Epstein Secrets

— a similar effort to intervene on a "reputational" claim. That claim was made by Bruce Reinhart who — like Dershowitz — had previously represented Jeffrey Epstein's interests in related litigation. Reinhart moved to intervene in this case to contest the victims' allegations that Reinhart (a former prosecutor in

attempted to block discovery of materials in this case, leading to an Eleventh Circuit ruling that the victims' discovery efforts were proper. Doe'. Epstein, 749 F.3d 999 (1 1 th Cir. 2014). 3 Remarkably, even though the Court directed the Government to begin producing discovery in June 2013, the Govern

e criminal prosecution broke) Dershowitz stated "I'm on my 20th book. . . . The only person outside of my immediate family that I send drafts to is Jeffrey." The Talented Mr. Epstein, by Vicky Ward, in Vanity Fair (Jan. 2005)21 Dershowitz has also been quoted as saying that, even if Epstein went bankrup

n asked: Do you know what Jeffrey Epstein's relationship is with Alan Dershowitz? That's somebody [i.e., Dershowitz] who you know to have stayed at Jeffery Epstein's house on many occasions, correct? And also somebody who you know to have been at the house when E.W. was in Jeffrey Epstein's bedroom getting sexua

in took the Fifth when asked during his deposition "[h]ave you ever socialized with Alan Dershowitz in the presence of females under the age of 18?" Jeffrey Epstein Depo. at 90, Epstein'. Edwards, No. 502009CA040800XXXXMB (Palm. Beach Cty. Cir. Ct. Mar. 17, 2010) (excerpts attached as Exhibit 24). Indeed, going a ste

tance. She was sexually trafficked and abused by Mr. Epstein (and others at the direction of Mr. Epstein) not

ediate family that I send drafts to is Jeffrey." The Talented Mr. Epstein, by Vicky Ward, in Vanity Fair (Jan. 2005)21 Der

ie.c.villafana@usdojdzov Attorneys for the Government Thomas Scott [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre H 9150 South Dadeland Boulevard, Suite 1400 Miami, Florida 33156 Telephone: (305) 350-5300 Facsimile: (305) 373-2294 -and- Kendall Coffey [email protected] Gabriel

650 652 1 APPEARANCES (Continued): 1 Thereupon. the proceedings continued at 9:04 a.m. 2 2 VIDEOGRAPHER: Are now on the video 3 On behalf of Jeffrey Epstein: 3 record. This is the 13th day of January. 2016. 4 DARREN K. INDYKE. PLLC 4 The time is 9:04 am. This is the videotaped 575 Lexington Ave.. 4

uld allow him to answer it. He's 670 672 1 those allegations? 1 trying to be responsive to the question. 2 A. I don't think he was aware that Jeffrey 2 Please proceed. 3 Epstein had nude an allegation of that kind. 3 A. One of them was a Conner president or 4 Q. At the time when David Marku

670 672 1 those allegations? 1 trying to be responsive to the question. 2 A. I don't think he was aware that Jeffrey 2 Please proceed. 3 Epstein had nude an allegation of that kind. 3 A. One of them was a Conner president or 4 Q. At the time when David Markus called you 4 chairman or at

ou 8 Rothstein did not do anything without conferring 8 Brad Edwards was the brains behind the Scott 9 with Brad Edwards. were you representing Jeffrey 9 Rothstein operation? 10 Epstein? 10 A. I cant give you a name of somebody who 11 A. Yes. 11 said those precise words outside the privilege. 1

