Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE 43, Plaintiff, VS. JEFFREY EPSTEIN, GHISLAINE MAXWELL, AND Defendants. CASE NO. 17 Civ 616 (JGK) MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS EFTA00307096 ARGUMENT 1 A.

er Defendants 21 F. Venue Is Improperly Laid in the Southern District of New York 22 CONCLUSION 22 EFTA00307097 Defendants Jeffrey Epstein ("Epstein") and (a") (collectively "Defendants") submit this memorandum in support of their motion to dismiss the First Amended Complaint ("FAC") filed by

th substance and cited sources. See FAC at ¶11 ("Defendant Epstein is widely recognized..."), ¶22 ("Defendants Epst

TRICT OF NEW YORK JANE DOE 43, Plaintiff, VS. JEFFREY EPSTEIN, GHISLAINE MAXWELL, AND Defendants. C

rgin Islands. Dated: July 2017 Respectfully submitted, STEPTOE & JOHNSON, LLP By /s/ Michael Miller Justin Y.K. Chu Attorneys for Defendants JEFFREY EPSTEIN & To: FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Brad Edwards Attorney for Plaintiff Jane Doe 43 ALSTON & BIRD, LLP Alexander S L

menced until January 27, 2017, more than four years after any of the events alleged in the FAC occurred. Plaintiff's claim is therefore time-barred. Abarca v. Little, 54 F.Supp.3d 1064, 1068 (Minn. 2014). As the Court stated in Abarca, a claim under Section 1595 had a four-year of statute of limitation

mim Michael C. Miller May 15, 2017 Brad Edwards, Esq. Re: v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Brad: Steptoe stenos • JOHNSON 1.0 In accordance with the Court's May 15, 2017 Stipulation and Order in t

stenos • JOHNSON 1.0 In accordance with the Court's May 15, 2017 Stipulation and Order in the above- referenced matter, defendants Jeffrey Epstein ("Epstein") and (collectively "Defendants" se f rth in this letter sinds pursuant to which the Complaint filed by plaintiff ("Plaintiff" or ' ') should be

"in addition to their requiring Plaints to prow e Defendant Epstein with sex acts, Defendants continued to pressure

Miller May 15, 2017 Brad Edwards, Esq. Re: v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear

d until January 27, 2017, more than four years after any of the events alleged in the Complaint occurred. Plaintiffs claim is therefore time-barred. Abarca v. Little, 54 F.Supp.3d 1064, 1068 (Minn. 2014). As the Court stated in Abarca, a claim under Section 1595 had a four-year of statute of limitation

ss you from the podium there? THE COURT: Sure. MR. MILLER: Michael Miller from Steptoe & Johnson, and as I indicated we are here on behalf of and Jeffery Epstein, and Your Honor, we respectfully submit that the amended complaint before you is legally deficient and should be dismissed for several reasons, t

MILLER: Good afternoon, your Honor. Michael Miller and Justin Chu from the law firm of Steptoe & Johnson, and Darren Indyke, who is counsel to Mr. Epstein. We represent Jeffery Epstein and , and yesterday filed a substitution of counsel with respect to , whose previously existing counsel is also he

rdered by the defendant Maxwell to have sex with defendant Epstein. Defendants Maxwell, and Epstein each fraudulen

& Johnson, and Darren Indyke, who is counsel to Mr. Epstein. We represent Jeffery Epstein and , and yesterd

that analysis has been applied to conclude that the ten year statute of limitations applies. We cited a case out of the District of Minnesota, the Abarca case, that takes a different view, and the thinking in the Abarca case -- which we think is the correct thinking -- THE COURT: So far the thinking

.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

Court Should Modify the Protective Order I I CONCLUSION 15 CONFIDENTIAL - FILED UNDER SEAL EFTA00805390 TABLE OF AUTHORITIES Page(s) Cases Abarca v. Little, 54 F. Supp. 3d 1064 (D. Minn. 2014) 4 Charter Oak Fire Ins. Co. v. Electrolux Home Prods., Inc., 287 F.R.D. 130 (E.D.N.Y. 2012) 11, 1

ds, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Re: Jane Doe 43 v. Jeffery Epstein, et al. Civil Action No. 17-cv-616 Dear Brad: In accordance with the procedures directed by the Court at the initial case manar. conference in th

ordance with the procedures directed by the Court at the initial case manar. conference in the above-referenced matter, defendants Jeffrey Epstein ("Epstein") and ("=") (collectively "Defendants") set forth in this letter the pursuant to which the Complaint filed by plaintiff ("Plaintiff" or a") sho

addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, Defendants continued to pressure h

erence in the above-referenced matter, defendants Jeffrey Epstein ("Epstein") and ("=") (collectively "De

until January 27, 2017, more than four years after any of the events alleged in the Complaint occurred. Plaintiff's claim is therefore time-barred. Abarca v. Little, 54 F.Supp.3d 1064, 1068 (Minn. 2014). As the Court stated in Abarca, a claim under Section 1595 had a four-year of statute of limitation