Michael C. Miller 212 506 3955 1114 Avenue of the Americas New York. NY 10036 212 506 3900 main August 8, 2017 Sigrid McCawley, Esq. Boles Schiller & Flexner LLP 401 East Las Olas Blvd. Suite 1200 Fort Lauderdale, FL 33301 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Ms. McCawley: We write in response to your August 7, 2017 letter ("August 7 Letter"), regarding a) the briefing schedules for the defendants' motions i) seeking relief from a protective order issued in the v. Maxwell matter ("Protective Order" and "M Matte?) and ii) to 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 matter, we are surprised to receive this letter from you. As you know, on July 17, 2017, Judge John Koeltl issued an Order Under Seal ("July 17 Order"), in which he granted the defendants permission to seek relief from the Protective Order "to submit 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 Order so that they can use the testimony and documents that Jane Doe produced as a third party witness in the Matter ("Jane Doe Evidence"). Judge Koeltl directed the parties to "attempt to obtain agreement from the iarties" in the Matter before applying for relief from the judge presiding over the Matter. On July 24, 2017, and pursuant to the Court's admonition in the July 17 Order, we spoke with Brad 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 to the judge presiding over the Matter for relief from the Protective Order as it applies to the Jane Doe Evidence. Mr. Edwards advised that he was generally supportive of the notion that we shoul