Epstein Secrets

Michael C. Miller 1114 Avenue of the Americas New York. NY 10036 main www.steploe.com May 2017 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrew

cuments or had any power to affect her ability to travel to the United States. To the contrary, the Complaint alleges that she travelled to and from the United States as she wished. Indeed, she admits that "she refused to perform the recruitment assignment" allegedly "demanded" by Epstein to find young females to

until January 27, 2017, more than four years after any of the events alleged in the Complaint occurred. Plaintiff's claim is therefore time-barred. Abarca v. Little, 54 F.Supp.3d 1064, 1068 (Minn. 2014). As the Court stated in Abarca, a claim under Section 1595 had a four-year of statute of limitation

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

Court Should Modify the Protective Order I I CONCLUSION 15 CONFIDENTIAL - FILED UNDER SEAL EFTA00805390 TABLE OF AUTHORITIES Page(s) Cases Abarca v. Little, 54 F. Supp. 3d 1064 (D. Minn. 2014) 4 Charter Oak Fire Ins. Co. v. Electrolux Home Prods., Inc., 287 F.R.D. 130 (E.D.N.Y. 2012) 11, 1

Doe v. Shakur, 164 F.R.D. 359 (S.D.N.Y. 1996). 3 EFTA00307100 her prior employment, social or travel experiences, nor her purposes for coming to the United States, nor her immigration status while she was in the United States. One can only assume that she has chosen to omit these important facts, which are dir

menced until January 27, 2017, more than four years after any of the events alleged in the FAC occurred. Plaintiff's claim is therefore time-barred. Abarca v. Little, 54 F.Supp.3d 1064, 1068 (Minn. 2014). As the Court stated in Abarca, a claim under Section 1595 had a four-year of statute of limitation

assignment" allegedly "demanded" by Epstein to find young females to serve in "sexual servitude." Cplt. 1 51. Yet, she was able to come back to the United Stat ere is no showing of any threatened "serious harm" had she chosen to remain in There is simply no "threat of serious harm" alleged. In any event, this

d until January 27, 2017, more than four years after any of the events alleged in the Complaint occurred. Plaintiffs claim is therefore time-barred. Abarca v. Little, 54 F.Supp.3d 1064, 1068 (Minn. 2014). As the Court stated in Abarca, a claim under Section 1595 had a four-year of statute of limitation

to dismiss. Jeffery Espstein is a wealthy individual who, along with and , has previously been investigated by Florida state law enforcement and the United States Attorney's office for the Southern District of Florida for various offenses relating to sex trafficking, including 18 SOUTHERN DISTRICT REPORTERS,

that analysis has been applied to conclude that the ten year statute of limitations applies. We cited a case out of the District of Minnesota, the Abarca case, that takes a different view, and the thinking in the Abarca case -- which we think is the correct thinking -- THE COURT: So far the thinking