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BIT A EFTA00092647 Case 1:19-cv-03377-LAP Document 101-1 Filed 12/20/19 Page 2 of 41 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA GIUFFRE, Plaintiff, v. ALAN DERSHOWITZ, Defendant. ALAN DERSHOWITZ, Counterclaim Plaintiff, v. VIRGINIA L. GIUFFRE, Counterclaim Defendant.
TA00092647 Case 1:19-cv-03377-LAP Document 101-1 Filed 12/20/19 Page 2 of 41 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA GIUFFRE, Plaintiff, v. ALAN DERSHOWITZ, Defendant. ALAN DERSHOWITZ, Counterclaim Plaintiff, v. VIRGINIA L. GIUFFRE, Counterclaim Defendant. Civil A
UTHERN DISTRICT OF NEW YORK VIRGINIA GIUFFRE, Plaintiff, v. ALAN DERSHOWITZ, Defendant. ALAN DERSHOWITZ, Counterclaim Plaintiff, v. VIRGINIA L. GIUFFRE, Counterclaim Defendant. Civil Action No. I :19-cv-3377 (LAP) AMENDED COMPLAINT EFTA00092648 Case 1:19-cv-03377-LAP Document 101-1 Filed 12/20/
. ALAN DERSHOWITZ, Counterclaim Plaintiff, v. VIRGINIA L. GIUFFRE, Counterclaim Defendant. Civil Action No. I :19
omen first indicate they never had sex with me; then they meet Boies. Then they suddenly `remember' they had sex with me. Boies must know that both Accusers cannot be believed and that they made up the stories about me in the hope of getting money (which they got). Yet, he submitted their false affidavi
heir credibility without disclosing to the courts their documented history of lying about prominent people." ii. "In all three instances, my false Accusers have refused to make their accusations to the media on the record. They have made them only in court papers, hiding behind the litigation privilege
. 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
As to Epstein's mother, who died in April 2004, the defendant contends that she "would have testified that she did not observe Ms. Maxwell with any Accusers between 1994 and 1997." (Def. Mot. 7 at 9). "Counsel's unworn assertions as to vague generalities" that witnesses, "if alive, would give testimony
. 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
As to Epstein's mother, who died in April 2004, the defendant contends that she "would have testified that she did not observe Ms. Maxwell with any Accusers between 1994 and 1997." (Def. Mot. 7 at 9). "Counsel's unworn assertions as to vague generalities" that witnesses, "if alive, would give testimony
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
As to Epstein's mother, who died in April 2004, the defendant contends that she "would have testified that she did not observe Ms. Maxwell with any Accusers between 1994 and 1997." (Def. Mot. 7 at 9). "Counsel's unworn assertions as to vague generalities" that witnesses, "if alive, would give testimony
Entities connected to both Virginia Giuffre and Accusers

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
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
PERSONthe Southern District
LOCATIONMaria Farmer
PERSON
Colorado
LOCATIONFBI
ORGANIZATION
Kenneth Marra
PERSON
Scarlett Johansson
PERSON
Michael Jackson
PERSON
George Mitchell
PERSON
Michigan
LOCATION