Epstein Secrets

LAINTIFF ALAN DERSHOWITZ’S MOTION FOR CLARIFICATION OF CONFIDENTIALITY ORDER OR RELIEF FROM THAT ORDER The transcript of the deposition of non-party Virginia Roberts Giuffre (“Roberts”) is currently under seal as a result of the January 12, 2016 Confidentiality Order in this action. Dershowitz seeks clarification that the

ranscript of the deposition of non-party Virginia Roberts Giuffre (“Roberts”) is currently under seal as a result o

MOTION FOR CLARIFICATION OF CONFIDENTIALITY ORDER OR RELIEF FROM THAT ORDER The transcript of the deposition of non-party Virginia Roberts Giuffre (“Roberts”) is currently under seal as a result of the January 12, 2016 Confidentiality Order in this action. Dershowitz seeks clarification that the Confident

ts. It is without question that Giuffre was sexually abused as ' Jane Doe No. 3 is Virginia Roberts Giuffre, and will hereinafter be referred to as “Guiuffre.” > See Exhibit 1, CNN International, New Day, January 6, 2015. See also Exhibit 2, Australian Broadcasting System (ABC), January 6, 2015. “My goal

dent Bill Clinton to Little St. James Island and the US Virgin Islands” (Attachment A). The basis of the above-described FOIA request was a claim by Virginia Roberts, in court papers filed in early 2015 in Florida federal court, that she and former President Clinton were on Little St. James Island at the same time

uis J. Freeh Mobile: 202.215.8321 January 22, 2016 RE: FOIA Request Dear Professor Dershowitz: As you know, on April 6, 2015, a request was made to the United States Secret Service under the federal Freedom of Information Act (FOIA; 5 U.S.C. Sec. 552), relating to the period 1/01/01 to 1/1/03, for "any and all shift logs, travel

conducted by a Good Morning America co-host, of a woman known in court papers as Jane Doe 3.' I write to put you on notice that ABC's publication of Jane Doe 3's accusations is grossly negligent or worse. The accusations, many of which relate to my client, relate to alleged conduct that occurred approximatel

e. Upon inquiry, I am certain that you would receive similar denials from Mr. and Mrs. Gore either directly or by or through their counsel Mr. Boies. Jane Doe 3's fabrication of these claims against respected former officials undermines completely the trustworthiness of each and every one of her remaining alleg

Neither former President Clinton nor former Vice-President Gore and his wife have ever been present at Mr. Epstein's Virgin Island home. A review of United States Secret Service records, obtainable through a Freedom of Information Request would prove the falsity of the claim. Virgin Island government records would provide fur

r, uncorroborated allegations with extreme caution. At the very least, ABC has an obligation to verify—with independent evidence—the truthfulness of Jane Doe 3's claims. Merely declining to air those portions of her interview that relate to President Clinton and Vice-President Gore is insufficient. If ABC ha

legations involving students at the University of Virginia, ABC would proceed with similar, uncorroborated

either former President Clinton nor former Vice-President Gore and his wife have ever been present at Mr. Epstein's Virgin Island home. A review of United States Secret Service records, obtainable through a Freedom of Information Request would prove the falsity of the claim. Virgin Island government records would provide f

his became important because the video in question was copied over the day after the police were served with a subpoena). I testified in a Richmond Virginia Murder case where the prosecutor was about to make plea agreements for 5 years, but after recovering the video of the murders they resulted in judgm

ometimes need the DVR in question) I have collaborated with other law enforcement partners within the federal government and keep contacts with the United States Secret Service, Department of Health and Human Services, and the Office of the Inspector General. (contacts I made through the Scientific Working Group — Digital E

his became important because the video in question was copied over the day after the police were served with a subpoena). I testified in a Richmond Virginia Murder case where the prosecutor was about to make plea agreements for 5 years, but after recovering the video of the murders they resulted in judgm

ometimes need the DVR in question) I have collaborated with other law enforcement partners within the federal government and keep contacts with the United States Secret Service, Department of Health and Human Services, and the Office of the Inspector General. (contacts I made through the Scientific Working Group — Digital E

his became important because the video in question was copied over the day after the police were served with a subpoena). I testified in a Richmond Virginia Murder case where the prosecutor was about to make plea agreements for 5 years, but after recovering the video of the murders they resulted in judgm

he DVR in question) EFTA00174658 I have collaborated with other law enforcement partners within the federal government and keep contacts with the United States Secret Service, Department of Health and Human Services, and the Office of the Inspector General. (contacts I made through the Scientific Working Group — Digital E

became important because the video in question was copied over the day after the police were served with a subpoena). Mr. testified in a Richmond Virginia Murder case where the prosecutor was about to reach a plea agreement for 5 years, after recovering the video of the murders they resulted in judgmen

ometimes need the DVR in question) I have collaborated with other law enforcement partners within the federal government and keep contacts with the United States Secret Service, Department of Health and Human Services, and the Office of the Inspector General. (contacts I made through the Scientific Working Group — Digital E

entist of the Year" by the Mid-Atlantic Association of Forensic Scientists ■ Recipient of the United States Attorney's Office Eastern District of Virginia "Law Enforcement Public Service Award" ■ Recipient of the FBI Director's Award of Excellence for Outstanding Scientific Advancement EFTA00073053

USA Director of Research Innovation Florida International University — Global Forensic and Justice Center United States Department of Justice and United States Secret Service (RET) Education: University of Alabama at Birmingham (1994) Birmingham, Alabama USA Master of Science in Forensic Science (M.S.F.S.) University