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,

that case.' Under the terms of the Protective Order, "Confidential" documents "shall not be disclosed or used for any purpose except the A copy of the Protective Order is attached hereto as Exhibit A. Out of respect for the provisions of the Protective Order, we are submitting this letter under seal. EFTA00793037

rovides the public and the press a constitutional right of access to all trials, criminal or civil." Id. at 468 (citing Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 580, 100 S.Ct. 2814, 65 L.Ed.2d 973 (1980) ) (internal citation omitted). This right applies specifically to "related proceedings an

mmon law right of access, or of the more robust First Amendment right to access certain judicial documents. Id. at 119-20. It is a given accepted by the Protective Order that the trial and all trial documents are accessible and public absent special circumstances. *8 1121 II3IUnder the common law approach, once a do

("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

" Exhibit A at ¶ 4. Further, any documents marked "Confidential" must be returned or destroyed at the conclusion of the case. Id. at1 12. A copy of the Protective Order is attached hereto as Exhibit A. Out of respect for the provisions of the Protective Order, we are submitting this letter to the Court under seal.

he Gee v. Maxwell matter ("Protective Order" and "Giuffre Matte?) and ii) to dismiss the plaintiff's First

ter and the defendants' motion to dismiss the FAC. In fact, the July 17 Order does not set any deadline for submission of the motion for relief from the Protective Order; it only requires the parties to meet and confer before filing that motion — which the defendants attempted to do with Mr. Edwards. Moreover, the J

while a minor," was a victim of an offense. 3. Jane Doe #3 v. Epstein, 08-CV-80232-KAM: This suit was filed

s they agreed to be bound by a Protective Order. Each victim (or her attorney) was provided with notice of the Court's ruling, and several executed the Protective Order and were provided with copies of the Non-Prosecution Agreement. From the beginning, Epstein has "vigorously defended" the suits, and has filed seve

while a minor," was a victim of an offense. 3. Jane Doe #3 I. Epstein, 08-CV-80232-KAM: This suit was filed

s they agreed to be bound by a Protective Order. Each victim (or her attorney) was provided with notice of the Court's ruling, and several executed the Protective Order and were provided with copies of the Non-Prosecution Agreement. From the beginning, Epstein has "vigorously defended" the suits, and has filed seve