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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
. These records prove incontrovertibly that I could not have been, and was not, where Roberts’ falsely claimed to have met me — a Caribbean Island, a New Mexico Ranch, a private jet, a Palm Beach mansion — during the relevant time period. I also called for an independent investigation by the former Director of th
s case. As one of innumerable examples, on March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you rub Jane Doe 3's vagina? A: Excuse me. I'd like to answer that question, as I would like to answer mostly every question you've asked me here today; however, upon ad
ess. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Epstein at Epstein's New Mexico Ranch. There was information indicating that Epstein had young girls at his ranch which, given the circumstances of the case, raised the reasonable infer
e 3 at or after the meeting; and (f) Any FBI 302's, witness statements, documents, correspondence, or similar information developed as a result of Jane Doe 3's contact with the FBI in and around April 2014 following up on her meeting in Sydney. Supplemental Discovery Request 5. As the Government is aware,
frey Epstein or his co-conspirators, including surveillance videos, photographs, or similar images taken in Epstein's Florida and New York mansions, New Mexico Ranch, or on Epstein's island in the U.S. Virgin Islands. Please also provide the same for Jane Doe 1, 2, and 4. If any of the videos, photographs or ima
e 3 at or after the meeting; and (f) Any FBI 302's, witness statements, documents, correspondence, or similar information developed as a result of Jane Doe 3's contact with the FBI in and around April 2014 following up on her meeting in Sydney. Supplemental Discovery Request 5. As the Government is aware,
frey Epstein or his co-conspirators, including surveillance videos, photographs, or similar images taken in Epstein's Florida and New York mansions, New Mexico Ranch, or on Epstein's island in the U.S. Virgin Islands. Please also provide the same for Jane Doe 1, 2, and 4. If any of the videos, photographs or ima
s case. As one of innumerable examples, on March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you rub Jane Doe 3's vagina? A: Excuse me. I'd like to answer that question, as I would like to answer mostly every question you've asked me here today; however, upon ad
ess. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Epstein at Epstein's New Mexico Ranch. There was information indicating that Epstein had young girls at his ranch which, given the circumstances of the case, raised the reasonable infer
s case. As one of innumerable examples, on March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you rub Jane Doe 3's vagina? A: Excuse me. I'd like to answer that question, as I would like to answer mostly every question you've asked me here today; however, upon ad
ess. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Epstein at Epstein's New Mexico Ranch. There was information indicating that Epstein had young girls at his ranch which, given the circumstances of the case, raised the reasonable infer
Second Renewed Motion for Leave to Assert Claim for Punitive Damages; Exhibit “D” — Edwards’ Notice of Filing of Transcript of Telephone Interview of Virginia Roberts in Support of Motion for Leave to Amended to Assert Punitive Damages; Exhibit “E” — Transcript of Deposition of Jeffrey Epstein dated January 25, 20
Page: HOUSE_OVERSIGHT_013305 →cases. Richardson was properly identified as a possible witness because Epstein’s personal pilot testified to Richardson joining Epstein at Epstein’s New Mexico Ranch. See deposition of Larry Morrison, October 6, 2009, at 167-169. There was information indicating that Epstein had young girls at his ranch which, giv
Page: HOUSE_OVERSIGHT_013368 →Entities connected to both Virginia Giuffre and New Mexico Ranch

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSON
United States
LOCATION
Alan Dershowitz
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Bill Clinton
PERSONJane Doe
PERSON
New York
LOCATIONthe Southern District
LOCATION
Marc Rich
PERSONMaria Farmer
PERSON
Kenneth Marra
PERSONFBI
ORGANIZATION
Scarlett Johansson
PERSON
Paul Cassell
PERSON