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EFTA00605165

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CIIISeeliTh(01$00016-1tai< ClatatilifffIglfi ilerrliSdar464511geffigP21 of 2 Michael C. /afar 212 508 3955 romtkeastera eon 1114 Avenue of the Americas New Yorks NY 10038 212 506 3900 main wevateroloo USDC SDNY DOCUMENT ELECTRONICALLY FILED DOCH DATE FILED. 10.4-ri October 4, 2017 VIA ECF Hon. John O. 'Coal 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: Steptoe ......... ji b. We are counsel for Defendants Jeffit E stein and In the above-referenced matter. We write jointly with Defendant (toge”ifendants") to request an adjournment of the conference schedul or cto er 10, 2017. This is our first request for adjournment of this conference. As Your Honor may recall, the Court issued an Order on July 17, 2017 concerning the Ili on and documents Plaintiff produced as a non-party witness in an action captioned v. Mayen, 15 Civ. 7433 (RWS), pending before Judge Robert Sweet ("July 17 Order" and "Jane Doe Evidence", respectively). Pursuant to the July 17 Order, we have sought consent from Plaintiff's counsel to use the Jane Doe Evidence, but with only limited success. Specifically, on July 24, I spoke with Plaintiff's counsel Brad Edwards concerning the Jane Doe Evidence. I informed Mr. Edwards that we would like to make an application to Judge Sweet for relief from the Protective Order as it applies to the Jane Doe Evidence. On August 8, I wrote to Mr. Edwards reiterating our request. On August 10, Mr. Edwards informed me that he .l e would consent to the use of Plaintiff's deposition she gave in the matter, but that he would need an itemized list of the documents we want to use, even thou documents totaled only 557 pages. On August 17, I wrote to Mr. Edwards reiterating our belief that all of the Jane Doe Evidence is relevant to the Motions to Dismiss, but that I would nonetheless provide hi

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