esq. August 8, 2017 Page
f the,/ Letter, please confirm whether Jane Doe consents to the defendants' application in the Matter for relief from the Protective Order to use the Jane Doe Evidence in support of their motion to dismiss the Amended Complaint in the Jane Doe Matter. In addition to sending the July 7 Letter in the midst
Entities connected to both Jane Doe and the Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONMaria Farmer
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATIONRoy Black
PERSONMartin Weinberg
PERSON
Marc Rich
PERSON
Julie K. Brown
PERSON
Harvey Weinstein
PERSON
Woody Allen
PERSON
Michael Cohen
PERSON
Samantha Power
PERSON
Jackie Perczek
PERSONGarcia
PERSON