## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT NEW YORK

x

JANE DOE 43,

17-4:v-00616-R iK

Plaintiff,

vs.

JEFFREY EPSTEIN GHISLAINE MAXWELL, LESLEY GROFF, AND NATALYA

Defendant.

-x

## DECLARATION OF JOHN E. STEPHENSON. JR.

I, John E. Stephenson, Jr., declare as follows pursuant to 28 U.S.C. § 1746:

1. I am an attorney-at-law duly admitted to practice pro hac vice before the Southern District of New York in this matter. I am a partner with the law finn of Alston & Bird LLP, which has an office at 90 Park Avenue, New York, NY 10016. I represent in the above-captioned case.

1. I submit this Declaration based upon my personal knowledge, information, and belief, in support of Complaint. Supplemental Motion to Dismiss the Amended

1. Attached hereto as Exhibit A is a true and correct copy of the May 15, 2017 pre-motion letter that I sent to Plaintiff's counsel. That letter served to identify and discuss the deficiencies in the January 26, 2017 Complaint.

1. Attached hereto as Exhibit B is a true and correct copy of the April 10, 2009 New York Times article titled "Keeping Up With Being Kept" The article can be accessed online at http://www.nytimes.com/2009/04/12/magazine/12sugardaddies-t.html. The last time that I accessed the article online was earlier today.

I declare under penalty of perjury that the above facts are true and correct.

Executed this 26th day of January, 2018.

/s/ John E. Stephenson, Jr. John E. Stephenson, Jr.