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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
the largest Ponzi schemes in American history. When Epstein met Hoffenberg in London in the 1980s, the latter was the charismatic, audacious head of the Towers Financial Corporation, a collection agency that was supposed to buy debts that people owed to hospitals, banks, and phone companies. But Hoffenberg began using company fun
ea. There was a later unsuccessful effort to add Virginia Roberts (Jane Doe 3) and another woman (Jane Doe
e Crime Victims', Rights Act by the U.S. of Justice's NPA with Epstein and his limited 2008 state plea. There was a later unsuccessful effort to add Virginia Roberts (Jane Doe 3) and another woman (Jane Doe 4) as plaintiffs to that case.(~1 The addition accused Alan Dershowitz of sexually abusing a minor, Jane D
Roberts (Jane Doe 3) and another woman (Jane Doe 4) as plaintiffs to that case.(~1 The addition accused Alan Dershowitz of sexually abusing a minor, Jane Doe 3, provided by EpsteinSW The allegations against Dershowitz were stricken by the judge and eliminated from the case because he said they were outside
to notify victims before they allowed him to plead guilty to only the two Florida offenses. The judge left open what the possible remedy could be.M1 Virginia Giuffre v. Epstein (2015) In a December 2014 Florida court filing by Bradley Edwards External video and p4.14 G. Cassell meant for inclusion in the Crime
stein's sex slave from nog to 2002, and had recruited other underage girls1451 Prince Andrew, Epstein, and Dershowitz all denied having had sex with Giuffre. Dershowitz took legal action over the allegations.(146-alcD4131 Giuffre filed a defamation suit against Dershowitz, EFTA00264301 P 9n07 LI/ i-
ealings in the Ward House at 457 Madison Avenue.l9~1 Steven Hoffenberg originally set up the offices for Epstein in 1987 when he was consulting for Tower Financial. IA Epstein used these offices until at least 2003. Around this time, Michael Wolff saw the financier in his office, which in the past were the offi
Dear Mr. Mannion: This is in reference to the Board's Order of July 24, 1990, approving the application of Avantor Financial Corporation, Norfolk, Virginia ("Applicant") to become a bank holding company by acquiring The Citizens and Southern Corporation, Atlanta, Georgia ("C&S"), and Sovran Financial Co
William W. Wiles, Secretary of the Board Dear Mr. Mannion: This is in reference to the Board's Order of July 24, 1990, approving the application of Avantor Financial Corporation, Norfolk, Virginia ("Applicant") to become a bank holding company by acquiring The Citizens and Southern Corporation, Atlanta, Georgia ("C&S"), and
to add (Jane Doe 3) and another woman (Jane Doe 4) as plaintiffs to that case.E'V The addition accused Alan Dershowitz of sexually abusing a minor, Jane Doe 3, provided by Epsteiniall The allegations against Dershowitz were stricken by the judge and eliminated from the case because he said they were outsid
dealings in the Ward House at 457 Madison Avenue.1231 Steven Hoffenbe originally set up the offices for Epstein in 1987 when he was consulting for Tower Financial. ni Epstein used these offices until at least 2003. Around this time, Michael Wolff saw the financier in his office, which in the past were the offi
ater (Jane Doe 3) and another woman (Jane Doe 4) as plaintiffs to that case 5132) The addition accused Alan Dershowitz of sexually abusing a minor, Jane Doe 3, provided by Epstein. all The allegations against Dershowitz were stricken by the judge and eliminated from the case because he said they were outsi
t!Steven Hoffenberg. They had been introduced through Douglas Leese, a defense contractor, and John Mitchell, the former U.S. Attorney General.(321 Towers Financial Corporation Epstein in 1980 Steven Hoffenberg hired Epstein in 1987, as a consultant for Towers Financial Corporation (unaffiliated with the company of the same name f
- 65il 1976-77 1985-86 1986-87 1989-90 1993.94 2002-03 2003-04 Award 1997 1998 1999 2000 2001 2002 2003 2004 2005 TOP 10 MOMENTS IN VIRGINIA ATHLETIC HISTORY 'Aso part of De CeebrattOn of the end Cl tie teentietn Century. the AtNetic Cspanrner1 pa together a 'Tod 1r bst-tho toa 10 atMcies
rgest Ponzi schemes in American history. When Epstein met Hotienbcre_ in Lon- don in the 1980s. the latter was the char- ismatic. audacious head of the Towers Financial Corporation. a collection agency that was supposed to buy debts that peo- ple owed to hospitals. banks, and phone companies. But Hoffenberg began using compan
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
argest Ponzi schemes in American history. When Epstein met Hoffenberg in Lon- don in the 1980s, the latter was the char- ismatic, audacious head of the Towers Financial Corporation. a collection agency that was supposed to buy debts that peo- ple owed to hospitals. banks, and phone companies. But Hoffenberg began using compan
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
amest Ponzi schemes in American history. When Epstein met Hoffenberg in Lon- don in the 1980s, the latter was the char- ismatic, audacious head of the Towers Financial Corporation. a collection agency that was supposed to buy debts that peo- ple owed to hospitals. banks, and phone companies. But HotTenbere began using compan
Entities connected to both Virginia Giuffre and Towers Financial

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
PERSONMaria Farmer
PERSON
Stephen Hawking
PERSON