Epstein Secrets

manner we will be forced to raise the issue of intentional delay with Judge Koeltl. Sincerely, /s/ Sigrid McCawley Sigrid McCawley SM/akc cc: Bradley Edwards (via E-mail) Paul Cassell (via E-mail) Stan Pottinger (via E-mail) EFTA00792781

d McCawley Sigrid McCawley SM/akc cc: Bradley Edwards (via E-mail) Paul Cassell (via E-mail) Stan Pot

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

manner we will be forced to raise the issue of intentional delay with Judge Koeltl. Sincerely, /s/ Sigrid McCawley Sigrid McCawley SM/akc cc: Bradley Edwards (via E-mail) Paul Cassell (via E-mail) Stan Pottinger (via E-mail) EFTA00613862

d McCawley Sigrid McCawley SM/akc cc: Bradley Edwards (via E-mail) Paul Cassell (via E-mail) Stan Pot

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

al. Civil Action No. 17-cv-616 Dear Judge Koeltl: We represent Defendants Jeffrey Epstein and Lesley Groff ("Defendants") and write to respond to Bradley J. Edwards' letter of October 5, 2017. Mr. Edwards' contention that Plaintiff be allowed to depose Mr. Epstein on the ground that Defendants have been engaging

We represent Defendants Jeffrey Epstein and Lesley Groff ("Defendants") and write to respond to Bradley J. Edwards' letter of October 5, 2017. Mr. Edwards' contention that Plaintiff be allowed to depose Mr. Epstein on the ground that Defendants have been engaging in discovery from another matter befor

rsuant to the Protective Order in the action. Mr. Epstein, through his counsel, as a non-party witness in the action, was provided with a copy of the Plaintiff's Evidence. The Plaintiff's Evidence is dispositive of the Motion to Dismiss that Defendants plan to file, and particularly on the issue of whether the Court l