Epstein Secrets

NDUM OF LAW IN SUPPORT OF INTERVENORS' MOTIONS FOR LEAVE TO INTERVENE AND TO MODIFY THE PROTECTIVE ORDER STEPTOE & JOHNSON LLP 1114 Avenue of the Americas New York, New York 10036 (212) 506-3900 October 5, 2017 CONFIDENTIAL - FILED UNDER SEAL EFTA00805389 TABLE OF CONTENTS PRELIMINARY STATEMENT

vance of the Jane Doe Evidence to the Jane Doe Matter, Jane Doe should not be permitted to limit Intervenors' legal arguments by dictating which of the Jane Doe Evidence Intervenors should be allowed to include in their pleadings in that matter. Finally, Mr. Epstein already possesses the Jane Doe Evidence,

ter ("Motion to Dismiss"). The Jane Doe Evidence is highly probative of the issues the Intervenors intend to raise in the Motion to Dismiss. To use the Jane Doe Evidence to support the Motion to Dismiss, however, the Intervenors need relief from the Protective Order. Judge Koeltl instructed the Intervenors

ing crime victims informed. Just as the Government cannot illegally agree to run a sentence on a new crime concurrently with a probation revocation, United States v. Walker, 98 F.3d 944 (7th Cir. 1996), so too here it cannot illegally agree not to prosecute a sex offender without first conferring with his vict

Yet Would Otherwise Evade Review. For all the reasons just explained, the Court clearly is in a position to address the CVRA violations alleged by the Jane Doe #1 and Jane Doe #2. Even assuming for sake of argument it was not, however, the Court would still clearly possess the ability to review the Governme

ing crime victims informed. Just as the Government cannot illegally agree to run a sentence on a new crime concurrently with a probation revocation, United States I Walker, 98 F.3d 944 (7th Cir. 1996), so too here it cannot illegally agree not to prosecute a sex offender without first conferring with his victi

Yet Would Otherwise Evade Review. For all the reasons just explained, the Court clearly is in a position to address the CVRA violations alleged by the Jane Doe #1 and Jane Doe #2. Even assuming for sake of argument it was not, however, the Court would still clearly possess the ability to review the Governme

Michael C. Miller 212 506 3955 1114 Avenue of the Americas New York. NY 10036 212 506 3900 main August 8, 2017 Sigrid McCawley, Esq. Boles Schiller & Flexner LLP 401 East Las Olas Blvd. Suite 1200 For

f the,/ Letter, please confirm whether Jane Doe consents to the defendants' application in the Matter for relief from the Protective Order to use the Jane Doe Evidence in support of their motion to dismiss the Amended Complaint in the Jane Doe Matter. In addition to sending the July 7 Letter in the midst