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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
e Epstein designated],’” she said. Roberts’ story about the modeling agency is supported, to a degree, by the sworn statement of a Miami woman named Maritza Vasquez, who was later interviewed in New York by an FBI agent from Miami. Vasquez worked as a bookkeeper for Mc2, owned by Epstein associate Jean-Luc Brunel
s case. As one of innumerable examples, on March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you rub Jane Doe 3's vagina? A: Excuse me. I'd like to answer that question, as I would like to answer mostly every question you've asked me here today; however, upon ad
cy MC2, a company for which Epstein provides financial support. See Message Pad's attached as Exhibit "J" supra and Sworn Statement of MC2 employee Maritza Vasquez, June 15, 2010, "Maritza Vasquez Sworn Statement" attached at Exhibit "RH" at 1-16. 65. Employees of MC2 told Edwards that Epstein's numerous cond
me Court, an Associate Deputy Attorney General with the U.S. Justice Department (1986-88), and an Assistant U.S. Attorney for the Eastern District of Virginia (1988 to 1991). Cassell joined the faculty at the University of Utah College of Law in 1992, where he taught full time until he was sworn in as a U.S
lost potentially ten-million dollars in profits due to this initial one-million dollar loss. 23. Additionally, a former financial controller of MC2, Maritza Vasquez, stated in a 2012 deposition that Plaintiff Brunel had never done anything inappropriate or illegal with any under- age model. (Exhibits H! & H2 -Tra
Microsoft Word - Exhibit K.docx
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 →e Epstein designated],’” she said. Roberts’ story about the modeling agency is supported, to a degree, by the sworn statement of a Miami woman named Maritza Vasquez, who was later interviewed in New York by an FBI agent from Miami. Vasquez worked as a bookkeeper for Mc2, owned by Epstein associate Jean-Luc Brunel
Page: HOUSE_OVERSIGHT_017806 →, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you rub Jane Doe 3's
ency MC2, a company for which Epstein provides financial support. See Message Pad's attached as Exhibit “J” supra and Sworn Statement of MC2 employee Maritza Vasquez, June 15, 2010, “Maritza Vasquez Sworn Statement” attached at Exhibit “HH” at 1-16. 65. Employees of MC2 told Edwards that Epstein’s numerous condos
Page: HOUSE_OVERSIGHT_010590 →Second Renewed Motion for Leave to Assert Claim for Punitive Damages; Exhibit “D” — Edwards’ Notice of Filing of Transcript of Telephone Interview of Virginia Roberts in Support of Motion for Leave to Amended to Assert Punitive Damages; Exhibit “E” — Transcript of Deposition of Jeffrey Epstein dated January 25, 20
Page: HOUSE_OVERSIGHT_013305 →ency MC2, a company for which Epstein provides financial support. See Message Pad's attached as Exhibit “J” supra sii Sworn Statement of MC2 employee Maritza Vasquez, June 15, 2010, “Maritza Vasquez Sworn Statement” attached at Exhibit “HH” at 1-16. : 65. Employees of MC2 told Edwards that Epstein’s numerous cond
Page: HOUSE_OVERSIGHT_013344 →Entities connected to both Virginia Giuffre and Maritza Vasquez

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
PERSONMaria Farmer
PERSON
Kenneth Marra
PERSONFBI
ORGANIZATION