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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE 43 Plaintiff, v. JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and Defendants. No. 17 Civ. 00616 (JGK) MEMORANDUM IN OPPOSITION TO LETTER MOTION TO OPPOSE ALTERNATIVE SERVICE ON MAXWELL Plaintiff, Jane Doe 4
v. JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and Defendants. No. 17 Civ. 00616 (JGK) MEMORA
unsuccessfully — to arrange service through the Haddon Morgan firm. For example, on May 9, 2017, co-counsel for Jane Doe 43 (Ms. Sigrid McCawley at Boies Schiller) sent an email to Mr. Pagliuca as follows (id. at 3-4): From: Sigrid McCawley Sent: Tuesday, May 09, 017 4:33 PM To: Jeff Pagliuca Subject: Servi
will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. I at 20-21. Aside from the reference to "United States" which, as noted above, is insufficient, the defen
ot limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. I at 2
The defendant's motion is, at its core, premised on a false factual narrative. The defendant alleges, based on a New York Daily News article, that Boies Schiller and the Government colluded starting in at least early 2016 with the "precise[] design[]" of having the defendant "charged with perjury." (Def. Mot
will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted above, is insufficient, the defen
ot limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 2
The defendant's motion is, at its core, premised on a false factual narrative. The defendant alleges, based on a New York Daily News article, that Boies Schiller and the Government colluded 60 EFTA00095152 starting in at least early 2016 with the "precise[] design[]" of having the defendant "charged with
t will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff or Nadia Marcinkova... From the time the FBI began 11 HOUSE_OVERSIGHT_017945 Case 1:19-cv-03377 Document1 Filed 04/16/19 Page 12 of 28 investigat
tein brought her from Yugoslavia to live with him. Several victims told police that she was involved in orgies with Epstein and underage girls. Ross, Groff and Kellen, now known by her married name, Vickers, were schedulers who arranged his underage sex sessions, according to the FBI and police. Marcink
ons but he also said that the client strongly believed what she was saying. At Mr. Dershowitz’s request I attended a meeting on July 6, 2015, at the Boies Schiller Flexner offices in New York City with David Boies and Sigrid McCawley with Mr. Dershowitz participating by Skype. The purpose of the meeting as state
Entities connected to both Lesley Groff and Boies Schiller

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Marc Rich
PERSON
Richard Kahn
PERSON
John F. Kennedy
PERSON
Woody Allen
PERSON
Prince Andrew
PERSON
George Mitchell
PERSON
Alan Dershowitz
PERSON
Teterboro
LOCATION
Newark
LOCATION
Lawrence Krauss
PERSON
George W. Bush
PERSON
Reid Weingarten
PERSON
Sarah Kellen
PERSON
Glenn Dubin
PERSON
Mort Zuckerman
PERSON
Ghislaine Maxwell
PERSONJack Goldberger
PERSON
United States
LOCATION