Cgagellitreir-ta14-3W ClaglikigHtnt3nilalcdt 0 2/Nignatr-41 of 4 SHER TREMONTE LLP VIA ECF The Honorable John G. Kochi United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Jane Doe 43 v. Epstein et aL, No. 17 Qv. 616 (.1OK) Dear Judge Kochi: October 30, 2017 A codPEA-e—ce wiLL 56 iawi rveson, ezovE--40%. 4e s:oo/—. 50 We represent non-party Iladdon, Morgan and Foreman, P.C. ("Haddon Morgan which represented Defendant Ghislane Maxwell ("Maxwell") in Giuffre v Maxwell, Case No. 15-cv-7433 (RWS) (S.D.N.Y.) (the "Giuffre Action'). We write to respectfully request an opportunity to oppose Plaintiffs motion for alternative service on Maxwell through Haddon Morgan, or to seek reconsideration of the Court's order granting that motion, to which Haddon Morgan was not provided notice or any opportunity to respond. Procedural Background As the Court knows, counsel for Plaintiff in this action were also counsel for another plaintiff in the Giuffre Action, filed in 2015. Iladdon Morgan represented Maxwell as a defendant in that case. Maxwell and the plaintiff in that case reached a settlement, and the claims against her were dismissed with prejudice on May 25, 2017, see So Ordered Joint Stipulation for Dismissal, Giuffre v Maxwell. Case No. 15 Civ. 7433 (RWS) (S.D.N.Y. May 25, 2017), ECF No. 919. This action before Your honor has been pending since January 26. 2017. See Complaint, Dkt. No. I. On May 11, 2017, Plaintiff filed a motion seeking an additional 90 days to serve Maxwell (Dkt. No. 34). which the Court granted on May 12, 2017 (Dkt. No. 36). On August 10, 2017, Plaintiff's lust day to serve Maxwell, Plaintiff filed a motion for alternative service pursuant to Federal Rule of Civil Procedure 4(e)(1) and New York Civil Practice Law and Rules ("CPLR") § 308(5) (Dkt. No. 55) (the "Alternative Service Motion"). The Court issued an order granting the Alternative Service Motion on September 29, 20