Epstein Secrets

following: Sigrid S. McCawley Meredith Schultz David Boies Boies, Schiller & Flexner, LLP 401 East Las Ola

ing: Sigrid S. McCawley Meredith Schultz David Boies Boies, Schiller & Flexner, LLP 401 East Las Ola

H A D D O N MORGAN FOREMAN October 4, 2018 Via ECF Hon. John G. Koeltl United States District Judge United States District Court Daniel Patrick Moynihan Courthouse Southern District of New York 500 Pearl Street New

A. MennInger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831/364 DC 303.832.2628 VAVW .hmil ow c o m Imenningergithmflaw.com Dear Judge Koeltl: This is a letter motion requesting a pre-motion discovery conference regarding the need for a protective order pursuant to Fed. R. Civ. P. 26(c)(1

BSF BOIES SCHILLER FLEXNER Sigrid S. • Telephon Email

BSF BOIES SCHILLER FLEXNER Sigrid S. • Telephon Email: smccaw ey to s p.com November 29, 2017 VIA ECF Honorable John G. Koeltl Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 Re: Jane Doe 43. v. Epstein, et al. Case No.: 17-CIV-0061

nihan United States Courthouse 500 Pearl Street New York, NY 10007 Re: Jane Doe 43. v. Epstein, et al. Case No.: 17-CIV-00616 (JGK) Dear Judge Koeltl: We represent Plaintiff Jane Doe 43 in the above-referenced matter. The Defendants Jeffrey Epstein and Lesley Groff (hereinafter referred to simply

Maxwell with step-by-step instructions on how to provide sexual services for Epstein.[79)(8°) v Maxwell and Epstein's Estate (2019) represented by David Boies, sued Maxwell and Epstein's estate in Federal District Court in Manhattan in November 2019, accusing them of rape, battery and false imprisonment a

and Epstein's Estate (2019) represented by David Boies, sued Maxwell and Epstein's estate in Federal Dis

xwell has a history of b ii tachable during legal proceedings.[81][98][9O100] During the lawsuit filed in 2017 from against Maxwell, District Judge John G. Koeltl granted a motion for "alternative service" on the grounds that the plaintiffs efforts to reach Maxwell were persistently thwarted; these included h

er & Flexner LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL, USA 33301 954-356-0011 Fax: 954-356-0022 Email:[email protected] David Boies, II [ATTORNEY TO BE NOTICED] Boies, Schiller & Flexner LLP (Armonk) 333 Main Street Armonk, NY, USA 10504 (914)-749-8200 Fax: (914)-749-8300 Emai

S): Sigrid S. McCawley [ATTORNEY TO BE NOTICED] Boies, Schiller & Flexner LLP 401 East Las Olas Boulev

, Lesley Groff; Jeffrey Epstein; Ghislaine Maxwell DOCKET CASE NUMBER: 1:17cv616 FILING DATE: 1/26/2017 JURISDICTION: Federal Question JUDGE: John G. Koeltl NATURE OF SUIT: 890 Other Statutory Actions FILING TYPE: Civil CAUSE: Fed. Question28 USC 1331 JURY DEMAND: Plaintiff PLAINTIFF ATTORNEY(S): Si

BSF Si 'cl McCawle Tele hone: Email: BOIES SCHILLER FLEXNER August 7, 2017 VIA EMAIL Mi

ice wherein you state that Jane Doe 43 does not have 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, un

BSF Si rid McCawle Tele hone: Email: BOIES SCHILLER FLEXNER August 7, 2017 VIA EMAIL Mi

ice wherein you state that Jane Doe 43 does not have 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, un

-counsel for Jane Doe 43 (Ms. Sigrid McCawley at Boies Schiller) sent an email to Mr. Pagliuca as follow

to litigate on behalf of defendant Maxwell in this very Court and, thus, presumably has an effective way of communication with Maxwell. This Court (Koeltl, J.), has previously allowed service to be made through an attorney that was representing a client, explaining that the attorney "must know how to c