Epstein Secrets

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

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"

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

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

submitted a motion to Judge Koeltl requesting leave to file a Motion with Judge Sweet for the release of Jane Doe 43's transcript in the Guiffre v. Maxwell matter. It was our understanding you were going to be filing your motion with Judge Sweet on Monday, July 24, 2017 yet you failed to file the motio

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

ddition, you submitted a motion to Judge Koeltl re uestin leave to file a Motion with Judge Sweet for the release of Jane Doe 43's transcript in th Maxwell matter. It was our understanding you were going to be filing your motion with Judge Sweet on Monday, July 24, 2017 yet you failed to file the motio

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

d premature fishing expedition. As we previously advised the Court, the Plaintiff gave deposition testimony and documents in a matter captioned v. Maxwell, No. 15 Civ. 7433 (RWS) (the egio action") shortly after she filed this action (the "Plaintiff's Evidence"). The Plaintiff's Evidence was designate

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