Case 1:22-cv-10904-JSR Document 353 Filed 03/12/24 Page 1 of 5 BOIES SCHILLER FLEXNER BS. F March 12, 2024 VIA ECF The Honorable Jed S. Rakoff United States District Court Southern District of New York Daniel Moynihan United States Courthouse 500 Pearl Street, Room 1340 New York, New York 10007 Re: Jane Doe I v. JPMorgan Chase Bank, N.A., Case No.: 22-CV-10019 (JSR); Gov't of the U.S. Virgin Islands v. JPMorgan Chase Bank, No. 22-cv-10904 (JSR) Dear Judge Rakoff: We represent Jane Doe 1 and write in response to the letter motion of The New York Times Company (the "Times") to unseal excerpts of Jane Doe l's deposition testimony that were attached to motions in this case and a related case brought by the U.S. Virgin Islands. Doe, ECF No. 291; USVI, ECF No. 352. The Times has made clear that it does not seek to unseal the name of Jane Doe 1 or any other victim, but otherwise proposes that the excerpts—which include substantial details about Jane Doe l's family and a horrific rape she endured—be fully unsealed for public consumption. Jane Doe l's Anonymity and the Excerpts at Issue Since she first filed this action on November 24, 2022, Jane Doe 1 has proceeded as the lead plaintiff in this action in reliance on the Court's order granting her leave to proceed anonymously. Doe, ECF No. 22. And throughout the course of this litigation, the Court and the parties have gone to great lengths to enforce the protections the Court granted Jane Doe 1. The Times—which has extensively reported on this case-essentially seeks to revoke the protections the Court granted Jane Doe 1 so that it can publish more stories about Epstein and expose "famous people linked with Mr. Epstein," all at Jane Doe 1's expense.' Specifically, the Times requests to unseal to following excerpts of Jane Doe l's deposition (the "Excerpts"). I. Excerpts from Jane Doe 1's March 3, 2023, deposition in which she discusses the other victims with whom she has discussed this lawsuit; her introduction to Jeffre