YKE: If Mr. Dershowitz is 4 I. 4 referring to Mr. Epstein. then I would object 5 BY MR. EDWARDS: 5 to —

ant: Certificate of Reporter 779 9 COLE. SCOTT & KISSANE. P.A. 8 Read and Sign Letter to Witness 780 10 Dadeland Centre II - Suite 1400 9150 South Dadeland Boulevard Miami. Herida 33156 9 Errata Sheet (forwarded upon execution) 781 11 BY: THOMAS EMERSON SCOTT. JR.. ESQ. 10 PLAINTIFF EXHIBITS thotnas.scou6

original, native format in which they were taken (not a paper copy) not produced in response to Request No. 2, above, of Alan M. Dershowitz at (i) Jeffrey Epstein's Manhattan home in New York City, New York; (ii) Mr. Epstein's home in Palm Beach, Florida; (iii) Mr. Epstein's Zorro Ranch in Santa Fe, New Mexico;

not produced in response to Request No. 2, above, of Alan M. Dershowitz at (i) Jeffrey Epstein's Manhattan home in New York City, New York; (ii) Mr. Epstein's home in Palm Beach, Florida; (iii) Mr. Epstein's Zorro Ranch in Santa Fe, New Mexico; (iv) Little Saint James island in the U.S. Virgin Islands;

quest No. 2, above, of Alan M. Dershowitz at (i) Jeffrey Epstein's Manhattan home in New York City, New Yo

s Manhattan home in New York City, New York; (ii) Mr. Epstein's home in Palm Beach, Florida; (iii) Mr. Epstein

om Steven R. Safra Florida Bar No. 057028 [email protected] COLE, SCOTT & KISSANE, P.A. Cole, Scott & Kissane Building, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson [email protected] Mary E. Botja [email protected] A

tantly before a Non-Prosecution Agreement is entered. (See, DE 99 and DE 189 at 8.) The decision to not pursue federal criminal prosecution against Jeffrey Epstein was made, at latest, on September 24, 2007 when a Non- Prosecution Agreement (hereinafter "NPA") was negotiated, finalized, and then executed by the

xecuted by the Government and Jeffrey Epstein. The Petitioners in this case have vigorously argued that the decision not to federally prosecute Mr. Epstein did not moot their CVRA In the event the Court declines to accept this submission as a supplement to Dershowitz's pending Motion for Limited Interv

not pursue federal criminal prosecution against Jeffrey Epstein was made, at latest, on September 24, 200

gued that the decision not to federally prosecute Mr. Epstein did not moot their CVRA In the event the Court d

er these unfortunate circumstances. Respectfully submitted, Thomas Scott. Fla. Bar No. 149100 COLE, SCOTT & KISSANE, U. Dadeland Centre H 9150 South Dadeland Boulevard, Stine 1400 Miami, Florida 33156 Telephone: (305) 350-5300 Facsimile: (305) 373-2294 -and- is/Kendall Coffey Kendall Coffey, Fla. Bar No. 259681

if You have the right to secure the Document or a copy thereof from another person. 7. "Edwards," "You" and "Your" means Bradley J. Edwards. 8. "Epstein" means Jeffrey Epstein. 9. "Federal Action" means the matter styled Jane Doe #1, et al. v. United States of America, Case No. 08-80736-CIV-MARRA/J

right to secure the Document or a copy thereof from another person. 7. "Edwards," "You" and "Your" means Bradley J. Edwards. 8. "Epstein" means Jeffrey Epstein. 9. "Federal Action" means the matter styled Jane Doe #1, et al. v. United States of America, Case No. 08-80736-CIV-MARRA/JOHNSON (S.D. Fla.). 10

r" means Bradley J. Edwards. 8. "Epstein" means Jeffrey Epstein. 9. "Federal Action" means the matter s

Scott Thomas E. Scott Florida Bar No. 149100 Steven It Safra Florida Bar No. 057028 COLE, SCOTT & K1SSANE, Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 350.5300 Fax: (305) 373-2294 Counsel for Alan M. Dershowitz CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a t

e by making repeated and voluntary statements about her allegations about being a "sex slave" who was purportedly sexually trafficked as a minor by Jeffrey Epstein, as well as by disclosing the substance of her communications with Plaintiffs, including through her disclosure of and reliance on a 2011 interview

ortedly sexually trafficked as a minor by Jeffrey Epstein, as well as by disclosing the substance of her c

was purportedly sexually trafficked as a minor by Jeffrey Epstein, as well as by disclosing the substance

