Epstein Secrets

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

as aware, Doe v. Indyke was the "lone case in this District that has not yet been either resolved or stayed at this point. . . In 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover

by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00077689 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine M

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

as aware, Doe v. Indyke was the "lone case in this District that has not yet been either resolved or stayed at this point. . . In 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover

by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00039504 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine M

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

stayed at this point. . . In particular, this matter appears to be the only remaining active civil case in this District in which 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover

by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00095149 claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless con

stein and named the additional individuals Lesley Groff and Cimberly Espinosa as enablers.07°] Katlyn Do

e.DW In October 2019, Araoz amended her complaint to include over 20 corporate entities associated with Epstein and named the additional individuals Lesley Groff and Cimberly Espinosa as enablers.07°] Katlyn Doe, et at v. Epstein's estate (2019) EFTA00264313 • . moo. c_c_)wwt RA-VCRS - A 50SC 5/22/22

nd Circuit.M On March 11, 2019, in the appeal of the district judge's refusal to unseal the documents relating to the 2017 defamation settlement of Giuffre v. Maxwell, the Second Circuit Court gave parties one week to provide good cause as to why they should remain under seal, without which they would be unsealed

10007-1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Judge Koeltl: We represent Defendants Jeffrey Epstein and Lesley Groff ("Defendants") in the above- referenced matter. Defendants have been attempting to reach agreement with Plaintiff concerning the Confidentiality Sti

e represent Defendants Jeffrey Epstein and Lesley Groff ("Defendants") in the above- referenced matter. D

to use materials in addition to her deposition and the documents marked at the deposition (collectively, the "Transcript") in the matter captioned Giuffre v. Maxwell, Case No. 15-cv-07433(RWS) ("Giuffre Action"). We agreed to Plaintiff's request, and in return we proposed that should Plaintiff decide to use mater

EY EPSTEIN, GHISLAINE MAXWELL, AN Defendants. NOTICE OF MOTION FOR SANCTIONS PLEASE TAKE NOTICE, that Defendants Jeffrey Epstein ("Epstein") and Lesley Groff ("Groff") (together, "Defendants"), upon the pleadings and prior proceedings had herein, and on the grounds stated below, intend to move this Court

LAINE MAXWELL, AN Defendants. NOTICE OF MOTION FOR SANCTIONS PLEASE TAKE NOTICE, that Defendants Jeffrey Epstein ("Epstein") and Lesley Groff ("Groff") (together, "Defendants"), upon the pleadings and prior proceedings had herein, and on the grounds stated below, intend to move this Court before t

laid in the Southern District of New York. Finally, Plaintiff's deposition testimony, and the documents that she produced, in the action captioned Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS) (the "Giuffre action") further demonstrate that the FAC should be dismissed for the reasons set forth above and in the Defi