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,

the Americas www.steptoe.com SUBMITTED UNDER SEAL July 14, 2017 Hon. John G. Koeltl United States District Court, Southern District of New York Daniel Patrick Moynihan United 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 Koelt

d light on a jurisdictional issue: If so, he remains free, of course, to obtain that same information by deposing her in this case. And, of course, Jane Doe 43 can obtain her own information relevant to jurisdiction by deposing Epstein and the other Defendants in this case. No good reason exists for delayin

modification of the protective order entered in Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS), any issues re

[email protected] July 17, 2017 SUBMITTED UNDER SEAL Hon. John G. Koeltl United States District Court for the Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 RE: Jane Doe 43 v. Epstein et al., No. 17 Civ. 616 (JOK) Dear Judge. Koeltl: W

("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

Americas New York, NY 10036 main wontsteptoe.com July 14, 2017 Hon. John G. Koeltl United States District Court, Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, New York 10007-1312 RE: Jane Doe 43 v. Epstein, el at, No. 17 Civ. 616 (JGK) Dear Judge Koel

dismiss is pending. See, e.g., Daventree Ltd. v. Republic of Azerbaijan, 349 F.Supp.2d 736, 765 (S.D.N.Y. 2004). The jurisdictional discovery that Jane Doe 43 requests is simply for a one-hour deposition of defendant Epstein. The deposition could be conducted over the telephone to minimize inconvenience t

BSF BOIES SCHILLER FLEXNER Sigrid S. • Telephon Email: smccaw ey to s p.com November 29, 2017 VIA ECF Honorable John G. Koeltl Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 Re: Jane Doe 43. v. Epstein, et al. Case No.: 17-CIV-00616 (JGK) Dear Judge Koelt

otion to disqualify Mr. Boies and his law firm in Giuffre v. Dershowitz, 1:19-cv-03377 (SDNY), a pending d

74$5 USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC DATE FILED: Hon. Richard M. Berman U.S. District Court for the Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 re: United States v. Epstein. I :19-cr-00490-RMB Dear Judge Berman: 0, 2019

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

urt and send a copy to Class Counsel and Defendant's Counsel, at the addresses listed below by , 2023. The Court's address is: Hon. Jed S. Rakoff, Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York, NY 10007; Class Counsel's address is: Boies Schiller Flexner LLP, 55 Hudson Yards, 20th Floor,