Case 1:17-cv-00616-JGK-SN Document 179 Filed 12/13/18 Page 1 of 14 PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake Cit UT 84112 Tele hone: December 13, 2018 VIA CM/ECF Honorable Magistrate Judge Sarah Netburn United States District Court Thurgood Marshall Courthouse 40 Foley Square, Rm 430 New York, NY 10007 Re: Jane Doe 43 v. Jeffrey Epstein, et at, Case No.: 17-cv-00616 (JGK) — Letter Motion Seeking Pre-Motion Conference Dear Judge Netburn, We write today to request a pre-motion conference, pursuant to Local Civil Rule 37.2, to seek the Court's guidance as to compelling defendant Maxwell to produce requested documents. As the Court will recall, this is a case in which the plaintiff,M has alleged that she was sexually trafficked by Jeffrey Epstein and his co-defendants, including defendant Ghislaine Maxwell. Maxwell is the only one of the four defendants who did not invoke her Fifth Amendment right against self-incrimination to refuse to produce documents. But in response to requests for production, Ms. Maxwell produced very little information. Following that limited production, counsel for clarified her requests for production, via email. See Attachment A. Counsel for Ms. Maxwell then conferred via telephone on November 21, 2018, but were unsuccessful in narrowing many of the substantive disputes. and While there are various individual issues about the requests for production, there are several overarching disputes that we think might usefully be discussed in a pre- motion conference. • This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah. EFTA00805057