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08-80736-C1V-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Plaintiffs. vs. UNITED STATES OF AMERICA, Defendant. MOTION FOR LIMITED INTERVENTION BY ALAN M. DERSHOWITZ Alan M. Dershowitz (herein, "Prof. Dershowitz"), a nonparty to this litigation, is the victim of scurrilous allegations made in Jane Doe #3 and Jan
g duplicative discovery to that which is already being sought in Broward County Circuit Court. One forum is enough to litigate reputations] issues. B. DERSHOWITZ SHOULD NOT BE ALLOWED TO INTERVENE IN THIS ACTION WHEN HE HAS DECLINED TO DEFEND HIS REPUTATION IN OTHER ACTIONS. Dershowitz also claims that he h
and they have spread around the world. What makes them doubly troubling is their irrelevancy: although categorically false, the allegations against Prof Dershowitz have absolutely nothing to do with whether the United States government violated its duty to confer with the Plaintiffs prior to entering into the n
in New York in Epstein's home. It was in Epstein's room (not the massage room). I was approximately 16 years old at the time. I called Dershowitz "Alan." I knew he was a famous professor. 27. The second time that I had sex with Dershowitz was at Epstein's house in Palm Beach. During this encounter
n-a I legal ions—tota Ily-fa Ise-38194285 I 573 (Dershow kz: "Right now. they have accused me of these .
e latest date on which, according to Dershowitz, the Government made the decision not to pursue federal criminal charges against Epstein. DE 285 at I. Dershowitz appears to be unaware that the Government told the victims well after that date that the Government was still "investigating" the case. DE 48 at 16.
2015 Page 27 of 40 attorneys proffered in her earlier motion — i.e., that Epstein sexually trafficked Jane Doc No. 3 to numerous persons, including Dcrshowitz. If the Court believes it would be useful. Jane Doe No. 3 requests an evidentiary hearing to prove she is telling the truth 19 and directs the Court
. at 122 (Palm Beach Cty. Cir. Ct. Oct. 8, 2009). In short, all the key conspirators in Epstein's sexual trafficking ring who could be asked about Derhowitz's involvement took the Fifth." This "[sJilence is . . . evidence of the most persuasive character." United States ex rd. Bilokumsky 'Tod, 263 U.S. 1
ictim to this case.: a young woman Jeffrey Epstein sexual abused when she was under age. On August 20, 2014. counsel sent a letter to U.S. Attorney Wilfredo Ferrer requesting the Government's consent to a stipulated motion to simply add her into the case (as had been done earlier with Jane Doe No. 2). Counsel
from exhibit 30, which is correspondence sent by Alan Dershowitz and Gerald Lefcourt, attorneys for Je
t. / ORDER GRANTING MOTION TO SEAL It is hereby ordered that the Unredacted version of Plaintiff's Response to Motion for Limited Intervention by Alan M. Dershowitz and Exhibit 30 of said Response be sealed until further order of this Court. DONE AND ORDERED in Chambers at Palm Beach County, Florida, this day
ung girls, there is no good reason that the Court should now allow a special, discretionary opportunity to intervene to respond to the allegations. C. DERSHOWITZ SHOULD NOT BE ALLOWED TO INTERVENE TO STRIKE ALLEGATIONS RELEVANT TO ISSUES PENDING BEFORE THE COURT. The Court should also deny Dershowitz's motio
ut lacking such an allegation, his existing motion does not allege any concrete impainnent of his interests supporting mandatory intervention. II. DERSHOWITZ IIAS NOT SHOWN THAT THE COURT SHOULD ALLOW PERMISSIVE INTERVENTION UNDER RULE 24(B). 7 During the hearing on Reinhart's intervention motion, the Governm
. at 122 (Palm Beach Cty. Cir. Ct. Oct. 8, 2009). In short, all the key conspirators in Epstein's sexual trafficking ring who could be asked about Derhowitz's involvement took the Fifth.29 This Isjilence is . . . evidence of the most persuasive character." United States ex rd. Biloktanskyl. Tod. 263 U.S.
