Epstein Secrets

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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

id McCawle Tele hone: Email: BOIES SCHILLER FLEXNER August 7, 2017 VIA EMAIL Michael Miller, Esq. Steptoe & Johnson, LLP 1114 Avenue of the Americas New York NY 10036 [email protected] Re: Jane Doe 43 v. Jeffrey Epstein, et al. Case No.: 17-cv-616 Dear Mr. Miller, We are in receipt of you

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

Michael C. Miller 1114 Avenue of the Americas www.steptoe.com SUBMITTED UNDER SEAL July 14, 2017 Hon. John G. Koeltl United States District Court, Southern District of New York Daniel Patri

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"

cl McCawle Tele hone: Email: BOIES SCHILLER FLEXNER August 7, 2017 VIA EMAIL Michael Miller, Esq. Steptoe & Johnson, LLP 1114 Avenue of the Americas New York NY 10036 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 where

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

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

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