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legations of sexual abuse extend beyond just Ms. Maxwell and encompass many notable public figures, such as Prince Andrew and Harvard Law Professor Alan Dershowitz, as well as un-named "numerous American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world
light on the false accusations directed at Ms. Maxwell. In response to Plaintiff's published claims, Ms. Maxwell (like Prince Andrew and Professor Dershowitz), issued general denials to the allegations. Those two denials form the basis of this defamation action: Plaintiff claims it defamatory for Ms. Maxw
shed claims, Ms. Maxwell (like Prince Andrew and Professor Dershowitz), issued general denials to the allegations. Thos
such as Prince Andrew and Harvard Law Professor Alan Dershowitz, as well as un-named "numerous Americ
force, Inc. v. Alden Personnel, Inc., 288 F.Supp.2d 513, 516 (S.D.N.Y. 2003) 16, 21 Kirk v. Heppt, 532 F.Supp.2d 586 (S.D.N.Y. 2008) 14 Krepps v. Reiner, 588 F.Supp.2d 471, 483 (S.D.N.Y. 2008) 7 Liberman v. Gelstein, 80 N.Y.2d 429, 590 (N.Y. 1992) 22 McNamee v. Clemens, 762 F.Supp.2d 584, 601 (E.D
ion. Sixth, plaintiff argues that Mr. Epstein should be required to appear personally to answer questions regarding his relationship with Professor Dershowitz on the off chance that it might prove admissible and even though she has herself moved to exclude information about Prof. Dershowitz from the trial
answer questions regarding his relationship with Professor Dershowitz on the off chance that it might prove admissible
IN By his attorneys, 8 EFTA00589517 /s/ Jack Alan Goldberger Jack Alan Goldberger Atterbuiy, Gold
ge. Response at 3-4. Leaving aside the question whether one can "contaminate" proceedings by quoting from opinions of the Supreme Court, see Ohio v. Reiner, 532 U.S. 17, 21 (2001)("we have emphasized that one of the Fifth Amendment's basic functions . . . is to protect innocent men ... who otherwise mi
ion. Sixth, plaintiff argues that Mr. Epstein should be required to appear personally to answer questions regarding his relationship with Professor Dershowitz on the off chance that it might prove admissible and even though she has herself moved to exclude information about Prof. Dershowitz from the trial
answer questions regarding his relationship with Professor Dershowitz on the off chance that it might prove admissible
ed, JEFFREY EPSTEIN By his attorneys, is/ Jack Alan Goldberger Jack Alan Goldberger Atterbury, Gold
ge. Response at 3-4. Leaving aside the question whether one can "contaminate" proceedings by quoting from opinions of the Supreme Court, see Ohio v. Reiner, 532 U.S. 17, 21 (2001)("we have emphasized that one of the Fifth Amendment's basic functions . . . is to protect innocent men ... who otherwise mi
d am available to discuss this and any other issues at your earliest convenience. Very truly yours, Go-a( Gerald B. Lefcourt alak,,,.1 44A),,5 Alan Dcrshowitz cc: Lilly Ann Sanchez, Esq. Roy Black, Esq. EFTA00226777 STEVEN PINKER Johnstone Family Professor DEPARTMENT OF PSYCHOLOGY HARVARD UNIVERSITY
RTMENT OF PSYCHOLOGY HARVARD UNIVERSITY Professor Alan Dershowitz Harvard Law School Harvard University Cambridge, MA 02138 June 28, 2007 Dear Alan, I'm happy to offer the help of my knowledge in linguistics to determine the natural interpretation of a statute you have inquired about. My commen
OF PSYCHOLOGY HARVARD UNIVERSITY Professor Alan Dershowitz Harvard Law School Harvard University Cambridg
of their trip and that one of the motivating purposes of requiring victim to accompany him was to facilitate their sexual relationship. 3) U.S. I Reiner, 397 I Supp. 2d 101 (D. Me. 2005). This case discusses the forfeiture of assets related to a "massage parlor"/ "health club" that was a front for p
32, 08-80380, 08-80381, 08-80993, 08- 80994 Jack Alan Goldberger, Esq. AUerbury Goldberger & Weiss, P.
486 (1951). Epstein, in fact, can deny the occurrence of the nesindta alleged and still maintain the safe harbor of the 5'" Amendment2 ate Ohio v. Reiner, 532 U.S. 17 (1991). 2 See PeLisi v. Bankers Ins. Company 436 So.2d 1099 (Fla. 4d. DCA 1983); Malloy v. Hogan. 84 S.Ct. 1489, 1495 (1964Xthe Fifth
day of March, 2009. Adam D. Horowitz, Esq. Jack Alan Goldberger EFTA00222107 Case 9:08-cv-80119-KAM
ceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985), citing Lefkowitz v. Turlev 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege is also available to those who claim innocence. One of the Fifth Amendment's
nlaw.com Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 2
ceedings." Edwin v. Price 778 F.2d 668, 669 (11i' Cir. 1985), citing Lefkowitz v. Turley 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner 532 U.S. 17, 21, 121 S.Q. 1252 (2001)(The Fifth Amendment privilege is also available to those who claim innocence. One of the Fifth Amendment's "b
ff Service List in the manner specified by Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P
eedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985), citin Lefkowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege is also available to those who claim innocence. One of the Fifth Amendment's
day of March, 2009. Adam D. Horowitz, Esq. Jack Alan Goldberger Stuart S. Mermelstein Es• Atterbu Go
ceedings." Edwin v. Price 778 F.2d 668, 669 (11i' Cir. 1985), citing Lefkowitz v. Turley 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner 532 U.S. 17, 21, 121 S.Q. 1252 (2001)(The Fifth Amendment privilege is also available to those who claim innocence. One of the Fifth Amendment's "b
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Entities connected to both Alan Dershowitz and Reiner

Jeffrey Epstein
PERSONLeon Black
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSON
Paul Cassell
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONMartin Weinberg
PERSONRobert D. Critton
PERSONMaria Farmer
PERSONSouthern District
LOCATION
Woody Allen
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
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