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IONS A. Epstein's Sex Trafficking Enterprise 30. Plaintiff became a victim of sex trafficking and repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein when Plaintiff was under the age of eighteen. 31. Between 2000 and 2002, Epstein sexually abused Plaintiff at numerous locatio
e he feared a reopening of a federal criminal investigation of him. 53. Defendant made his statements pursuant to his conspiracy with Epstein and Maxwell maliciously as part of an effort to conceal sex trafficking crimes committed around the world by Epstein and other powerful persons. 54. Defendant
d repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein when Plaintiff was un
s friend. "I would be as interested in him [Epstein] as a friend if we had hamburgers on the boardwalk in Coney Island and talked about his ideas." Ray Gustini, Vanity Fair Reminds Us When Jef•ey Epstein Wasn't a Creep, THE ATLANTIC (June 21, 2011), https://bit.ly/38ZwHGK. Defendant frequently traveled with
inister pattern — it is also worth noting that each of the other four individuals Jane Doe No. 3 identified by name in her motion (Jeffrey Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have also all been afforded opportunities to explain themselves — and all four have declined to take them. Eps
After extensive discussion and coordinating a convenient time and place, as well as ultimately agreeing to a confidentiality agreement prepared by Maxwell's attorney, at the eleventh hour Maxwell's attorney informed the undersigned that Maxwell's mother was very ill and that consequently Maxwell was le
entified by name in her motion (Jeffrey Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have
d if we had hamburgers on the boardwalk in Coney Island and talked about his ideas." Vanity Fair Reminds Us When Jeffrey Epstein Wasn't a Creep, by Ray Gustini, in The Wire (June 21, 201 I). Second, Jeffrey Epstein brazenly abused numerous girls in his Florida mansion, his New York mansion, and several oth
inister pattern — it is also worth noting that each of the other four individuals Jane Doe No. 3 identified by name in her motion (Jeffrey Epstein. Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have also all been afforded opportunities to explain themselves — and all four have declined to take them. Eps
ked questions about his sexual abuse of young girls. including Jane Doe No. I. Jane Doe No. 2, and Jane Doe No. 3. See generally Exhibit 16 at 1-7. Maxwell. In 2009, undersigned counsel (Brad Edwards) served Ghislaine Maxwell with a subpoena for a deposition in a civil case against Jeffrey Epstein. Afte
entified by name in her motion (Jeffrey Epstein. Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have
if we had hamburgers on the boardwalk in Coney Island and talked about his ideas.- Vanity Fair Reminds Us When Jeffrey Epstein Warn 't a Creep. by Ray Gustini, in The Wire (June 21, 2011). Second, Jeffrey Epstein brazenly abused numerous girls in his Florida mansion, his New York mansion, and several othe
quoting Dershowitz as stating “I’m on my 2(th book. . .. The only person outside of my immediate family that | send drafts to is Jeffrey.”); see also Ray Gustini, Vanity Fair Reminds Us When Jeffrey Epstein Wasn't a Creep, in The Wire (June 21, 2011) (quoting Dershowitz as stating that even if Epstein went ban
Page: HOUSE_OVERSIGHT_016198 →vidence I possessed showed the following things. 36. On February 9, 1998, Alan Dershowitz appears on flight #1073 to Teterboro Airport with Epstein, Ghislaine Maxwell, Emmy Taylor, Claire Hazel, Joel Pashcow, one unidentified female, Mandy and Dubins +1 (without his wife). 37. On February 5, 2004, Alan Dershowitz
Page: HOUSE_OVERSIGHT_016200 →n flight #1073 to Teterboro Airport with Epstein, Ghislaine Maxwell, Emmy Taylor, Claire Hazel, Joel Pashcow,
Page: HOUSE_OVERSIGHT_016200 →e course of professional dealings with them, including working closely with them as co-counsel to represent Ms. Giuffre in the complicated Giuffre v. Maxwell case. At all times they have exhibited nothing but the highest levels of professionalism and adherence to cthical requirements. 54, I expected no le
Page: HOUSE_OVERSIGHT_016201 →Entities connected to both Ghislaine Maxwell and Ray Gustini

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
FedEx
ORGANIZATION
Marc Rich
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSON
Les Wexner
PERSONJane Doe
PERSONEmmy Taylor
PERSON
Joe Biden
PERSON
David Boies
PERSON
Vicky Ward
PERSON
David Rodgers
PERSON