Epstein Secrets

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") and write to respon

Defendants") and write to respond to Bradley J. Edwards' letter of October 5, 2017. Mr. Edwards' contention that Plaintiff be allowed to depose Mr. Epstein on the ground that Defendants have been engaging in discovery from another matter before Judge Robert Sweet is baseless. Defendants have not engage

within seven (7) days. The Court then can dispose of the matter in its entirety. Respectfully submitted, Michael C. Miller Counsel for Defendants Jay Epstein and Lesley Groff Doc # DC-10491295 v.1 EFTA00583064

eet New York, NY 10007-1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear

' contention that Plaintiff be allowed to depose Mr. Epstein on the ground that Defendants have been engaging

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

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 ("Defendants") in the

ork 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 ("Defendants") in the above- referenced lawsuit ("Action"). The Defendants intend to move to dismiss the Action based on, inter alia, the failu

e STEPTOS E JOHNSON LIP We represent defendants Jeffrey Epstein and ("Defendants") in the above- referen

duced documents, i.e., the Plaintiff's Evidence. Mr. Epstein, through his counsel, as a non-party witness in t

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"

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 you via facsimil

k 10007-1312 RE: Jane Doe 43 v. Epstein, et al., No. 17 Civ. 616 (JOK) Dear Judge Koelti: StePtOe STEPTOO a JOHNSON LLP We represent defendants Jeffrey Epstein and Lesley Groff ("Defendants") in the above- referenced lawsuit ("Action"). The Defendants intend to move to dismiss the Action based on, inter ali

e STEPTOO a JOHNSON LLP We represent defendants Jeffrey Epstein and Lesley Groff ("Defendants") in the ab

produced documents i.e. the Plaintiff's Evidence. Mr. Epstein, through his counsel, as a non- party witness in

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

17 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 not have a basis for

unequivocally, answers to all 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

Y 10036 [email protected] Re: Jane Doe 43 v. Jeffrey Epstein, et al. Case No.: 17-cv-616 Dear Mr. Mi

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

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 not have a basis for

unequivocally, answers to all 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

Americas New York NY 10036 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Case No.: 17-cv-616 Dear Mr. Mi

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