Epstein Secrets

ith their legibility) the following or other appropriate notice: "CONFIDENTIAL." Discovery material designated CONFIDENTIAL shall be identified by Bates number. To the extent practical, the respective legend shall be placed near the Bates number. 8. Designation of a document as CONFIDENTIAL INFORMA

nihan United States Courthouse 500 Pearl Street New York, New York 10007-1312 RE: Jane Doe 43 v. Epstein, et al.,No.17 Civ. 616 (JGK) Dear Judge Koeltl: Steptoe STEPTOS E JOHNSON LIP We represent defendants Jeffrey Epstein and ("Defendants") in the above- referenced lawsuit ("Action"). The Defend

Michael C. Miller 1114 Avenue of the Americas www.steptoe.com SUBMITTED UNDER SEAL July 14, 2017 Hon. John G. Koeltl United States District Court, Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, New York

odified to permit the Intervenors to use her deposition and a portion of her document production in the Matter, specifically the documents bearing Bates-stamp numbers 15, 157-168, 175- 203 ("Agreed Evidence"). All of the Agreed Evidence is relevant to the Motion to Dismiss. For example, Jane Doe pr

T Intervenors are two of the defendants in an action captioned Jane Doe 43 v. Epstein, et al, No. 17 Civ. 616 (JGK), currently pending before Judge John G. Koeltl (the "Jane Doe Matter"). Jane Doe 43 ("Plaintiff" or "Jane Doe") filed the original complaint in the Jane Doe Matter on January 26, 2017, and subse

ion 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 to "make their application for relief from the Protective Order to the Judge in the CONFIDENTIAL - FILED UNDER SEAL EFT

ith their legibility) the following or other appropriate notice: "CONFIDENTIAL." Discovery material designated CONFIDENTIAL shall be identified by Bates number. To the extent practical, the respective legend shall be placed near the Bates number. 8. Designation of a document as CONFIDENTIAL INFORMA

ihan United States Courthouse 500 Pearl Street New York, New York 10007-1312 RE: Jane Doe 43 v. Epstein, el at, No. 17 Civ. 616 (JGK) Dear Judge Koeltl: Steptoe STEPTOE E JOHNSON LIP I am writing to advise that we inadvertently sent you via facsimile a draft version of a letter we prepared for yo

ve attached copies of the documents listed below if they were not provided to the defense by the government in discovery. Otherwise, we provide the Bates numbers for the produced documents. Because we have already provided the government with the defense expert notice, which referenced articles, repor

ims' Compensation Program Attached as Exhibit E 8. General Release, Epstein Victims' Compensation Program — Not attached — pending release by Judge Koeltl in Doe v. Indyke, 20 Civ. 484 (JGK) (S.D.N.Y. 2020) 9. Floorplans, Palm Beach residence SDNY GM 00328519-00328521 10. Palm Beach Police Departmen

ve attached copies of the documents listed below if they were not provided to the defense by the government in discovery. Otherwise, we provide the Bates numbers for the produced documents. Because we have already provided the government with the defense expert notice, which referenced articles, repor

tims' Compensation Program Attached as Exhibit E 8. General Release, Epstein Victims' Compensation Program Not attached — pending release by Judge Koeltl in Doe v. Indyke, 20 Civ. 484 (JGK) (S.D.N.Y. 2020) 9. Floorplans, Palm Beach residence SDNY GM 00328519-00328521 10. Palm Beach Police Departmen