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EFTA02819695

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Cases e4g1M.104131q150 Doil9R8Mt %ed feigit1914§AZ 1 chge 1 of 2 Michael C. MCier 252 5C6 3955 mmtlerasteNne corn Steptoe J0.0.1141 1A; 1114 Avenue of the Ainecicee New Yoe*. NY 10038 212 506 3800 mein wmv.eteploo corn USOC SONY DOCUMENT ELECT RONiCALLY FILED DOCs DATE FILED. /049 art October 4, 2017 VIA ECF Hon. John O. KoelU 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 Kueltl: We are counsel for Defendants Je ei 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 October 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 on and documents Plaintiff produced as a non-party witness in an action captioned v. Maxwell, IS 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 Plaintiffs counsel to use the Jane Doe Evidence, but with only limited success. de i Specifically, on July 24, I s ke vith Plaintiff's counsel Brad concerning the Jane Doe Evidence. 1 informed Mr. that we would like to make an application to Judge Sweet for relief ence. On August 3, 1 c Protective Order as it applies to the Jane informed me that he wrote to Mr. reiterating our request. On August 10, Mr. matter, but that he would consent to the use of Plaintiffs deposition she gave in the would need an itemized list of the documents we want to use, even though the documents totaled reiterating our belief that all of the Jane only 557 pages. On August 17, I wrote to Mr. onetheless provide him Doe Evidence is relevant to the Motions to Dismiss, but that I w mid reiterated that we with a list of the documents. On September 1, wrote to M

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