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,

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

er 3, 2017, we submitted a letter motion to Judge Sweet seeking permission to file under seal a motion to modify the Protective Order entered in the Giuffre matter before him. On October 4, 2017, Judge Sweet granted the letter motion to file under seal. As a result, we will be filing tomorrow the motion

s Courthouse 500 Pearl Street New York, NY 10007.1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Judge Koeltl: Steptoe ......... ji b. We are counsel for Defendants Jeffit E stein and In the above-referenced matter. We write jointly with Defendant (toge”ifendants

("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

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