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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
ationally televised news interviews, wrongfully claimed that Edwards and Cassell had engaged in unethical behavior warranting disbarment for filing the Joinder Motion that described Defendant's involvement with Epstein and Plaintiff. Edwards, who is a prominent lawyer for sexually abused women and children, and Ca
pstein’s victims. As a consequence, the victims were not told about the NPA. 42. On July 7, 2008, a young woman identified as Jane Doe No. 1, one of Jeffrey Epstein’s victims (other than Roberts), filed a petition to enforce her rights under the Crime Victims’ Rights Act (“CVRA”), 18 U.S.C. 9 3771, alleging that th
ring 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 billionai
for many years. (Exhibit 7). In 2003, Dershowitz said “I’m on my 20" book... The only person outside of my immediate family that I send drafts to is Jeffrey.” “The Talented Mr. Epstein.” Vanity Fair 2003. (Exhibit 8). Dershowitz also described Epstein as his friend “I would be interested in him [Epstein]
. Brown A decade before #MeToo, a multimillionaire sex offender from Florida got the ultimate break. fy Palm Beach County Courthouse June 30, 2008 Jeffrey Edward Epstein appeared at his sentencing dressed comfortably in a blue blazer, blue shirt, jeans and gray sneakers. His attorney, Jack Goldberger, was at his side
ntiff 34. Dershowitz has been “a close friend of Mr. Epstein” for many years. (Exhibit 7). In 2003, Dershowitz
ediate family that I send drafts to is Jeffrey.” “The Talented Mr. Epstein.” Vanity Fair 2003. (Exhibit 8). Dershowitz also
nationally televised news interviews, wrongfully claimed that Edwards and Cassell had engaged in unethical behavior warranting disbarment for filing the Joinder Motion that described Dershowitz’s involvement with Epstein and Roberts. Edwards, who is a prominent attorney for sexually abused women and children, and Ca
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
All Documents Concerning own benefit. 23. All Documents Concerning to influence the terms of the NPA. any press release Concerning this action, the Joinder Motion, any assertion that Dershowitz was a "co-conspirator" with any assertion that Dershowitz negotiated the NPA for his any actions allegedly taken by
s federal civil actions in Florida. Compl. ¶ 8-21, 26-27. Ms. Maxwell was not a party to any of those litigations: not the criminal case against Mr. Epstein (Compl. ¶ 14), any non-prosecution agreement between Mr. Epstein and the U.S. Attorney's Office (Comp1.11 11-13), the litigation concerning the Cri
those litigations: not the criminal case against Mr. Epstein (Compl. ¶ 14), any non-prosecution agreement bet
eaders." Menninger Decl. Ex. C at 4-5. On April 7, 2015, U.S. District Court Judge Marra denied Plaintiff's Joinder Motion, ordered the portions of the Joinder Motion pertaining to non-parties Although the Complaint does not explicitly mention the 2011 Statement, it appears Plaintiff believes it to be the "additi
Entities connected to both Jeffrey Epstein and the Joinder Motion

Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONJane Doe
PERSONMaria Farmer
PERSONMartin Weinberg
PERSON
Alfredo Rodriguez
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSON
Bill Clinton
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
New York
LOCATION
Wilbur Ross
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSON