Case 1:15-cv-07433-LAP BO I ES . SCH Document 113 I LLER & Filed 04/21/16 Page 1 of 3 FLEXNER LLP 101 EAST LAS OLAS BLVD.' SUITE 1200' FT. LAUDERDALE, FL 33301' PH. 950-356-0011' FAX 950-356-0022 Sigrid S. McCawley, Esq. Email: smccawley®bsfilp.com April 21, 2016 Honorable Judge Robert W. Sweet District Court Judge United States District Court 500 Pearl Street New York, NY 10007 Re: v. Maxwell, Case no. 15-cv-07433-RWS — Regarding Pro Hac Vice Motion of J. Dear Judge Sweet: This letter is in res nse to the Court's direction that additional material be submitted J. regarding Esq. motion to appear pro hac vice in this matter. This letter provides: (I) the stipulation for dismissal of the MI referenced in the Defendant's objection to the pro hac vice motion; (2) an affidavit from J. that he is not aware of any other anticipated litigation in which he would be a party, other than a malicious prosecution counterclaim that he has pending against Jeffrey Epstein; and (3) an affidavit from J. stating that he is aware of the protective order in this matter and will abide by its restrictions. In light of these submissions, laintiff requests that her choice of counsel be honored and that J. motion for pro hac vice be granted. As mentioned at today's hearing, because the deposition of Defendant is scheduled to start tomorrow, A ril 21 at 9:00 a.m., and because it is anticipated that confidential matters will be discussed. requests expedited consideration of these materials. As the Court recalls, in her o sition to J. Edward's pro hac vice motion, Defendant briefly mentioned that is a party to litigation st led as and Cassell v. Dershowitz, No. 15-000072 (17 Cir. Court Fla.) In response, explained that the litigation had settled and the dismissals would be entered shortly. DE 89 at 3. All parties to the action have now filed their dismissals. See Declaration at Exhibit 1. Under Florida law, such dismissals end the case. See Fla. R. Civ. P. 1.420 ("any part of an