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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
rance regulators off, the $1.8 million was reported as being safely invested in a money-market account. United Fire’s former chief financial officer Daniel Payton confirms part of Hoffenberg’s account. He says he recalls making one or two telephone calls to Epstein (at Hoffenberg’s direction) about the missing
nd out later that he had sold those assets ... leveraged them ... [and] used some margin account to take some positions in... Emery and Pan Am,” says Payton. Epstein’s extraordinary creativity was, according to Hoffenberg, responsible for the purchase by the insurance companies of a $500,000 bond, with n
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later that he had sold those assets ... leveraged them .. . [and) used some mar- gin account to take some positions in .. . Emery and Pan Am." says Payton. Epstein's extraordinary creativity was. ac- cording to HotTenberg. responsible for the purchase by the insurance companies of a $500.000 bond, wi
ce regula- tors off the S1.8 million was reported as being safely invested in a money-market account. United Fire's former chief financial officer Daniel Payton confirms part of Hoffenberg's account. He says he recalls making one or two telephone calls to Epstein tat Holten- berg's direction) about the miss
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
ance regulators off, the $1.8 million was reported as being safely invested in a money-market account. United Fire's former chief financial officer Daniel Payton confirms part of Hoffenberg's account. He says he recalls making one or two telephone calls to Epstein (at Hoffenberg's direction) about the missin
out later that he had sold those assets ... leveraged them ... (and) used some margin account to take some positions in ... Emery and Pan Am," says Payton. Epstein's extraordinary creativity was, according to Hoffenberg, responsible for the purchase by the insurance companies of a $500,000 bond, with
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
t later that he had sold those assets ... leveraged them ... [and] used some mar- gin account to take some positions in ... Emery and Pan Am." says Payton. Epstein's extraordinary creativity was, ac- cording to HotTenberg, responsible for the purchase by the insurance companies of a $500.000 bond, wi
e regula- tors otT. the S1.8 million was reported as being safely invested in a money-market account. United Fire's former chief financial officer Daniel Payton confirms part of Hoffenberg's account. He says he recalls making one or two telephone calls to Epstein (at Hoffen- berg's direction) about the miss
Entities connected to both Virginia Giuffre and Daniel Payton

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
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
LOCATION
Julie K. Brown
PERSON
Joe Biden
PERSONthe Southern District
LOCATION
Marc Rich
PERSON
Prince Charles
PERSON
Stephen Hawking
PERSONMaria Farmer
PERSON