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egations against Alan Dershowitz made by Virginia Roberts Giuffre were false or unfounded. Neither the terms of set
Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 1 of 28 United States District Court Southern District of New York VIRGINIA L. GIUFFRE, Plaintiff, CASE NO: Vv. ALAN DERSHOWITZ, Defendant. COMPLAINT Boies Schiller Flexner LLP HOUSE_OVERSIGHT_017935 Case 1:19-cv-0337
TZ, Defendant. COMPLAINT Boies Schiller Flexner LLP HOUSE_OVERSIGHT_017935 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 2 of 28 Plaintiff, VIRGINIA L. GIUFFRE, formerly known as Virginia Roberts (“Roberts”), for her Complaint against Defendant, Alan Dershowitz (“Dershowitz”) avers upon personal knowledge as
ler Flexner LLP HOUSE_OVERSIGHT_017935 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 2 of 28 Plaintiff, VIRGINIA L. GIUFFRE, formerly known as Virginia Roberts (“Roberts”), for her Complaint against Defendant, Alan Dershowitz (“Dershowitz”) avers upon personal knowledge as to her own acts and status and upon
conclude based upon Dershowitz’s statements that Bradley Edwards and Paul Cassell had determined that the allegations against Alan Dershowitz made by Virginia Roberts Giuffre were false or unfounded. Neither the terms of settlement nor the agreed upon joint public statement issued as part of the settlement support any such
Jeffrey Epstein manipulated the system | Miami Herald Page 5 of 17 Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 6 of 18 Virginia Roberts, now Giuffre, says she was 16 and working as a locker room attendant at Donald Trump’s Mar-a-Lago resort when she was approached by Ghislaine Maxwell, Jeffrey Eps
mmediate family that I send drafts to is Jeffrey.” Real-estate developer and philanthropist Marshall Rose, who has worked with Epstein on projects in New Albany, Ohio, for Wexner, says, “He digests and decodes the information very rapidly, which is to me terrific because we have shorter meetings.” Also on th
99, when she was a minor, and grooming her to provide sexual services for Epstein. Zs A 2018 exposé by Julie K. Brown in the Miami Herald revealed Jane Doe 3 to be yi_Tinia Giuffre, who was previously known as Virginia Roberts. Giuffre met Maxwell at Donald Trump's Mar-a-Lago Club in Palm Beach, Florida,
ervices for Epstein. Zs A 2018 exposé by Julie K. Brown in the Miami Herald revealed Jane Doe 3 to be yi_Tinia Giuffre, who was previously known as Virginia Roberts. Giuffre met Maxwell at Donald Trump's Mar-a-Lago Club in Palm Beach, Florida, when Giuffre was a 16- year-old spa attendant.(2-A She asserted that
n. Zs A 2018 exposé by Julie K. Brown in the Miami Herald revealed Jane Doe 3 to be yi_Tinia Giuffre, who was previously known as Virginia Roberts. Giuffre met Maxwell at Donald Trump's Mar-a-Lago Club in Palm Beach, Florida, when Giuffre was a 16- year-old spa attendant.(2-A She asserted that Maxwell h
, had been sexually assaulted by Epstein and Maxwell in separate locations in 1996. Farmer's affidavit was filed in support of a defamation suit by Virginia Giuffre against Alan Dershowitz.i641 According to the affidavit, Farmer had met Maxwell and Epstein at a New York art gallery reception in 1995. The affidav
be yi_Tinia Giuffre, who was previously known as Virginia Roberts. Giuffre met Maxwell at Donald Trump's M
irector of the Weimer Foundation and Wexner Heritage Foundation. He was also the president of Wexner's Property, which developed part of the town of New Albany outside Columbus, Ohio, where Wexner lived. Epstein made millions in fees by managing Wexner's financial affairs. Although never employed by L Bran
tact information of material witnesses and additional victims 41263(127] Civil cases Jane Does v. Epstein (2008) On February 6, 2008, an anonymous Virginia woman, known as Jane Doe No. 2, filed a $50-million civil lawsuit 121 in federal court against Epstein, saying that when she was a 16- year-old mi
o add (Jane Doe 3) and another woman (Jane Doe 4) as plaintiffs to that case.inal The addition accused Alan Dershowitz of sexually abusing a minor, Jane Doe 3, provided by Epstein ['331 The allegations against Dershowitz were stricken by the judge and eliminated from the case because he said they were outs
irector of the Wexner Foundation and Wexner Heritage Foundation. He was also the president of Wexner's Property, which developed part of the town of New Albany outside Columbus, Ohio, where Wexner lived. Epstein made millions in fees by managing Wexner's financial affairs. Although never employed by L Bran
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tigations. 104749084A 59 358 El Brillo Way Palm Beach, FL 33480-4730 457 Madison Ave Fl 4TH New York, NY 10022-6843 6525 W Campus Oval Ste 10 New Albany, OH 43054-8830 515 Abigail Plantation Rd Albany, GA 31721-8114 8000 Walton Pkwy Ste 100 New Albany, OH 43054-7075 EFTA01482068 Address New Yo
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. Epstein runs a lean operation, and those close to him say that his actual staff— based here in Manhattan at the Villard House (home to Le Cirque); New Albany, Ohio; and St. Thomas, where he reincorporated his company seven years ago (now called Financial Trust Co.) — numbers around 150 and is purely admin
the second time in less than two weeks Wednesday, this time by another teenager who claims she was sexually abused at his mansion. The 16-year-old Virginia girl is represented by the same attorney who filed a $50 million federal lawsuit in late January against Epstein, 55. This lawsuit seeks similar d
diate family that I send drafts to is Jef- frey." Real-estate developer and philanthropist Marshall Rose, who has worked with Epstein on projects in New Albany, Ohio, for Wexner, says, "He digests and decodes the information very rapidly, which is to me terrific because we have shorter meetings." Also on
mes Richardson & Sons, Ltd., Winnipeg Rozanne L. Ridgeway, Director, Citicorp. Charles S. Robb, Member of United States Senate; former Governor of Virginia Gianfelice Rocca, Chairman, Techint Group of Companies, Milan David Rockefeller, Founder and Honorary Chairman, Trilateral Commission, Chase Manha
iate family that I send drafts to is Jeffrey." Real-estate developer and philanthropist Marshall Rose. who has worked with Epstein on projects in New Albany. Ohio, for Wexner, says. "He digests and decodes the information very rapidly, which is to me terrific because we have shorter meetings." Also on
Entities connected to both Virginia Giuffre and New Albany

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
George W. Bush
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Alan Dershowitz
PERSONLeon Black
PERSON
Stephen Hawking
PERSON
Bill Clinton
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
New York
LOCATION
Julie K. Brown
PERSON
Joe Biden
PERSONthe Southern District
LOCATION
Marc Rich
PERSON
Prince Charles
PERSONMaria Farmer
PERSON