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Microsoft Word - 2016-02-08 Response to Defendant's Alan Dershowitz's Moton for Clarification of Confidentiality Order or Rel
RSHOWITZ, Defendant. RESPONSE TO DEFENDANT ALAN DERSHOWITZ’S MOTION FOR CLARIFICATION OF CONFIDENTIALITY ORDER OR RELIEF FROM THAT ORDER Non-Party Virginia Giuffre, by and through undersigned counsel, hereby responds to Defendant Alan Dershowitz’s Motion for Clarification of Confidentiality Order or Relief From
Page: HOUSE_OVERSIGHT_015650 →ief From that Order and states as follows: FACTUAL BACKGROUND On November 12, 2015 this Court issued an Order granting in part, non-party Virginia Giuffre’s Motion to Quash the subpoena served by Defendant Alan Dershowitz and ordered protective limits relating to her deposition. See Exhibit A, November
Page: HOUSE_OVERSIGHT_015650 →ential in accordance with this Court’s Order. As the Court knows, Ms. Giuffre was a victim of sexual trafficking when she was a minor child. Indeed, the U.S. Attorney’s Office for the Southern District of Florida has specifically recognized HOUSE_OVERSIGHT_015650 --- PAGE BREAK --- her as a “victim” of federal sex offens
Page: HOUSE_OVERSIGHT_015650 →“Evidence” of Perjury And Instead Is Simply Trying To Bully This Victim As explained above, Defendant Dershowitz wrongly suggests to this Court that non-party Virginia Giuffre has committed perjury in an effort to taint the Court against this victim. His only “evidence” of this alleged perjury is a self-serving opinion fro
Page: HOUSE_OVERSIGHT_015652 →that during Defendant Dershowitz’s recent deposition, counsel for Mr. Edwards and Mr. Cassell asked Defendant Dershowitz the following question: “Was Virginia Roberts lying when she said Jeffrey Epstein socialized with Bill Clinton during the relevant time period?” Depo Tr. Of Alan Dershowitz, Vol. 4, January 12, 2
Page: HOUSE_OVERSIGHT_015653 →been charged with wrongdoing, has denied allegations made in Jeffrey Epstein the lawsuit that she was Epstein’s “madam.” The suit, filed by victim Virginia Roberts, was settled in 2017. It was Epstein’s contacts with powerful and famous people that first propelled him into the public spotlight. In 2002, he fle
Page: HOUSE_OVERSIGHT_022210 →tion, saying he did not participate in Epstein’s criminal case and “never learned any confidential, non-public information about the Epstein matter” The U.S. Attorney’s Office has since disputed that, saying in court papers that he did possess confidential information about the case. Contacted for this story, Reinhart, in
Page: HOUSE_OVERSIGHT_022210 →Standing and the Public Interest. 56. The press has a constitutional right of access to criminal proceedings, see, e.g., Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980), including pre-trial criminal proceedings. Newman v. Graddick, 696 F.2d 796 (11th Cir. 1983). Indeed, “the integrity of the
on “34 confirmed minors” that were victims ofEpstein’s sexual predations. Based on evidence gathered by the FBI, a 53-page indictment was prepared by the U.S. Attorney’s Office in June 2007. However, at the request ofEpstein’s lawyers, the indictment was never presented to a federal grand jury. 25. Instead, then U.S. Attorne
titutional protections."'Butterworth, 494 U.S. at 630—31 (quoting U.S, v. Dionisio, 410 U.S. 1, 11 (1973)); see also Landmark Communications, Inc. v. Virginia, 435 U.S, 829, 838 (1978) (balancing state’s interest in preserving confidentiality ofjudicial misconduct proceedings against rights of newspaper rep
Recarey shared the same view that “it wasn’t any.justice served.” Appendix at 2 (Recarey Depo. 496:1-2). 26. Deputy Chief of the Criminal Division of the U.S. Attorney’s Office, Andrew Lourie, in a transmittal letter with the prosecution memo of Assistant U.S'. Attorney Ann Marie Villafana, told Criminal Chief Matthew Menche
ticle-2974613/Jeffrey- Epstein-sex-slave-money-hungry-sex-kitten-enjoyed-role-travelling-masseuse-former-friends-clai... Jeffrey Epstein ‘sex slave’ Virginia Roberts was a'money-hungry sex kitten’, ex friends claim | Daily Mail Online ‘millionaire's house’ for a day or two, before returning with cash. He did say
Page: HOUSE_OVERSIGHT_015529 →ay or two, before returning with cash. He did say that she tried to get out of the sex business, but was dragged back in. Last month it was revealed Roberts accused two male acquaintances she was raped, bringing her credibility into question. Roberts’ lawyers says the latest allegations do not contend th
Page: HOUSE_OVERSIGHT_015529 →GHT_015530 --- PAGE BREAK --- Case 1:15-cv-07433 Document1 Filed 09/21/15 Page 1 of 12 United States District Court Southern District of New York VIRGINIA L. GIUFFRE, Plaintiff, CASE NO: V. GHISLAINE MAXWELL, Defendant. / COMPLAINT Boies Schiller & Flexner LLP 575 Lexington Avenue New York, NY 10022 (212) 446-
Page: HOUSE_OVERSIGHT_015531 →1 --- PAGE BREAK --- Case 1:15-cv-07433 Document1 Filed 09/21/15 Page 2 of 12 Plaintiff, VIRGINIA L. GIUFFRE, formerly known as Virginia Roberts (“Giuffre”), for her Complaint against Defendant, GHISLAINE MAXWELL (“Maxwell”), avers upon personal knowledge as to her own acts and status and otherwise upon
Page: HOUSE_OVERSIGHT_015532 →as “child prostitution.” November: The FBI begins interviewing potential witnesses and victims from Florida, New York and New Mexico. 2007 May: As the U.S. Attorney’s Office prepares to present the case to a federal grand jury, Epstein’s attorneys request a meeting to discuss the investigation. June: A 53-page indictment
Page: HOUSE_OVERSIGHT_023005 →s global conferences on ways to achieve world peace and save the planet. He funds cancer and educational research projects around the country. 2015 Virginia Roberts was working at Mar-a-Lago when she was recruited to be a masseuse to Palm Beach hedge fund manager Jeffrey Epstein. She was lured into a life of depr
Page: HOUSE_OVERSIGHT_023011 →as Epstein’s madam, which she denies. Dershowitz and the prince deny her claims as well, setting off a series of legal actions between Dershowitz and Roberts’ attorneys that are later resolved in an out-of-court settlement. April: A federal judge rules that Roberts cannot join the federal Crime Victims’ R
Page: HOUSE_OVERSIGHT_023012 →, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you rub Jane Doe 3's
very day, often two or three times per day. Jd. 25, In light of all of the information of numerous crimes committed by Epstein, Edwards learned that the U.S. Attorney’s Office began preparing the filing of federal criminal charges against Epstein. For example, in addition to the witness tampering and money laundering charge
Page: HOUSE_OVERSIGHT_010577 →ch effort was successful. See Correspondence from U.S. Attorney’s Office to Epstein (hereinafter “U.S. Attorney’s Correspo
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 →Entities connected to both Virginia Giuffre and the U.S. Attorney’s Office

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Bill Clinton
PERSONJane Doe
PERSON
Julie K. Brown
PERSON
Marc Rich
PERSONMaria Farmer
PERSON
Stephen Hawking
PERSON
Kenneth Marra
PERSON
Colorado
LOCATIONFBI
ORGANIZATION
Paul Cassell
PERSON
Alexander Acosta
PERSON
Michigan
LOCATION