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,

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"

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

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

("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

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

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

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