Epstein Secrets

("Defendants") in the above- referenced lawsuit ("Action"). The Defendants intend to move to dismiss the Action based on, inter alia, the failure of Jane Doe 43 ("Plaintiff") to establish personal jurisdiction over the Defendants ("Motion to Dismiss"). The Plaintiff provided deposition testimony and produced

laims in the present action, and produced documents, 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 c

-RWS Document 39-1 Filed 03/02/16 Page 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

tion designated "CONFIDENTIAL" shall be information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff Virginia Roberts Giuffre and (b) defendant Ghislaine Maxwell. 4. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial o

and statutory privacy interests of (a) plaintiff Virginia Roberts Giuffre and (b) defendant Ghislaine Maxwell. 4.

tory privacy interests of (a) plaintiff Virginia Roberts Giuffre and (b) defendant Ghislaine Maxwell. 4. CONFIDE

w York I DIME• ma z k a u c i 15-cv-07433-RWS Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell,

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 failure of Jane Doe 43 ("Plaintiff") to establish personal jurisdiction over the Defendants ("Motion to Dismiss"). The Pl

m 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 alleging jurisdiction in New York. Specifically you stated in your letter to Judge Koeltl as follows: "We respectfully s

dition, you 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 fil

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 Defendants have no present connection to New York upon whi

("Defendants") in the above- referenced lawsuit ("Action"). The Defendants intend to move to dismiss the Action based on, inter alia, the failure of Jane Doe 43 ("Plaintiff") to establish personal jurisdiction over the Defendants ("Motion to Dismiss"). The Plaintiff provided deposition testimony and produced

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 alia, the failure of Jane Doe 43 ("Plaintiff") to establish personal jurisdiction over the Defendants ("Motion to Dismiss"). The Pl

uals. Her public federal court filings in those cases are littered with implausible factual assertions and irrational legal arguments. For example, Jane Doe 7 3 EFTA00145649 Case 1:22-cv-10019-JSR Document 256 Filed 11/02/23 Page 8 of 23 In all instances, . Firs . Second, Third. Jane Doe 7 also claims

he Court should ignore these baseless allegations. M— the administrator of the Epstein Victims' Compensation Program, which ended long before this Action was filed and is unrelated to the Settlement—is not a Claims Administrator in this case, and Jane Doe 7 fails to 8 EFTA00145654 Case 1:22-cv-100

6 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 alleging jurisdiction in New York. Specifically you stated in your letter to Judge Koeltl as follows: "We respectfully s

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 Defendants have no present connection to New York upon whi

applications to the Epstein Victim's Compensation Fund. They have also represented an Epstein survivor in her civil lawsuit against Prince Andrew, Giuffre v. Andrew (21-cv-6702) (S.D.N.Y.). 23. Sigrid McCawley: Sigrid McCawley is a Managing Partner of BSF. Ms. McCawley's experience and talents have b

forth my background as a mediator to provide context for the comments that follow, and to demonstrate that my perspective on the settlement of this Action is rooted in significant experience in the resolution of complex litigation. As described below, this Action presented complicated legal, factual,

12, 2016, and in support thereof states the following: On January 16, 2016, Defendant Alan M. Dershowitz began the deposition of non-party Virginia Roberts Giuffre (“Roberts”). Pursuant to this Court’s January 12, 2016 Confidentiality Order, that transcript currently is under seal. The Confidentiality Order shou

n M. Dershowitz began the deposition of non-party Virginia Roberts Giuffre (“Roberts”). Pursuant to this Court’s January 12,

support thereof states the following: On January 16, 2016, Defendant Alan M. Dershowitz began the deposition of non-party Virginia Roberts Giuffre (“Roberts”). Pursuant to this Court’s January 12, 2016 Confidentiality Order, that transcript currently is under seal. The Confidentiality Order should be modi

oena for documents sought for a federal action.” c. Category 3 — Documents that Contain Personal Financial Information Completely Irrelevant to this Action Defendant also wrongfully abuses the subpoena power to seek personal financial information from this non-party. See Woodward v. Berkery, 714 So. 2d

poena, as to the law firm, is quashed As to the "Jane Doe #3" subpoena: The motion is granted as to request #9

he attends star studded charity gala On behalf of Action on Addiction Charlie Sheen cuts a casual figure whil

DISTRICT OF NEW YORK pane eee ene een enenenee X VIRGINIA L. GIUFFRE, : Plaintiff, V. 15-cv-07433-RWS GHISLAINE MAXWE

deo | Travel | Columnists sex offender friend flew to Britain to meet him By SHARON CHURCHER UPDATED: 08:02 EST, 2 March 2011 101 View comments » Virginia Roberts reveals she is 'Jane Doe 102’ in Jeffrey Epstein case + Mother-of-three spent four years as millionaire's personal masseuse - She describes being f

ory up to the Second Circuit. 1 document attached I Read full article » ENERGY & ENVIRONMENTAL Statoil, Texaco Units Want Brakes Kept On $16 Award Action A Statoil unit and a Texaco subsidiary have asked a New York federal court to keep on ice their litigation seeking to enforce roughly $1 billion in

i has assailed a motion to hand over more documents in a multidistrict litigation against generic-drug maker Zydus over antitrust claims, telling a Virginia federal court it has already provided plaintiff drug buyers with 3,600 pages. Read full article » JOBS Search full listings or advertise your job