E Scott, Esq. Florida Bar No. 149100 Steven R. Safra. Esq. Florida Bar No. 05702 COLE, SCOTT & KISSANE. P.A. Dadeland Centre II, 14th Hoor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: Fax: Richard A. Sim son ro hac vice) ~wc vice) WILEY REIN LLP 1776 K Street, NW Washin ton DC 20006 Phon - Fa

istrict of Florida (the "Federal Action") more than eight years ago. In the Federal Action, Edwards and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend that the Government violated their rights under the Crime Victims Rights Act (the "CVRA"). Specifically, the

the Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement (the "NPA") with Epstein, who allegedly subjected them to various sexual crimes when they were minors. On December 30, 2014 — more than eight years after the Federal Action

and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend t

Scott Thomas E. Scott Florida Bar No. 149100 Steven R. Safra Florida Bar No. 057028 COLE, SCOTT & KISSANE, Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson admittec i ce Mary E. Botja (admittet ice) Ashley E. Eiler

15-000072 Plaintiff(s), JUDGE: LYNCH v. ALAN M. DERSHOWITZ, Defendant. I MOTION FOR RECONSIDERATION OF THIS COURT'S ORDER DENYING NON- PARTY JEFFREY EPSTEIN'S MOTION TO OUASH SUBPOENA Jeffrey Epstein (hereinafter "Epstein"), a non-party to this action, by and through his undersigned counsel and pursuant t

nt. I MOTION FOR RECONSIDERATION OF THIS COURT'S ORDER DENYING NON- PARTY JEFFREY EPSTEIN'S MOTION TO OUASH SUBPOENA Jeffrey Epstein (hereinafter "Epstein"), a non-party to this action, by and through his undersigned counsel and pursuant to Rule 1.530 of the Florida Rules of Civil Procedure, hereby mo

DERATION OF THIS COURT'S ORDER DENYING NON- PARTY JEFFREY EPSTEIN'S MOTION TO OUASH SUBPOENA Jeffrey Epste

67.1223 EFTA00582769 SERVICE LIST Thomas Scott, Esquire Steven Safra, Esquire COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Richard A. Simpson, Esquire Mary Botja, Esquire WILEY REIN LLP 1776 K Street, NW Washington, DC 20006 Jack Scarola, Esqui

and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend t

istrict of Florida (the "Federal Action") more than eight years ago. In the Federal Action, Edwards and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend that the Government violated their rights under the Crime Victims Rights Act (the "CVRA"). Specifically, the

the Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement (the "NPA") with Epstein, who allegedly subjected them to various sexual crimes when they were minors. On December 30, 2014 — more than eight years after the Federal Action

Scott Thomas E. Scott Florida Bar No. 149100 Steven R. Safra Florida Bar No. 057028 COLE, SCOTT & KISSANE, Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson (admitted pro hac vice) Mary E. Borja (admitted pro hac vice

pecializes in sex 11 trafficking. 12 I needed to call them to prove what I knew 10:15:49 13 immediately, that the only time I was ever at 14 Jeffrey Epstein's ranch was when I went to visit the 15 Ashes in New Mexico. I spoke to their daughter, the 16 prosecutor's, class. She was then in high school, 1

heir daughter, the 16 prosecutor's, class. She was then in high school, 17 and took a day trip to Santa Fe. 18 Ashe had known -- had heard that Jeffrey 10:16:15 19 Epstein had bought a ranch, a very large ranch in 20 New Mexico and Ashe was very interested in the 21 outdoors and asked me if I

prosecutor's, class. She was then in high school, 17 and took a day trip to Santa Fe. 18 Ashe had known -- had heard that Jeffrey 10:16:15 19 Epstein had bought a ranch, a very large ranch in 20 New Mexico and Ashe was very interested in the 21 outdoors and asked me if I would do him a favor an

Y: JACK SCAROLA, ESQ. 6 [email protected] 7 8 On behalf of Defendant: 9 COLE, SCOTT & KISSANE, P.A. Dadeland Centre II - Suite 1400 10 9150 South Dadeland Boulevard Miami, Florida 33156 11 BY: THOMAS EMERSON SCOTT, JR., ESQ. [email protected] 12 BY: STEVEN SAFRA, ESQ. (Via phone) steven.safra@cskl