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While investigations by other plaintiffs' attorneys and I have uncovered other persons who were acquaintances of Epstein, specifically David Trump, Alan Dershowitz, Bill Clinton, Tommy Mottola, and David Copperfield, we have no information that any of those people (other than Mr. Dershowitz) have spoken to Eps
y David Trump, Alan Dershowitz, Bill Clinton, Tommy Mottola, and David Copperfield, we have no information that any of those people (other than Mr. Dershowitz) have spoken to Epstein about Jane Doe or any of the other victims of Epstein's molestation. Mr. Dershowitz is acting as an attorney for Epstein, an
ws Ave., Suite 2, Fort Lauderdale, FL 33301 Jack Alan Goldberger, Esq., 250 Australian Avenue South, Su
reasons, as well as those set forth in the Affidavit of Michael Fisten, the Affirmation of Robert Y. Lewis, and the accompanying Memorandum of Law, Affiant requests that the Court issue an order pursuant to CPLR 3102(e) for production of the recording. On September , 2010, before me came rachey James
e. He then asked for and got a federal investigation. Epstein hired a phalanx of high-r antapi d lawyers — includ- ing law professor and author Alan Dershowitz — and public relations people who questioned Reiter's com- petence and the victims' truthfulness. In addition to mansions in Palm Beach and Manh
ers — includ- ing law professor and author Alan Dershowitz — and public relations people who questioned Re
lawyers — includ- ing law professor and author Alan Dershowitz — and public relations people who qu
id not require the issuance of a warrant, the forensic review that is requested by this application would expand that review and, accordingly, your Affiant requests the issuance of a search warrant in accordance with United States v. Jacobsen, 466 U.S. 109, 115-21 (1984). 23. As explained above, Epste
of tears." Herman has described both Jane Does as typical teenage girls Epstein robbed of their innocence. But Harvard University law Professor Alan Dershowitz, another Epstein attorney, pro- vided the state attorney's of- fine with information gleaned from the myspace-Corn Web site two years ago sh tha
ence. But Harvard University law Professor Alan Dershowitz, another Epstein attorney, pro- vided the state
innocence. But Harvard University law Professor Alan Dershowitz, another Epstein attorney, pro- vide
solicitation of minors to engage in prostitution and his lewd and lascivious conduct with minors. The FBI opened a case file in July 2006, and your Affiant is the case agent assigned to the investigation. 7. At around the same time that the FBI opened its investigation, the U.S. Attorney's Office bega
gement and/or non-prosecution agreement, including efforts on his behalf by former President Bill Clinton, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove the victims allegation that, after Epstein signed the non-prosecution agreement, his performance was delayed wh
n, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove the victims
linton, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove t
e FBI's Victim-Witness Specialist. Attached hereto arc copies of the letters provided to Bradley Edwards' three clients, T.M.. C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex. I ). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was int
gotiate theNon-Frosecution Agreement These negotiations were detailed and time-consuming. Mr. Epstein's defense team, including yourself, Professor Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy Black, Jack Goldberger, Gerry Lefeourt and Jay Lefkowitz had the opp
Florida Statute Section 796.03. At our meeting, Professor Dershowitz took the position that Mr. Epstein believes that
ey Epstein ("Part 3"). EFTA00234649 Case 9:08-cv-80736-KAM Document 35 Entered on FLSD Docket 12/22/2008 Page 2 of 4 4. On July 9, 2008, your Affiant sent a victim notification letter to Jane Doe #1, which contained pertinent language from "Part 3" of the Agreement (Ex. 6 to the July 9 Decl.). 5
gotiate theNon-Frosecution Agreement These negotiations were detailed and time-consuming. Mr. Epstein's defense team, including yourself, Professor Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy Black, Jack Goldberger, Gerry Lefcourt and Jay Lefkowitz had the opp
Florida Statute Section 796.03. At our meeting, Professor Dershowitz took the position that Mr. Epstein believes that
ey Epstein ("Part 3"). EFTA00213127 Case 9:08-cv-80736-KAM Document 35 Entered on FLSD Docket 12/22/2008 Page 2 of 4 4. On July 9, 2008, your Affiant sent a victim notification letter to Jane Doe #1, which contained pertinent language from "Part 3" of the Agreement (Ex. 6 to the July 9 Decl.). 5
levard Suite 250 Co-counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury, Goldberger, & Weiss,
9, 2008 in pertinent part (pages 1 , 4, 6 and 7) attached as Exhibit "C" hereto Exhibit C, par. 12 specifically states: 12. On today's date, your Affiant provided the attached victim notifications to ■. and via their attorney, Bradley Edwards (Exs. 6 & 7). A notification was not provided to ■. beca
SS X Index No: 13 Civ. 8563 (PKC) Affidavit Alan P. Fraade, being duly sworn, deposes and says: 1
ation. 8. By consequence of this retainer agreement and with respect to the matter of Mr. Hoffenberg's supervisory release, the sole action by the Affiant has been to make two phone calls to Mr. Hoffenberg's Probation Officer, Mr. Michael Cox, as well as sending one e-mail. 9. We do not represent Mr.
ent's (unopposed) motion. FN3.See a1so3 Charles Alan Wright et al., Federal Practice & Procedure § 52
r, and have been at all times and still am ready and willing to sell the brewers all such stamps as they may wish to purchase.' He also states: 'Affiant further says that while he held the office of collector of internal revenue of the Third district of New York, as aforesaid, he never did at any ti
ppropriate 13:1,6 certainly 12:8 13:25 15:11 4:22 bench 12:10 content al argue 11:11 certify 15:1 2:3,6 5:4 8:7 Berger 16:4 contest ALAN argument 2:10 3:10,10 chance 8:10 2:2 9:9 14:8 3:20,21,22 8:7 copy EFTA00233762 Proceedings June 10, 2009 2 6:14,23 correctly 8:15 c
gst other offenses. 3. Throughout the investigation, when a victim was identified, victim notification letters were provided to her both from your Affiant and from the FBI's Victim-Witness Specialist. Attached hereto are copies of the letters provided to Bradley Edwards' three clients, T.M., C.W., and
Entities connected to both Alan Dershowitz and Affiant

Jeffrey Epstein
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Marc Rich
PERSONJack Goldberger
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSON
Paul Cassell
PERSONJane Doe
PERSON
Richard Kahn
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONMartin Weinberg
PERSONMaria Farmer
PERSONSouthern District
LOCATION
Woody Allen
PERSONWeiss
PERSON