Michael C. Miller 1114 Avenue of the Americas www.steptoe.com SUBMITTED UNDER SEAL July 14, 2017 Hon. John G. Koeltl United States District Court, Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, New York 10007-1312 RE: Jane Doe 43 v. Epstein, et al.,No.17 Civ. 616 (JGK) Dear Judge Koeltl: Steptoe STEPTOS E JOHNSON LIP We represent defendants Jeffrey Epstein and ("Defendants") in the above- referenced lawsuit ("Action"). The Defendants intend to move to dismiss the Action based on, inter alia, the failure of Jane Doe 43 ("Plaintiff") to establish personal jurisdiction over the Defendants ("Motion to Dismiss"). The Plaintiff provided deposition testimony and produced documents in another proceeding ("Plaintiff's Evidence") which would be dispositive of the personal jurisdiction issue in the Motion to Dismiss. The Plaintiff's Evidence is subject to a protective order in the other proceeding. Defendants write this letter, first, to seek the Court's permission to file a motion requesting relief from the protective order ("Motion for Relief") or other similar relief, and, second, to request a stay of the briefing schedule on the Motion to Dismiss if the Court agrees to consider the Motion for Relief. By way of additional background information, shortly after Plaintiff initiated the Action, she was deposed in another matter pending in this District, Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS) (the "Giuffre action"). During that deposition, Plaintiff gave sworn testimony which relates in large measure to the claims in the present action, and produced documents, i.e., the Plaintiff's Evidence. Mr. Epstein, through his counsel, as a non-party witness in the Giuffre action, was provided with a copy of the Plaintiff's Evidence. These materials were marked "Confidential" pursuant to the Protective Order in that case.' Under the terms of the Protective Order, "Confidential" documents "shall n