Epstein Secrets

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

e Motion to Dismiss. EFTA00792777 Honorable John G. Koeltl July 17, 2017 Page 3 Very Truly Yours, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS and LEHRMAN, PL Bradley J. BJE:mwk EFTA00792778 2502658500 TRANSACTION REPORT FAX( TX) P.01/01 JUL/17/2017/MON 11:09 AM 001 DATE JUL/17 START T. RE

nd then you issue a press release that doesn't say, "I deny being a co-conspirator," that doesn't talk about that document at all other than to say Jane Doe 3 is to then say we get to introduce a bunch of evidence because we said she was a co-conspirator against her SOUTHERN DISTRICT REPORTERS, P.C. EFT

LTZ, ESQ. S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH For Plaintiff BY: PAUL G. CASSELL, ESQ. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS, LEHRMAN, P.L. Attorneys for Plaintiff BY: BRADLEY J. EDWARDS, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 1 of 31 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO.: 1:17-CV-00616 JANE DOE 43, Plaintiff, vs. JEFFREY EPSTEIN GHISLAINE MAXWELL, AND Defendants. / FIRST AMENDED COMPLAINT Plaintiff JANE DOE 43, by and through her unde

trial by jury on all issues triable as of right by a jury. Dated: June 5, 2017. Respectfully Submitted, FARMER, JAFFE, WEISSING. EDWARDS, FISTOS, LEHRMAN,. 29 EFTA00615967 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 By: /s/ Bradley J. Edwards Bradley J. Edwards PRO HAC VICE

-00616-JGK Document 45 Filed 06/05/17 Page I of 31 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK COMPLAINT CASE NO.: 1:17-C V-00616 JANE DOE 43, U R V I T I V tf el IV Z 3> t del V Plaintiff Ls, EFFREY EP TEIN HI LAINE MAXWELL AND Defendants. FIRST AMENDED COMPLAINT Plaintiff J

all issues triable as of right by a jury. Dated: Januafy-26r 201-7-.June 5, 2017. Respectfully Submitted, FARMER. JAFFE. WaVING. EDWARDS. FISTOS, LEHRMAN, M. EFTA00616000 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 29 EFTA00616001 Case 1:17-cv-00616-JGK Document 45 Filed 06/0

llow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doe #2 under the facts of this case. C. The U.S. Attorney's Office Has Previous

ourt's direction. DATED: March 21.2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS. FIST LEHRMAN. P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe #1 and Jane Doe #2 40 EFT

you issue a press release 22 that doesn't say, "I deny being a co-conspirator," that doesn't 23 talk about that document at all other than to say Jane Doe 3 is 24 to then say we get to introduce a bunch of 25 evidence because we said she was a co-conspirator against her SOUTHERN DISTRICT REPORTERS, P

7 S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH For Plaintiff 18 BY: PAUL G. CASSELL, ESQ. 19 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS, LEHRMAN, P.L. Attorneys for Plaintiff 20 BY: BRADLEY J. EDWARDS, ESQ. 21 HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant 22 BY: JEFFREY S. P