EFTA00582845Set 9
2017-08-082p832w
dismiss the
plaintiff's First Amended Complaint ("FAC") in the above-captioned matter ("Jane Doe
Matter"), and b) your request for an opportunity to depose Jeffrey Epstein.
As a preliminary ... documents
from [the Matter] in support of a motion to dismiss in [the Jane Doe Matter]."
Specifically, the defendants advised Judge Koeltl that they are seeking relief from the Protective ... Edwards, who is counsel for Jane Doe in both the Matter and the Jane Doe
Matter. We informed Mr. Edwards that the defendants would like to make an application
https://www.justice.gov/epstein/files/DataSet%209/EFTA00582845.pdf
EFTA00583038Set 9
2017-08-082p666w
motion to dismiss the plaintiff's Amended Complaint in the
above-captioned matter ("Jane Doe Matter"), and your request for an opportunity to depose
Jeffrey Epstein.
As a preliminary matter ... documents from [the Matter] in support of
a motion to dismiss in [the Jane Doe Matter]." Specifically, the defendants advised Judge Koeltl
that they are seeking relief from the Protective ... Edwards, who is counsel for Jane Doe in both the Matter and the Jane Doe
Matter. We informed Mr. Edwards that the defendants would like to make an application
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583038.pdf
EFTA00787645Set 9
2017-10-2611p2,606w
Jane Doe Evidence Is Relevant to the Motion to Dismiss the Jane Doe Matter 2
B. Intervenors Are Agreeable to a New Protective Order 3
C. Jane Doe's Efforts ... Jane Doe Evidence in support of their motion to dismiss the Jane Doe Matter ("Motion to
Modify") (together the "Motions"), and in response to the opposition submitted by Non-Party ... Modify, they concede that the Jane Doe Evidence is relevant to the
Jane Doe Matter, subject to discovery in the Jane Doe Matter, and relevant (at least in part
https://www.justice.gov/epstein/files/DataSet%209/EFTA00787645.pdf
EFTA00806813Set 9
2017-11-2221p3,387w
Defendants Jeffrey Epstein and Lesley Groff ("Defendants") in the above-
referenced matter (the "Jane Doe Matter"). The Defendants filed yesterday a motion to dismiss
the First Amended Complaint filed ... voluntarily gave deposition testimony and
documents relatin to the alle ations in the Jane Doe Matter in a matter captioned
(the '1= Matter") (the "Jane Doe Evidence").
The Jane Doe ... Evidence, given by Jane Doe shortly after she filed the Jane Doe Matter, was
designated as Confidential pursuant to the Protective Order in the Matter ("Protective
. Specifically, Jane Doe
https://www.justice.gov/epstein/files/DataSet%209/EFTA00806813.pdf
EFTA00805389Set 9
2017-10-0518p5,208w
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 ... First Amended Complaint ("FAC") on June 5, 2017.
Both the and the Jane Doe Matters are based primarily on the alleged
misconduct of Mr. Epstein. Indeed, shortly after Jane Doe ... filed her suit against the Intervenors
in the Jane Doe Matter, she gave deposition testimony and produced documents as a non-party
witness in the Matter concerning her alleged interactions
https://www.justice.gov/epstein/files/DataSet%209/EFTA00805389.pdf