Epstein Secrets

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

tached as Exhibit 24). Indeed, going a step further, on October 8, 2009, Epstein took the Fifth when asked whether he even knew Dershowitz was a 28 Mucinska also took the Fifth when asked about the involvement of Prince Andrew, Ghislaine Maxwell. and Jcan Luc Brunel. Id. at 37:3, 85:12, 85:13. 32 EFTA0

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.

tached as Exhibit 24). Indeed, going a step further, on October 8, 2009, Epstein took the Fifth when asked whether he even knew Dershowitz was a 38 Mucinska also took the Fifth when asked about the involvement of Prince Andrew, Ghislaine Maxwell, and Jean Luc Brunel. id. at 37:3, 85:12, 85:13. 32 EFTA0

F |S ao FBP WN F- 970 DO DN ODO OT BR W NY — ROUGH DRAFT TITLE ***ROUGH DRAFT TRANSCRIPT *** CASE NAME: BRADLEY J. EDWARDS and PAUL G. CASSELL vs. ALAN M. DERSHOWITZ WITNESS NAME: PAUL G. CASSELL DATE OF DEPOSITION: 10/16/15 This is an unedited, unproofread, | uncertified transcript for attorneys' information o

Oo O DN OO FF WwW NY =| NO RO PO PNP NM NO | S| S| HS SF S| S| S| S| S| non BP WO NO -|- ODO OO WDN OO OT BP WO NYO — Sweeder & Ross for Professor Dershowitz. Thereupon, PAUL G. CASSELL, having been first duly sworn, was examined and testified as follows: THE WITNESS: I do. DIRECT EXAMINATION BY MR. SI

ODO OO WDN OO OT BP WO NYO — Sweeder & Ross for Professor Dershowitz. Thereupon, PAUL G. CASSELL, having been first

NAME: BRADLEY J. EDWARDS and PAUL G. CASSELL vs. ALAN M. DERSHOWITZ WITNESS NAME: PAUL G. CASSELL DAT

ut what I discovered there was that when sarah Kellen was asked about Alan Dershowitz, she took the Fifth and she wasn't the only one. There was Miss Mucinska who also took the Fifth when asked questions about Alan Dershowitz. And then there was Marcin -- Miss Marcinkova who also took the Fifth. So what we

, 4:01 p.m. (Thereupon, a recess was taken.) THE VIDEOGRAPHER: We are back on the video record, 4:04 p.m. (Thereupon, Kenneth A. Sweder, Esquire, Alan M. Dershowitz and Carolyn Cohen left the proceedings.) ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 420 MR, SCAROLA: The record should reflect that Mr. and Mrs.

fy sealing these presumptively-public documents. L DERSHOWITZ HAS NOT JUSTIFIED SEALING ALLEGED DEFAMATORY RECO

e to speak up. MR. SCOTT: You're going to have to speak up a little bit more, Counsel. MR. INDYKE: Objection. This is Darren Indyke. Anything that Alan might have to say to that, to the extent they are covered under conversations with Jeffrey Epstein, privileged under attorney-client privileges as

UIRE DEPOSITION SOLUTIONS (954) 331-4400 mention Professor Dershowitz's name once. A. I said flight logs. And let's ta

about Alan Dershowitz, she took the Fifth, and there was -- she wasn't the only one. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 84 There was Miss Mucinska, who also took the Fifth when asked questions about Alan Dershowitz. And then there was Marcin -- Miss Marcinkova who also took the Fifth. So what w

t were the subject of the investigation. On June 26, 2007, Mr. Menchel, Mr. Lourie, AUSA Viliafafia, and FAUSA Sloman, and two FBI agents met with Alan Dershowitz, Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. During that meeting, Professor Dershowitz and other members of the defense team presented legal

a, and FAUSA Sloman, and two FBI agents met with Alan Dershowitz, Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. During that meeting, Professor Dershowitz and other members of the defense team presented legal and factual arguments against a federal indictment. Counsel for the defense also requested the

urt, and Lilly Ann Sanchez. During that meeting, Professor Dershowitz and other members of the defense team presented l

a, and FAUSA Sloman, and two FBI agents met with Alan Dershowitz, Roy Black, Gerald Lefcourt, and Lilly

ach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (223) On or about September 3, 2005, Defendants JEFFREY EPSTEIN and Mucinska," traveled from the U.S. Virgin Islands j • to Palm Beach County, Florida aboard th Gulfstream aircraft owned by Hyperion Air, Inc. (224) On or a

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

asiak Both initially asked for immunity. After speaking with Banasiak's attorney, r. anasi was satisfied with a standard Kastigar letter, but Ms. Mucinska's attorney was insistent on formal immunity, and as noted above, so was Individual #28. I don't believe that, prior to this investigation, I had ev

ith members of the defense team. USA Acosta had contact with Ken Starr, Jay Lefkowitz, Gerry Lefcourt, and Alan Dershowitz. FAUSA had contact with Alan Dershowitzi • Lefcourt, and Lilly . Criminal Chief had contact with Lilly and Gerry Lefcourt. There may have been other meetings that I was unaware of. I was

ck Goldberger twopersonal friends of ), and Alan Dershowitz. Det. stated that he and Chief were concerned

d Jack Goldberger twopersonal friends of ), and Alan Dershowitz. Det. stated that he and Chief were

with resolving the case against Epstein. In November and December 2006, subpoenas were served on two other Epstein employees — Janusz Banasiak and Mucinska. Both initially asked for immunity. After speaking with Banasiak's attorney, Mr. Banasiak was satisfied with I standard Kastigar letter, but Ms. Muc

ng but not limited to Harvard Law Professor Alan Dershowitz, former Independent Counsel and Solicitor Genera

cluding but not limited to Harvard Law Professor Alan Dershowitz, former Independent Counsel and Solic

fcourt, Esq. and Lilly Ann Sanchez, Esq., as well as numerous other nationally-renowned lawyers, including but not limited to Harvard Law Professor Alan Dershowitz, former Independent Counsel and Solicitor General of the United States Kenneth Starr, just to name a few, entered into a global resolution of state

2423(b) and 2. FORFEITURE 1 Upon conviction of the violation alleged in Count I of this indictment, the defendants, JEFFREY EPSTEIN, SARAH KELFN, Mucinska," and , shall forfeit to the United States any property, real or personal, which constitutes or is derived from proceeds traceable to the violation

Kellen 07/26/17 Page 2293 Public Records Request No.: 17-295 Dana Burns Tatiana 8/18 New Jersey Florida Jeffrey Epstein Adrian Mucinska Mr. Mucinska Mrs. Mucinska Adriana's Sister Nadia Marcinkova 8/22 TRAINING 8/22 Florida New Jersey Jeffrey Epstein Nadia Marcinkova 8/27 WINDSHIELD HE

evening hours. I received a package from Atty. Guy Fronstin, which was hand delivered at the police station. Within the package, was a letter from Alan Dershowitz, and two www.myspace.com profiles. The profiles were that of and MySpace.com is a social networking service that allows members to create uniq

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 ..o speak with law enfo