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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
oot Camp, LLC, 813 F.Supp.2d 489, 550 (S.D.N.Y. 2011) 22 Sexier v. Warm/lash, P.C. v. Margrabe, 828 N.Y.S.2d 315 (1st Dep't 2007) 14 Shenkman v. O'Malley, 157 N.Y.S.2d 290, 297-98 (V' Dep't 1956) 8 Siegel v. Metropolitan Life Ins. Co., 32 N.Y.S.2d 658 (15` Dep't 1942) 8 Thai v. Cayre Group, Ltd., 7
ive than any which I, or the prosecutors in my office, had previously encountered. Mr. Epstein hired an army of legal superstars: Harvard Professor Alan Dershowitz, former Judge and then Pepperdine Law Dean Kenneth Stan•, former Deputy Assistant to the President and then Kirkland & Ellis Partner Jay Lefkowitz,
this case. He was aware of the tactics of the defense, and he called to praise our prosecutors for holding firm against the likes of Messrs. Black, Dershowitz, Leflcowitz and Starr. It was a proud moment. I also received calls or communications from Messrs. Dershowitz, Lefkowitz and Stan•. I had known all
d an army of legal superstars: Harvard Professor Alan Dershowitz, former Judge and then Pepperdine Law
'indirect injuries, that is injuries sustained not as a direct result of predicate acts . . . will not allow recovery under Florida RICO." (quoting O'Malley v. St. Thomas Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-in
e station. Within the package, was a letter from Alan Der were that of wo profiles. The profiles an
ersonal profiles online in order to find and communicate with old and new friends. This package was in response to a previous meeting in which Mr. Dershowitz called to assist in the investigation in providing any additional witnesses such as house employees who have been reluctant to speak with law enfor
fore the Grand Jury to seek an indictment against Jeffrey Epstein. Due to subsequent meetings with the State Attorney's Office and Defense Attorney Alan Dershowitz the Grand Jury was postponed until a later time. Dershowitz had provided a package of material on the main victims in this case in which they appea
indirect injuries, that is injuries sustained not as a direct result of predicate acts . . . will not allow recovery under Florida RICO."' (quoting O'Malley v. St. Thomas Univ., Inc., 599 M. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-inj
fore the Grand Jury to seek an indictment against Jeffrey Epstein. Due to subsequent meetings with the State Attorney's Office and Defense Attorney Alan Dershowitz the Grand Jury was postponed until a later time. Dershowitz had provided a package of material on the main victims in this case in which they appea
. Due to subsequent meetings with the State Attorney's Office and Defense Attorney Alan Dershowitz the Grand Jury was postponed until a later time. Dershowitz had provided a package of material on the main victims in this case in which they appear on myspace.com and speak about alcohol use and some mariju
the State Attorney's Office and Defense Attorney Alan Dershowitz the Grand Jury was postponed until a
'indirect injuries, that is injuries sustained not as a direct result of predicate acts . . wit! not allow recovery under Florida RICO."' (quoting O'Malley v. St. Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-injury
April ., 2009: Theodore J. Leopold, Esq. Jack Alan Goldberger, Esq. Spencer T. Kuvin, Esq. Atterbu
224 (3d Cir. 2007). 8. Petrol LTD v. Radulovic, 764 So.2d 878 (Fla. 4th DCA 2000). DIRECT INJURIES MUST BE SUSTAINED TO PROPERLY ALLEGE RICO 1. O'Malley v. St. Thomas Univ., Inc. 599 So.2d 999, 1000 (Fla. 3d (DCA 1992). 2. Palmus Y Bambu, S.A. v. E.I. Dupont De Nemours & Company, 881 So.2d 565 (Fl
[email protected] Co-counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss,
lorida looks to Federal authority regarding the interpretation and application of its Acts, citing 18 U.S.C. 1961, et seq. and Fla. Stat. 772.104); O'Malley v. St.. Thomas Univ.. Inc., 599 So.2d 999, 1000 (Ha. 3d DCA 1992)("Since Florida Rico is patterned after Federal RICO. . . .[f]ederal decisions sho
eopold- Kuvin, P.A., Counsel for Plaintiff; Jack Alan Goldberger, Esq., Atterbury Goldberger & Weiss,
224 (3d Cir. 2007). 8. Petrol LTD v. Radulovic, 764 So.2d 878 (Fla. 4th DCA 2000). DIRECT INJURIES MUST BE SUSTAINED TO PROPERLY ALLEGE RICO 1. O'Malley v. St. Thomas Univ., Inc. 599 So.2d 999, 1000 (Fla. 3d (DCA 1992). 2. Palmus Y Bambu, S.A. v. E.I. Dupont De Nemours & Company, 881 So.2d 565 (Fl
ke City, UT 84112 Co-counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P
lorida looks to Federal authority regarding the interpretation and application of its Acts, citing 18 U.S.C. 1961, et seq. and Fla. Stat. 772.104); O'Malley v, St,„ Thomas Univ.. Inc., 599 So.2d 999, 1000 (FM. 3d DCA 1992)flince Florida Rico is patterned after Federal RICO. .. .[f]ederal decisions should
FBI) <[email protected]>; Alexander, Lawrence R. (CD) (FBI) <[email protected]>; Alfonso, Paula (NSB) (FBI) <[email protected]>; Allan, Aaron E. (BF) (FBI) <[email protected]>; Allebach, Lisa M. (MM) (FBI) <[email protected]>; AL-SQUAD11-d <[email protected]>; AL- SQU
Y-SSA_CD <[email protected]>; OC_SQ14 <[email protected]>; Oliver, Amanda (CTD) (FBI) <[email protected]>; OM_Intel2 <[email protected]>; O'Malley, Margaret Noreen (OGC) (FBI) <[email protected]>; OM-Squad8 <[email protected]>; O'Reilly, Lisa C. (CG) (FBI) <[email protected]>; Ort
Entities connected to both Alan Dershowitz and O'Malley

Jeffrey Epstein
PERSONLeon Black
PERSON
Marc Rich
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSON
Paul Cassell
PERSON
Richard Kahn
PERSONJane Doe
PERSON
Kenneth Marra
PERSONDarren Indyke
PERSON
Donald Trump
PERSONMartin Weinberg
PERSONRobert D. Critton
PERSONMaria Farmer
PERSON
Joe Biden
PERSON
Virginia Giuffre
PERSON