Case 1:17-cv-00616-JGK-SN Document 61 Filed 10/04/17 Michael C 1212 506 3955 [email protected] Page 1 of 2 S t_ePtOe syr ror 1114 Avenue of the Americas New York, NY 10036 212 506 3900 main www.steptoe.com October 4, 2017 VIA ECF Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Judge Koeltl: We are counsel for Defendants Jeffrey E stein and Lesley Groff in the above-referenced matter. We write jointly with Defendant (together, the "Defendants") to request an adjournment of the conference scheduled for Octo 10, 2017. This is our first request for adjournment of this conference. As Your Honor may recall, the Court issued an Order on July 17, 2017 concerning the de ion and documents Plaintiff produced as a non-party witness in an action captioned v. Maxwell, 15 Civ. 7433 (RWS), pending before Judge Robert Sweet ("July 17 Order" and "Jane Doe Evidence", respectively). Pursuant to the July 17 Order, we have sought consent from Plaintiff's counsel to use the Jane Doe Evidence, but with only limited success. Specifically, on July 24, I spoke with Plaintiff's counsel Brad concerning the to Judge Jane Doe Evidence. I informed Mr. that we would like to make an Sweet for relief from the Protective Order as it applies to the Jane Doe Evidence. On August 8, I infonned me that he wrote to Mr. reiterating our request. On August 10, Mr. matter, but that he would consent to the use of Plaintiff's deposition she gave in the would need an itemized list of the documents we want to use, even thou e documents totaled only 557 pages. On August 17, I wrote to Mr. reiterating our belief that all of the Jane Doe Evidence is relevant to the Motions to Dismiss, ut that I would nonetheless provide him and reiterated that we with a list of the documents. On September 1, I wrote to Mr. want to use all of the Jane Doe Evidence and provided him with c