Epstein Secrets

d acted in any way inappropriately with regard to Virginia [Giuffre], that I ever touched her, that I ever met her, t

al abuse Allegations. Rather, these records are an important part of this case, since they not only support the conclusion that Dershowitz abused Ms. Giuffre, but also indisputably establish Edwards and Cassell’s strong basis for filing the allegations on her behalf. Moreover, contrary to assertions made i

uded that “at this juncture in the proceedings” details about the sexual abuse she had suffered was unnecessary to making a determination “of whether Jane Doe 3 and Jane Doe 4 should be permitted to join [the other victims’] claim that the Government violated their rights under the CVRA. The factual details r

at question. I am aware that never before 2014, end of December, was it ever, ever alleged that I had acted in any way inappropriately with regard to Virginia [Giuffre], that I ever touched her, that I ever met her, that Ihad ever been with her. I was completely aware ofthat. There had never been any allega

body had taken the photograph. Given the surrounding circumstances, I thought perhaps Mr. Epstein had taken the photograph. So that would have shown Virginia Roberts's sexual abuse was not confined just to Florida, not confined to the New York mansion; it would have -- it would have presumably continued into London

owerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was former Harvard

aware that never, until the lies were put in a legal pleading at the end of December 2014, it was never alleged that I had any sexual contact with Virginia Roberts. I know that it was alleged that I was a 11:38:46 witness to Jeffrey Epstein's alleged abuse and that was false. I was never a witness to any of

EY, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33402-3626 BY: JACK SCAROLA, ESQ. [email protected] On behalf of Defendant: COLE, SCOTT & KISSANE, P.A. Dadeland Centre H - Suite 1400 9150 South Dadeland Boulevard Miami, Florida 33156 BY: THOMAS EMERSON SCOTT, JR., ESQ. [email protected]

fendant. PLAINTIFFS AND NON-PARTY CASE. NO. CACE 15-000072 NOTICE REGARDING THE PARTIES' JOINT SITPULATION OF DISMISSAL Plaintiffs and Non-Party Virginia Giuffre, by and through undersigned counsel, hereby provide the Court with Notice that while the Plaintiff and Defendant submitted a Joint Stipulation of D

N OF DISMISSAL Plaintiffs and Non-Party Virginia Giuffre, by and through undersigned counsel, hereby prov

ITPULATION OF DISMISSAL Plaintiffs and Non-Party Virginia Giuffre, by and through undersigned counsel, here

/Sigrid S. McCawley Sigrid S. McCawley " Thomas E. Scott I hgrna,.scott'd c,klecia I cop; Steven R. Safra Ste_‘ en safraw csk Icgal coin COLE, SCOTT & KISSANE. P.A. 9150 S. Dadeland Blvd., Suite 1400 Miami, Florida 33156 Iteles,pail ,:aiklei2,11 ni zi>, 4 Snell. csklcual ckun 4S. Counsel Ibr Alan D

curred, and the running of the limitations period, if applicable, did not begin until she returned to Florida about 16 months ago, in October 2013. Jane Doe 3 has therefore filed her action within the three-year time period specified by § 2401(a) for persons returning to this country from beyond the seas.

ach, Florida, to Sydney, Australia, is 9,364 miles — and that travel between the two points would involve passing over the Pacific Ocean. Therefore, Jane Doe 3 was plainly "beyond the seas" when the events giving rise to her claim occurred, and the running of the limitations period, if applicable, did not b

on February 6, 2015, on the following using the Court's CM/ECF system: Attorneys for the Government Thomas Scott [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre II Kendall Coffey Gabriel Groisman Groisman Benjamin H. Brodsky COFFEY BURLINGTON, P.L. Attorneys for Alan Dershowitz /

ening discovery (See Dkt 310 at 5), then the civil SOL should apply. The criminal SOL has nothing to do with the CVRA. Under the Petitioners theory, Jane Doe 3 could wait until she is 60 or 70 years old to bring the CVRA complaint (Dkt 311 at 9). 2 EFTA00188610 EFTA00188611 8. Jane Doe 3's residing i

ners theory, Jane Doe 3 could wait until she is 60 or 70 years old to bring the CVRA complaint (Dkt 311 at 9). 2 EFTA00188610 EFTA00188611 8. Jane Doe 3's residing in did not prevent her from joining the CVRA case. The case was widely reported in the media as was the NPA (DKT 290 at 7 fn 7 where Govt

500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: 561 820-8777 Attorneys for the Government Thomas Scott ar COLE. SCOTT & KISSANE, P.A. -and- Kendall Coffey Gabriel Groisman Benjamin H. Brodsk n om COFFEY BURLINGTON. P.L. Attorneys for Alan Dershowit: /s/ Bradley J. Edward

s filed a pleading in the Federal Action titled "Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for

etion for the Court to deny Dershowitz's request. 15 EFTA00613405 Respectfully submitted, s/ Thomas E. Scott Steven R. Safra, FBN 057028 COLE, SCOTT & KISSANE, P.A. Richard A. Simpson (pro hac vice) Ma E. Bo 'a ro hac vice) Ashle E. Filer ro hac vice) Nicole Audet Richardson (pro hac vice) Counsel for

ere it would have been possible to have sex with Jane Doe #3."). In media statements, Dershowitz has repeatedl

E-mail: [email protected] E-mail: ann.marie.c.villafana@usdojdzov Attorneys for the Government Thomas Scott [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre H 9150 South Dadeland Boulevard, Suite 1400 Miami, Florida 33156 Telephone: (305) 350-5300 Facsimile: (305) 373-2294 -and

the Government's alleged failure to confer with Jane Doe #3 before entering the NPA could not rationally be

lief that the Court deems just and proper under these unfortunate circumstances. Respectfully submitted, Thomas Scott. Fla. Bar No. 149100 COLE, SCOTT & KISSANE, U. Dadeland Centre H 9150 South Dadeland Boulevard, Stine 1400 Miami, Florida 33156 Telephone: (305) 350-5300 Facsimile: (305) 373-2294 -and-

Entered on FLSD Docket 12/30/2014 Page 10 of 13 Jane Doe #3's and Jane Doe #4's participation is also directl

Case 9:08-cv-80736-KAM Document 282 Entered on FLSD Docket 01/05/2015 Page 8 of 10 Respectfully submitted, Thomas Scott Fla. Bar No. 149100 COLE, SCOTT & KISSANE, P.A. -and- /s/ Kendall Coffey Kendall Coffey, Fla. Bar No. 259681 Benjamin H. Brodsky, Fla. Bar No. 73748 Counsel for Prof Alan Al. Dershowiiz

first met Epstein in 1999 and that Epstein "kept Jane Doe #3 as his sex slave from about 1999 through 2002, w

ated: May 2015 Respectfully Submitted, s/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 Steven R. Safra Florida Bar No. 057028 COLE, SCOTT & KISSANE, Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson

first met Epstein in 1999 and that Epstein "kept Jane Doe #3 as his sex slave from about 1999 through 2002, w

ated: May 2015 Respectfully Submitted, s/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 Steven R. Safra Florida Bar No. 057028 COLE, SCOTT & KISSANE, Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson