Epstein Secrets

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

, West Palm Beach, Florida 33409. Respectfully submitted, 5/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 Thomas.scott @csklegal.com Steven R. Safra Florida Bar No. 057028 [email protected] COLE, SCOTT & KISSANE, P.A. Cole, Scott & Kissane Building, 14th Floor 9150 South Dadeland Boul

Dershowitz, including (a) "[h]ave you 22 EFTA00613430 ever met a young girl, under the age of 18, in the presence of Jeffrey Epstein or on one of Jeffrey Epstein's properties?"; (b) "[d]idn't Jeffrey Epstein tell you that he repeatedly had sex with these underage girls?"; (c) in reference to the NPA, "[i]sn't i

dual against whom made allegations and requesting a response from him, for financial or other gain. has asserted under oath that Jeffrey Epstein ("Epstein") "arranged for many politically powerful, older men to have sex with underage girls—including me. Because these were crimes—and because some of th

elp me sort out what the names were, specifically Jeffrey Epstein, among others, have refused to cooperate

a Non-Prosecution Agreement entered into between Mr. Epstein and the United States Attorney's Office for the

end, it would be an abuse of discretion for the Court to deny Dershowitz's request. 15 EFTA00613405 Respectfully submitted, s/ Thomas E. Scott Steven R. Safra, FBN 057028 COLE, SCOTT & KISSANE, P.A. Richard A. Simpson (pro hac vice) Ma E. Bo 'a ro hac vice) Ashle E. Filer ro hac vice) Nicole Audet Ric

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

pre-trial deposition of the party]."). 8 EFTA00622842 Respectfully submitted, Is/ Thomas E. Scott Thomas 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:

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

sition of Jane Doe No. 3. 21 EFTA00582669 Dated: May 2015 Respectfully Submitted, s/ Thomas E. 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) 35

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

sition of Jane Doe No. 3. 19 EFTA00584080 Dated: May 2015 Respectfully Submitted, s/ Thomas E. 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) 35

[sexually abuse her] .. . even the most minimal of investigation would have proven conclusively that I could not have had sex with their client on Mr Epstein’s island, in New Mexico or on the airplanes; and that I did not have sex with her in his New York or Palm Beach homes.” DE 282-1 at { 8. On January

, custody or control. 2 Copies of any and all documents reflecting or relating to any and all occasions on which you have been physically present at Jeffrey Epstein’s Ranch in New Mexico including but not limited to your visit to Jeffrey Epstein’s Ranch in New Mexico, as described in paragraph 4 of the sworn Declar

documents evidencing the presence of “members of Mr. Epstein’s legal team”, as described in paragraph 5 of the

iuffre committed perjury by stating in her previously filed affidavit that it is her recollection that she witnessed former President Bill Clinton on Jeffrey Epstein’s island in the United States Virgin Islands (“USVI’)'. Setting aside Defendant Dershowitz’s baseless claims of perjury, Ms. Giuffre agrees that her c

grees to make his client, Jeffrey Epstein, and others with relevant testimony and with whom he has testified he shares a “common interest” — at least Epstein and Maxwell — available to any law enforcement agency reviewing any alleged criminal activities; or in the alternative, to attest to this Court that

t. It is worth noting on that point, that despite Mr. Epstein’s counsel’s attendance at depositions in this cas

as stated in an affidavit originally filed publicly in federal court in what the parties have referred to as the CVRA Action that she was present on Jeffrey Epstein’s private island, Little St. James Island, at the same time as former President Clinton. That affidavit was HOUSE_OVERSIGHT_010887 --- PAGE BREAK --

President Clinton did not leave office until January of 2001, and Roberts has repeatedly stated in publicly filed affidavits that she “escaped” from Epstein while in Thailand in September of 2002, the alleged meeting with former President Clinton must have taken place between January of 2001 and September

lief from that Confidentiality Order. Respectfully submitted, s/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 [email protected] Steven R. Safra Florida Bar No. 057028 [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Flo

15595 --- PAGE BREAK --- Dated: February 3, 2016 Respectfully submitted, s/Thomas E. Scott Thomas E. Scott, FBN 149100 [email protected] Steven R. Safra, FBN 057028 [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156

unting the allegations: The Joinder Motion then goes on to allege — without any supporting evidence — as follows: One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein’s and well-kn

Q. [Y]ou [are] aware that years before December of 2014, when the CVRA pleading was filed, that your name had come up repeatedly in connection with Jeffrey Epstein’s abuse of minors, correct? . . . A. Let me answer that question. I am aware that never before 2014, end of December, was it ever, ever alleged that I