Epstein Secrets

him. Afterwards, Carlos Sires ("Sires"), a partner at the Firm's Fort Lauderdale office, emailed Dershowitz saying Jeffrey Epstein's compatriot, Ghislaine Maxwell. that Defendant had a "very strong appearance on the (Schiller Decl. Ex. I2 at ¶ 8). Today [S]how" and informing him, "If there is anythi

ards, Carlos Sires ("Sires"), a partner at the Firm's Fort Lauderdale office, emailed Dershowitz saying Jeffrey Epstein's compatriot, Ghislaine Maxwell. that Defendant had a "very strong appearance on the (Schiller Decl. Ex. I2 at ¶ 8). Today [S]how" and informing him, "If there is anything I Sir

his is a subject on which reasonable men may differ." Reynolds v. Pegler 223 F.2d at 433. In M. MtucwelMas she does here, alleged that defendant Ghislaine Maxwell's statements in that case were made "with malice and knowledge of their falsity." 165 F. Supp. 3d at 155. This was a sufficient pleading to defeat a

Court:] You argue at page 5 of your reply that if Ms. Maxwell's simple denials destroyed the plaintiffs reputa

oies Schiller Flexner LLP, New York, NY, for Plaintiff. Arthur Louis Aidala, Law Offices of Aidala & Bertuna, P.C., Brooklyn, NY, Christian Kiely, Howard M. Cooper, Todd & Weld LLP, Boston, MA, Imran H. Ansari, Aidala Bertuna & Kamins PC, New York, NY, for Defendant. OPINION & ORDER LORETTA A. PRESKA, Senior

Office of the United States Attorney Southern District of New York One Saint Andrews Plaza New York, NY 10007 Ann: AUSAs Re: United States v. Maxwell Dear Counsel: 546 FIFTH MULE NEW YORK. IC( 10036 TELEPHONE: (212) 486-0011 FACSIMILE (917) 261-4832 WIVIN.ACALALAW.CCOA June 16, 2022 8118 •

f of Professor Alan Dershowitz to provide my opinions as a legal ethics expert regarding prosecutors' candor obligations relating to submissions at Ghislaine Maxwell's upcoming sentencing. The relevant facts, provided for my consideration, are, in brief, as follows. Although was not a witness at Ms. Maxwell's tria

pact statement during the sentencing phase of the Ghislaine Maxwell trial and therein vouch in that proceedi

brief, as follows. Although was not a witness at Ms. Maxwell's trial, she has been notified of her right to ma

. Imran H. Ansari Arthur L. Aidala Barry Kamins John M. Leventhal end: Bruce Green Letter cc: Todd & Weld, LLP Attorneys for Alan Dershowitz Howard M. Cooper Christian G. Kiely Kristine C. Oren - 2 - AIDALA, BERTUNA 8 KAMINS. P.C. • 546 FIFTH AVENUE. NEW YORK, NY, 10038 • T• 212.466-0011 • F: 917-201.4

Office of the United States Attorney Southern District of New York One Saint Andrews Plaza New York, NY 10007 Attn: AUSAs Re: United States v. Maxwell Dear Counsel: 6116 13" AVENUE BROOKIN. NEW YORK 11226 TEL r718) 2)84898 MX' fa1-32/.2 OF COUNSEL JOSEPH A. BARATTA ANTOINETTE LANTOS VALUA

informed basis, whether it would be appropriate or ethical for you to allow Ms. to give a victim impact statement during the sentencing phase of the Ghislaine Maxwell trial and therein vouch in that proceeding for her credibility. Both the Court, and ..ounsel, have made clear that they agree that we may notify

pact statement during the sentencing phase of the Ghislaine Maxwell trial and therein vouch in that proceedi

Arthur L. Aidala \-Pemr(A-F)ciesiW Barry Kamins John M. Leventhal end: Bruce Green Letter cc: Todd & Weld. LLP Attorneys 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