Epstein Secrets

tioned Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, is Lesley Groff, and a i = No. 1:17-cv-00616

w York, captioned Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, is Lesley Groff, and a i = No. 1:17-c

u") in connection with a lawsuit filed in the United States District Court, Southern District of New York, captioned Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, is Lesley Groff, and a i = No. 1:17-cv-00616 (SDNY), filed on January 26, 2017 ("Litigation' ). his letter updates our agreement of March 13, 2

Michael C. Miller Steptoe STEPTOE a JOHNSON LLP 1114 Avenue of the Americas New York, NV 10036 www.steptoe.com August 9, 2018 BY E-MAIL Mr. Jeffrey E. Epstein do Mr. D

writing. 3. Client Communication: The Client's continued attention to this Matter is critical. The Client agrees to respond to communications from Steptoe in a timely manner. Please inform Steptoe in writing of any changes in the name, address, telephone number or e-mail address of the Client entity o

OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Plaintiff, v. 17 Civ. 616 (JGK) JEFFERY EPSTEIN, GHISLAINE MAXWELL, and Defendants. Before: x New York, N.Y. August 7, 2018 2:30 p.m. HON. JOHN G. KOELTL District Judge APPEARANCES BOIES SCHILLER &

ERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00285631 I877DOEC APPEARANCES (Continued) HADDON MORGAN & FOREMAN P.C. Attorneys for Defendant Ghislaine Maxwell BY: LAURA MENNINGER 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALSO PRESENT: ALEXANDER LORENZO SOUTHERN DIS

mises made by the defendants, plaintiff returned to New York City, in the Southern District of New York, and was promptly ordered by the defendant Maxwell to have sex with defendant Epstein. Defendants Maxwell, and Epstein each fraudulently promised plaintiff again that her sexual compliance would be

ll right. OK. I know people personally and professionally at Boies Schiller. I knew Mr. Haddon when I was in private practice. I may know people at Steptoe, but I'm not sure. Nothing about any of that affects anything that I do in the case. I also had dealings with Mr. Boise when I was in private pra

2 of 7 United States District Court Southern District Of New York I DIME• ma z k a u c i 15-cv-07433-RWS Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. X X PROTECTIVE ORDER Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissem

o all parties and an opportunity for them to be heard. 13Y THE STATES DISTRICT JUDGE 6 EFTA00793046 To: Laura Menninger, Esq. Re: Giuffre v. Maxwell, Case No. 1S-cv-07433 United States District Court For the Southern District of New York March 17, 2016 Protective Order by United States District

-07433-RWS Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. X X PROTECTIVE ORDER Upo

ted 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 above- referenced lawsuit ("Action"). The Defendants inten

NFIDENTIAL" shall be information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ohislaine Maxwell. 4. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case. 5. CONFIDENTIAL docum

ct Of New York. ' • Plaintiff, v. Gh isla ine Maxwell, Defendant. X X I ~ tiikn -31_1S) PROTECTI

Case 1:15-cv-07433-RWS Document 39.1 Filed 03/02/16 Page 2 of 7 United States District Court Southern District Of New York. ' • Plaintiff, v. Gh isla ine Maxwell, Defendant. X X I ~ tiikn -31_1S) PROTECTIVE ORDER Upon a showing of good cause in support of the entry of a protective order to protect the

ENUE OF THE AMERICAS NEW YORK, NEW YORK 10036-7703 FACSIMILE: 212 506 3950 VERIFICATION: 212 506 3900 MAIN NUMBER: 212 506 3900 www.steptoe.com Steptoe STIFT°, ♦ JOHNSON I.LP LOS ANGELES, CALIFORNIA FACSIMILE 213 439 9 VERIFICATION: SAN FRANCISCO, CALIFORNIA FACSIMILE: 415 365 6699 VERIFICATIO

esent you ("You") in connection with a lawsuit filed in the United States District Court, Southern Dis rict of rk .oned lar s ioNaffrey Epstein, Ghislaine Maxwell, , and , No. 1:17-cv-00616 (SDNY), filed on January 26, 2017. The terms and conditions that govern this engagement and the services we w

("You") in connection with a lawsuit filed in the United States District Court, Southern Dis rict of rk .oned lar s ioNaffrey Epstein, Ghislaine Maxwell, , and , No. 1:17-cv-00616 (SDNY), filed on January 26, 2017. The terms and conditions that govern this engagement and the services we will prov

HNSON ll• This letter and the attached General Terms and Conditions of Engagement set forth the basis for the engagement of Steptoe & Johnson LLP ("Steptoe") to represent you ("You") in connection with a lawsuit filed in the United States District Court, Southern Dis rict of rk .oned lar s ioNaffrey

will charge the Client for various services and expenses, such as duplication, travel and the like. Expenses for services that are furnished using Steptoe resources (or for contractors that use Steptoe office space, equipment, services or facilities) are billed at a rate that covers direct costs plus a

st, the allegations of coercion are unspecific and wholly conclusory, as exemplified by the allegations in paragraph 45 that "Defendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance. These Defendants threatened Plaint

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 the above- referenced matter, defendants Jeffrey Epstein (

LLP ('Steptoe') to represent you ('You') in connection with a lawsuit filed in the United States District Cowl, Southern District of N y Epstein, Ghislaine No 1:17-cv-00616 Iga The terms and conditions that govern this engagement and the services we will provide are descnbed in detail in the attachme

Mchael C March 8, 2017 BY E-MAIL Dear Ms. Steptoe TTTTT CI 6 JOS/46CP. LP This letter and the attached General Terms and Conditions of Engagement set forth the basis for the engagement of Steptoe