victim to this case: a young woman Jeffrey Epstein sexual abused when she was under age. On August 20, 2014, counsel sent a letter to U.S. Attorney Wilfredo Ferrer requesting the Govermnent's consent to a stipulated motion to simply add her into the case (as had been done earlier with Jane Doe No. 2). Counsel
IAL EFTA00225418 EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA Exhibit 41 Date Description 33 7/6/2007 Letter from Gerald l.efcourt and Alan Dershonia toJeffrey Sloman and Andrei Londe arguing against federal prosecution. 34 7/13/2007 Letter from Roy Black to Marie Villa' la with handwritten atto
to subpoenas requested by Lilly Ann Sanchez and possible resolution of case 7/6/2007 Jeffrey Sloman and Andrew Lourie Gerald B. Lefcourt and Alan Dershowitz Follow-up letter to 6/26/07 meeting including facts, law, and policy that should inform any decision made on how and whether to proceed 33 7/13/2
07 Plea Notification Letter B-2 11/23/2007 Unscheduled meeting between Jay Lefkowitz, Alan Dershowitz and Jeff Sloman. (Drop in by Lefkowitz and Dershowitz) 11/26/2007 Jason Richards PBSO D/S Harold Elliott Research re work release: PBSO Post Orders for the Work Release Program Privileged Confidenti
n 33 7/6/2007 Letter from Gerald l.efcourt and Alan Dershonia toJeffrey Sloman and Andrei Londe argu
ileged Confidential Page 50 of 51 Contains 6(e) Material EFTA00225477 EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 8/24/2011 Wilfredo Ferrer (U.S. Attorney, SDFL), Robert O'Neill (U.S. Attorney, MDFL), Benjamin Greenberg (FAUSA, SDFL), and Lee Bentley (FAUSA, MDFL) Richard Sud
d to subpoenas requested by Lilly Ann Sanchez and possible resolution of case 7/6/2007 Jeffrey Sloman and Andrew Laurie Gerald B. Lefcourt and Alan Dershowitz Follow-up letter to 6/26/07 meeting including facts, law, and policy that should inform any decision made on how and whether to proceed 7/13/2007
007 Plea Notification Letter B-, 11/23/2007 Unscheduled meeting between Jay Lefkowitz, Alan Dershowitz and Jeff Sloman. (Drop in by Lefkowitz and Dershowitz) 11 /26/2007 Jason Richards PBSO D/S Research re work release: PBSO Post Orders for the Work Release Program Harold Elliott Privileged Confident
lafatia, Junior Ortiz, Nesbitt Kuyrkendall, DEF: Alan Dershowitz, Roy Black, Gerald Lefcourt and Lilly
leged Confidential Page 50 of 51 Contain)) 6(u) Material EFTA00224992 EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 8/24/2011 Wilfredo Ferrer (U.S. Attorney, SDFL), Robert O'Neill (U.S. Attorney, MDFL), Benjamin Greenberg (FAUSA, l)1,1.), and Lee Bentley (FAUSA, MDFL) Richard S
litigation Investigative Privilege Acosta, and Alan Santiago regarding results of additional victim-
letters were reviewed by my office and Jay Lefkowitz and Roy Black before they went out."" 155. In 2010, Jane Doe I met with the new U.S. Attorney, Wilfredo Ferrer. She explained to him how the NPA had been concealed from her. Nothing ever came of the meeting, and Mr. Ferrer has continued to fight efforts by J
Entities connected to both Alan Dershowitz and Wilfredo Ferrer

Jeffrey Epstein
PERSONLeon Black
PERSON
Marc Rich
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Lesley Groff
PERSON
United States
LOCATION
George W. Bush
PERSON
Paul Cassell
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bill Clinton
PERSONMartin Weinberg
PERSONRobert D. Critton
PERSONMaria Farmer
PERSON
Joe Biden
PERSON
Virginia Giuffre
PERSON
Barry Diller
PERSON