Michael C. Miller 212 506 3955 1114 Avenue of the Americas New York. NY 10036 212 506 3900 main October 5, 2017 VIA ECF Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Judge Koeltl: We represent Defendants Jeffrey Epstein and Lesley Groff ("Defendants") and write to respond to Bradley J. Edwards' letter of October 5, 2017. Mr. Edwards' contention that Plaintiff be allowed to depose Mr. Epstein on the ground that Defendants have been engaging in discovery from another matter before Judge Robert Sweet is baseless. Defendants have not engaged in any discovery; rather, it is the Plaintiff who is seeking to engage in a one-sided and premature fishing expedition. As we previously advised the Court, the Plaintiff gave deposition testimony and documents in a matter captioned v. Maxwell, No. 15 Civ. 7433 (RWS) (the egio action") shortly after she filed this action (the "Plaintiff's Evidence"). The Plaintiff's Evidence was designated as Confidential pursuant to the Protective Order in the action. Mr. Epstein, through his counsel, as a non-party witness in the action, was provided with a copy of the Plaintiff's Evidence. The Plaintiff's Evidence is dispositive of the Motion to Dismiss that Defendants plan to file, and particularly on the issue of whether the Court lacks personal jurisdiction over Defendants. On July 14, 2017, we wrote to Your Honor seeki permission file a motion requesting relief from the Protective Order issued in the ME action, so that Your Honor may consider the Plaintiff's Evidence in determining the Motion to Dismiss; and (b) a stay of the schedule for the Motion to Dismiss. On July 17, 2017, Mr. Edwards submitted a letter to the Court opposing Defendants' request. In particular, Mr. Edwards contended that Defendants may obtain the information contained in the Plaintiff's Evidenc