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That investigation was opened more than two and a half years after the last known contact between any lawyer associated with any civil counsel for Giuffre and, in any event, was initially focused on Epstein, not this defendant. As detailed above, the USAO-SDNY opened the instant investigation in late
.F.L). See generally Doe No. 1. v. United States, 749 F.3d 999, 1002 (11th Cir. 2014) (describing the background of the suit). On December 30, 2014, Virginia Roberts Giuffre moved to join the petition, alleging that the USAO-SDFL had also violated her CVRA rights. See Doe, No. 08 Civ. 80736, Dkt. No. 279.45 the9 "one of
t persons, people under the age of 18. A. I looked for people or tried to find people to fill professional jobs in professional situations. Q. So Virginia Roberts was under the age of 18, correct? A. I think we've established that Virginia was 17. Q. Is she the -- sorry, go ahead. Is she the only individual t
e to fill professional jobs in professional situations. Q. So Virginia Roberts was under the age of 18, correct? A. I think we've established that Virginia was 17. Q. Is she the -- sorry, go ahead. Is she the only individual that you met for purposes of hiring someone for Jeffrey that was under the ag
No. 542-4). Giuffre has since self-identified as Jane Doe #3. (See id., Dkt. No. 23 n.2). 117 EFTA00095209
se questions-for instance that Epstein in fact had a scheme to recruit underaged girls for sexual massages—would have been corroborative of some of Giuffre's claims. Second, had the defendant honestly answered the deposition questions, Giuffre could have located other victims or witnesses who may have cor
sed to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, 13 Cr. 128 (MA) (HKS), 2014 WL 1838255, at *1, 4-6 (W.D.N.Y. May 8, 2014) (denying motion to dismiss indictment charging enticement of a minor, in
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
. Several victims told police that she was involved in orgies with Epstein and underage girls. Ross, Groff and Kellen, now known by her married name, Vickers, were schedulers who arranged his underage sex sessions, according to the FBI and police. Marcinkova and Kellen, through their attorneys, declined t
that standard." (Id. at 7) (emphasis in original). 8. Unsealing of Maxwell's Depositions Three months after Chief Judge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain liti
.F.L). See generally Doe No. 1. v. United States, 749 F.3d 999, 1002 (11th Cir. 2014) (describing the background of the suit). On December 30, 2014, Virginia Roberts Giuffre moved to join the petition, alleging that the USAO-SDFL had also violated her CVRA rights. See Doe, No. 08 Civ. 80736, Dkt. No. 279.45 In her motion
t persons, people under the age of 18. A. I looked for people or tried to find people to fill professional jobs in professional situations. Q. So Virginia Roberts was under the age of 18, correct? A. I think we've established that Virginia was 17. Q. Is she the -- sorry, go ahead. Is she the only individual t
e to fill professional jobs in professional situations. Q. So Virginia Roberts was under the age of 18, correct? A. I think we've established that Virginia was 17. Q. Is she the -- sorry, go ahead. Is she the only individual that you met for purposes of hiring someone for Jeffrey that was under the ag
se questions-for instance that Epstein in fact had a scheme to recruit underaged girls for sexual massages—would have been corroborative of some of Giuffre's claims. Second, had the defendant honestly answered the deposition questions, Giuffre could have located other victims or witnesses who may have cor
sed to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 154 EFTA00077786 1838255, at *1, 4-6 (W.D.N.Y. May 8, 2014) (denying motion to dismiss indictment charging
that standard." (Id. at 7) (emphasis in original). 8. Unsealing of Maxwell's Depositions Three months after Chief Judge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain liti
.F.L). See generally Doe No. 1. v. United States, 749 F.3d 999, 1002 (11th Cir. 2014) (describing the background of the suit). On December 30, 2014, Virginia Roberts Giuffre moved to join the petition, alleging that the USAO-SDFL had also violated her CVRA rights. See Doe, No. 08 Civ. 80736, Dkt. No. 279.45 In her motion
t persons, people under the age of 18. A. I looked for people or tried to find people to fill professional jobs in professional situations. Q. So Virginia Roberts was under the age of 18, correct? A. I think we've established that Virginia was 17. Q. Is she the -- sorry, go ahead. Is she the only individual t
e to fill professional jobs in professional situations. Q. So Virginia Roberts was under the age of 18, correct? A. I think we've established that Virginia was 17. Q. Is she the -- sorry, go ahead. Is she the only individual that you met for purposes of hiring someone for Jeffrey that was under the ag
se questions-for instance that Epstein in fact had a scheme to recruit underaged girls for sexual massages—would have been corroborative of some of Giuffre's claims. Second, had the defendant honestly answered the deposition questions, Giuffre could have located other victims or witnesses who may have cor
