Michael C. Miller 212 506 3955 [email protected] 1114 Avenue of the Americas New York, NY 10036 212 506 3900 main www.steptoe.com SUBMITTED UNDER SEAL Hon. John G. Kochi United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 Steptoe STIPTOC Si JOHNSON PAP November 22, 2017 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") in the above- referenced matter (the "Jane Doe Matter"). The Defendants filed yesterday a motion to dismiss the First Amended Complaint filed by Plaintiff Jane Doe ("Jane Doe" and "MTD"). For the reasons set forth, below, the Defendants respectfully request that they be provided with an opportunity to submit a supplemental MID after the Court issues a confidentiality order in this matter. As we previously advised the Court, Jane Doe voluntarily gave deposition testimony and documents relatin to the alle ations in the Jane Doe Matter in a matter captioned (the '1= Matter") (the "Jane Doe Evidence"). The Jane Doe Evidence, given by Jane Doe shortly after she filed the Jane Doe Matter, was designated as Confidential pursuant to the Protective Order in the Matter ("Protective Ora . Specifically, Jane Doe and the parties to the in the Matter, the plaintiff, and the defendant, Ghislaine Maxwell, all designated Jane Doe's deposition transcript as Confidential, and Jane Doe designated her document production as Confidential. Jane Doe and the plaintiff in the Matter both subsequently withdrew their confidential designation of Jane Doe's deposition transcript "in its entirety," and objected to the confidential designation of that transcript by the defendant in that action. I Jane Doe's more recent conduct is entirely consistent with her decision to withdraw this confidential designation and calls into question whether she should be permitted to continue to proceed i