Epstein Secrets

CIIISeeliTh(01$00016-1tai< ClatatilifffIglfi ilerrliSdar464511geffigP21 of 2 Michael C. /afar 212 508 3955 romtkeastera eon 1114 Avenue of the Americas New Yorks NY 10038 212 506 3900 main wevateroloo USDC SDNY DOCUMENT ELECTRONICALLY FILED DOCH DATE FILED. 10.4-ri October 4, 2017 VIA ECF

erning the Ili on and documents Plaintiff produced as a non-party witness in an action captioned v. Mayen, 15 Civ. 7433 (RWS), pending before Judge Robert Sweet ("July 17 Order" and "Jane Doe Evidence", respectively). Pursuant to the July 17 Order, we have sought consent from Plaintiff's counsel to use the

ve fraud conducted through TFC and associated entities and perpetrated by him and his, until now, unnamed co-conspirators (the "TFC Ponzi Scheme"). See United States of America v. Steven Hoffenberg, 94 Cr. 213 (RWS), 95 Cr. 321 (RWS), 1997 U.S. Dist. LEXIS 2394 (S.D.N.Y. Mar. 4, 1997). Hoffenberg was convicted of conspiracy

s 2 In United States of America v. Steven Hoffenberg, 94 Cr. 213 (RWS), 95 Cr. 321 (RWS), 1997 U.S. Dist. LEXIS 2394 (S.D.N.Y. Mar. 4, 1997), Judge Robert Sweet issued a Sentencing Opinion ("Sentencing Opinion") which lays bare the fraudulent conduct that resulted in Hoffenberg's conviction and which was im

Michael C. Miller 212 506 3955 [email protected] 1114 Avenue of the Americas New York. NY 10036 212 506 3900 main www.steptoe.com October_, 2017 VIA ECF Hon. John G. Koeltl United States District Court United States Co

ning the /l ion and documents Plaintiff produced as a non-party witness in an action captioned v. Maxwell, 15 Civ. 7433 (RWS), pending before Judge Robert Sweet ("July 17 Order" and "Jane Doe Evidence", respectively). Pursuant to the July 17 Order, we have sought consent from Plaintiff's counsel to use the

rg's conviction and the several related civil lawsuits, Defendants' involvement was purposefully concealed and not revealed until Hoffenberg's 2 In United Stales of America v. Sleven Hoffenberg, 94 Cr. 213 (RWS), 95 Cr. 321 (RWS), 1997 U.S. Dist. LEXIS 2394 (S.D.N.Y. Mar. 4, 1997), Judge Robert Sweet issued a Sentencing

s 2 In United Stales of America v. Sleven Hoffenberg, 94 Cr. 213 (RWS), 95 Cr. 321 (RWS), 1997 U.S. Dist. LEXIS 2394 (S.D.N.Y. Mar. 4, 1997), Judge Robert Sweet issued a Sentencing Opinion ("Sentencing Opinion") which lays bare the fraudulent conduct that resulted in Hoffenberg's conviction and which was im

Michael C. Miller 212 506 3955 1114 Avenue of the Americas New York. NY 10036 212 506 3900 main October 5, 2017 VIA ECF Hon. John G. Koeltl United States District Court United States Courthouse 500 Pe

tion that Plaintiff be allowed to depose Mr. Epstein on the ground that Defendants have been engaging in discovery from another matter before Judge Robert Sweet is baseless. Defendants have not engaged in any discovery; rather, it is the Plaintiff who is seeking to engage in a one-sided and premature fishin