sed to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 154 EFTA00039601 1838255, at *1, 4-6 (W.D.N.Y. May 8, 2014) (denying motion to dismiss indictment charging
ocument 161-4 Filed 05/25/16 Page 2 of 6 VA?. 24. 2016 4:50PM NO. 480 P. 1 UNITED STATES DISTRICT COURT for the Southern District of New York Virginia L. Giuffre, Plaintiff v. Ghislaine Maxwell, Defendant Civil Action No. 15-CV-07433-RWS AFFIDAVIT Doug/as G. Mercer, being duly sworn deposes and states: 1
r the Southern District of New York Virginia L. Giuffre, Plaintiff v. Ghislaine Maxwell, Defendant Civ
CT COURT for the Southern District of New York Virginia L. Giuffre, Plaintiff v. Ghislaine Maxwell, Def
e Street, New York, New York to attempt to serve a subpoena on Sarah Kellen-Vickers. Investigator Murphy was advised by a doorman that Sarah Kellen- Vickers resides at the location, in Penthouse 2, but had not been staying at the location due to construction. 4. On Tuesday, April 26t, 2016 at 1:44 pm, In
. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government obtained such materials through a judicially approv
inner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards p
oies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 wi
nited States v. Valentine, 820 F.2d 565 (2d Cir. 1987) 156, 157, 158 United States v. Valona, 834 F.2d 1334 (7th Cir. 1987) 66 United States v. Vickers, 708 F. App'x 732 (2d Cir. 2017) 256 United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 1838255 (W.D.N.Y. May 8, 2014) passim United
. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government obtained such materials through a judicially approv
inner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards p
oies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 wi
nited States v. Valentine, 820 F.2d 565 (2d Cir. 1987) 156, 157, 158 United States v. Valona, 834 F.2d 1334 (7th Cir. 1987) 66 United States v. Vickers, 708 F. App'x 732 (2d Cir. 2017) 256 United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 1838255 (W.D.N.Y. May 8, 2014) passim United
side, the civil matters were in completely different procedural postures, which implicate different concerns regarding a pending criminal case. The Giuffre v. Maxwell litigation was settled and complete well before the Government even opened its investigation in this case. By contrast, the Doe v. Indyk
inner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards p
oies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 wi
23 United States v. Valentine, 820 F.2d 565 (2d Cir. 1987) 107, 108 United States v. Valona, 834 F.2d 1334 (7th Cir. 1987) 45 United States v. Vickers, 708 F. App'x 732 (2d Cir. 2017) 168 United States v. Vickers, No. 13-CR-I28-A, 2014 WL 1838255 (W.D.N.Y. May 8, 2014) 37, 38, 39, 154 United S
Jaine Maxwell Overall property manager for all of Epstein's property's. Was observed by a property manager Alessi in Palm Beach to have recruited Virginia Roberts to massage Epstein. Roberts eventually recruits multiple girls that spider web into that structure of the original Palm Beach investigation. Aless
manager Alessi in Palm Beach to have recruited Virginia Roberts to massage Epstein. Roberts eventually r
girls but at least 10 girls state she is the direct point of contact for scheduling his massage appointments in West Palm Beach and New York City. Vickers was also in charge of greeting the girls at his FL and NY residences, making them feel comfortable and welcome, offering them food, bringing them
Microsoft Word - Exhibit K.docx
. Several victims told police that she was involved in orgies with Epstein and underage girls. Ross, Groff and Kellen, now known by her married name, Vickers, were schedulers who arranged his underage sex sessions, according to the FBI and police. Marcinkova and Kellen, through their attorneys, declined t
Page: HOUSE_OVERSIGHT_017802 →d Scarola, a former state prosecutor. Florida and beyond Few people had as much insight into Epstein’s lifestyle — and its international reach — as Virginia Roberts. By age 16, Roberts had lived a life that was beyond that of most high school girls. At 11, she says, she was sexually molested by a family friend.
Page: HOUSE_OVERSIGHT_017804 →secutor. Florida and beyond Few people had as much insight into Epstein’s lifestyle — and its international reach — as Virginia Roberts. By age 16, Roberts had lived a life that was beyond that of most high school girls. At 11, she says, she was sexually molested by a family friend. At 12, she was smoki
Page: HOUSE_OVERSIGHT_017804 →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
Page: HOUSE_OVERSIGHT_017805 →Entities connected to both Virginia Giuffre and Vickers

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
PERSON
Bradley Edwards
PERSON
Bill Clinton
PERSONJane Doe
PERSON
Julie K. Brown
PERSON
New York
LOCATION
Joe Biden
PERSONthe Southern District
LOCATION
Marc Rich
PERSONMaria Farmer
PERSON
Stephen Hawking
PERSON
Colorado
LOCATIONFBI
ORGANIZATION