Michael C. MI 212 506 3955 mmiller©steptoe.com

1114 Avenue of the Americas New York, NY 10036 212 506 3900 main www.sleptoe.com

January 17, 2018

## 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 KocIt\]:

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We represent Defendants Jeffrey Epstein and Lesley Groff in the above-referenced matter. We write jointly on behalf of Plaintiff Jane Doe 43 and Defendants Epstein, Groff and (collectively, the "Parties") and submit the enclosed Confidentiality Stipulation and [Proposed] Order ("Proposed Order") pursuant to the Court's directive set forth at the conference of November 28, 2017.

The Parties have reached agreement on the Proposed Order after engaging in several rounds of negotiation and exchanging several rounds of drafts. The Parties hereby respectfully request the Court to enter the Proposed Order.

In accordance with the Court's prior orders, Defendants will e their supplemental motion to dismiss seven (7) days after the Proposed Order is en d y the Cou

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Michael C. Counsel for Defendants Jeffrey Epstein and Lesley Groff