UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 17 Civ 616 (JGK) JANE DOE 43, Plaintiff, vs. JEFFREY 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 before the Honorable John G. Koeltl at the United States Courthouse, 500 Pearl Street, New York, New York, for an Order pursuant to Fed.R.Civ.P. 11(c), sanctioning Plaintiff and Plaintiff's counsel, together with such other relief as this Court deems just and proper. The grounds for sanction are as follows. First, on January 26, 2017, the Plaintiff filed a Complaint in the above-captioned matter. Second, on May 15, 2017, the Defendants served a letter on Plaintiff detailing the many deficiencies in the Complaint, including, but not limited to, the failure of the Complaint to a) allege a legally sufficient claim as to either Defendant, b) identify the statutes allegedly violated by the Defendants, c) establish that the claims in the Complaint are not barred by applicable statute of limitations, d) establish personal jurisdiction over the Defendants, and e) establish that venue is properly laid in this District ("Deficiency Letter"). EFTA00308099