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tein's victims. As a consequence, the victims were not told about the NPA. 46. On July 7, 2008, a young woman identified as Jane Doe No. 1, one of Jeffrey Epstein's victims (other than Plaintiff), filed a petition to enforce her rights under the Crime Victims' Rights Act ("CVRA"), 18 U.S.C. § 3771, alleging that
ng 2000-2002, beginning when Plaintiff was 16, Plaintiff was the victim of sex trafficking and abuse by convicted sex offender Jeffrey Epstein. 3. Epstein's trafficking scheme involved recruiting young girls, often by claiming they would be paid $200 for simply providing a massage to a wealthy billiona
r. Epstein" for many years. In 2003, Defendant said "I'm on my 20th book... The only person outside of my immediate family that I send drafts to is Jeffrey." Vicky Ward, The Talented Mr. Epstein, VANITY FAIR (Jun. 27, 2003), https://bit.ly/2S9MzQU. Defendant also described Epstein as his friend. "I woul
ntiff 34. Defendant has been "a close friend of Mr. Epstein" for many years. In 2003, Defendant said "I'm on
y that I send drafts to is Jeffrey." Vicky Ward, The Talented Mr. Epstein, VANITY FAIR (Jun. 27, 2003), https://bit.ly/2S9
as." Ray Gustini, Vanity Fair Reminds Us When Jef•ey Epstein Wasn't a Creep, THE ATLANTIC (June 21, 2011), ht
demands a trial by jury on all causes of action asserted within this pleading. Dated: December 20, 2019 /s/ Charles J. Cooper Charles J. Cooper* Michael W. Kirk* Nicole J. Moss* Haley N. Proctor* COOPER & KIRK PLLC 39 EFTA00092686 Case 1:19-cv-03377-LAP Document 101-1 Filed 12/20/19 Page 41 of 41 1523
z pending before Hon. Loretta Preska in the Southern District of New York. lack of credibility, and actual conduct in recruiting young girls for Jeffrey Epstein, are critical issues in the above-mentioned litigation. We write to notify you that gave approximately nine hours of deposition testimony across t
al conduct in recruiting young girls for Jeffrey Epstein, are critical issues in the above-mentioned litig
and actual conduct in recruiting young girls for Jeffrey Epstein, are critical issues in the above-mention
for Alan Dershowitz Howard M. Cooper Christian G. Kiely Kristine C. Oren Cooper & Kirk, PLLC Attorneys for Virginia Giuffre Charles J. Cooper Michael W. Kirk Nicole J. Moss Haley N. Proctor AIDAI.A. BERTUNA a KAMINS. P.C. • 546 FIFTH AVENUE. NEW YORK, NY. 10036 • T: 212-4660011 • F: 917-26I-4.932 • VAVW
Haley Proctor Michael we would like very much to come to NYC to meet with you confidentially and open a dialogue about our mutual interests in the Epstein matter. May we get back with some dates that would work at our end? Best, Chuck Charles J. Cooper Cooper & Kirk, PLLC On Feb 13, 2020, at 1:28 P
Is roar: To: Chuck Cooper Cc: Si a 'd McCawle Haley Procto Subject: RE: Introduction Date: Thu, 13 Feb 2020 19:39:14 +0000 "Nicole Moss" "Michael W. Kirk" Chuck, I think it makes sense since we've already been in touch extensively with Sigrid regardin that we'll continue to be in touch with her on
Entities connected to both Jeffrey Epstein and Michael W. Kirk

Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Prince Charles
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
Bradley Cooper
PERSON
David Boies
PERSONLoretta A. Preska
PERSONCharles J. Cooper
PERSONNicole J. Moss
PERSON