Epstein Secrets

.S.C. § 1595 3, 4 Other Authorities Fed. R. Civ. P. 24 2, 9, 10 CONFIDENTIAL - FILED UNDER SEAL EFTA00805391 Third-Party Proposed Intervenors Jeffrey Epstein and Lesley Groff (the "Intervenors") respectfully submit this Memorandum of Law in support of their motion to intervene in v. Maxwell, No. 15 Civ.

tective Order") for the reasons set forth below. PRELIMINARY STATEMENT Intervenors are two of the defendants in an action captioned Jane Doe 43 v. Epstein, et al, No. 17 Civ. 616 (JGK), currently pending before Judge John G. Koeltl (the "Jane Doe Matter"). Jane Doe 43 ("Plaintiff" or "Jane Doe") filed

EFTA00805391 Third-Party Proposed Intervenors Jeffrey Epstein and Lesley Groff (the "Intervenors") res

are based primarily on the alleged misconduct of Mr. Epstein. Indeed, shortly after Jane Doe filed her suit ag

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

ust 8, 2017 Sigrid McCawley, Esq. Boles Schiller & Flexner LLP 401 East Las Olas Blvd. Suite 1200 Fort Lauderdale, FL 33301 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Ms. McCawley: We write in response to your August 7, 2017 letter ("August 7 Letter"), regarding the brief

ief defendants are se,from the Protective Order in the Matter, we will file an appropriate motion in the Matter. Finally, we decline to make Mr. Epstein available for a deposition. Discovery has been sensibly stayed in this proceeding pending further order of the Court. See Order dated May 24, 2017

0 Fort Lauderdale, FL 33301 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear

tion in the Matter. Finally, we decline to make Mr. Epstein available for a deposition. Discovery has been s

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

t the victims' pleadings are facially deficient, the Court must assume the truth of the victims' allegations — specifically that the Government and Epstein deliberately conspired to enter into a secret non- prosecution agreement in violation of the victims' rights under the Crime Victims' Rights Act (CV

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

t the victims' pleadings are facially deficient, the Court must assume the truth of the victims' allegations — specifically that the Government and Epstein deliberately conspired to enter into a secret non- prosecution agreement in violation of the victims' rights under the Crime Victims' Rights Act (CV

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