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

Richard Simpson of Wiley Rein on behalf of the Defendant and Counterclaim Plaintiff, Alan Dershowitz. With me is my colleague, Nicole Richardson, and Thomas Scott of Cole, Scott & Kissane, also for Mr. -~ Professor Dershowitz. MR. SCAROLA: Before we begin the deposition, ESQUIRE DEPOSITION SOLUTIONS (954) 331

en agreement? A. Well, there have been addenda to the agreement, if I recall correctly, but sitting here today, the parties to the agreement include Virginia Roberts, and her -- well, attorneys representing -- I ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021862 Oo O DN OO FF WwW NY =| NO RO PO PNP NM NO | S| S| HS SF S|

I'm putting aside her attorneys. MR. SCAROLA: Attorneys. MR. SIMPSON: Attorneys. MR. SCAROLA: Attorneys. MR. SIMPSON: Yes. MR. SCAROLA: Not just Virginia Roberts' attorneys, but any attorney sharing a common interest privilege? MR. SIMPSON: No. No. MR. SCAROLA: Okay. Well I'm not going to let him -- BY MR. S

ofessor Dershowitz engaged in this sexual misconduct with Miss Roberts; she's Jane Doe Number 3, correct? A. That's right. Jane Doe Number 3 is Miss Virginia Roberts Goufrey * (ph). Q. And I will ask you questions about that. But my question now is: You also allege that Professor Dershowitz was a participant in the abuse

| NO RO PO PNP NM NO | S| S| HS SF S| S| S| S| S| non BP WO NO -|- ODO OO WDN OO OT BP WO NYO — 28 A. Correct. Q. And focusing now, not -- not on Virginia Roberts, we are focusing on the other minors, correct? I just have that in mind, right? A. I'm sorry. Could you repeat the question? Q. I want to m

. MR. SIMPSON: Richard Simpson on behalf of Defendant and Counter-Claim Plaintiff Alan Dershowitz. And with me is my colleague Nicole Richardson and Thomas Scott from the firm of Cole Scott & Kissane. Ms. Richardson and I are from the firm of Wiley Rein. MR. SWEDER: Kenneth Sweder from the firm of ROUGH DRAF

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

certify that the foregoing document was served 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

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

, FL 33401 (561) 820-8711 Fax: (561) 820-8777 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 Telephon

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

iffs' counsel, and awarding such other relief 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

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

on the following using the Court's CM/ECF system: 500 S. Australian Ave., Suite 400 sis s West Palm Reach, FL 33401 Attorneys for the Government Thomas Scott [email protected] ar COLE. SCOTT & KISSANE, P.A. -and- Kendall Coffe Gabriel Groisman Benjamin H. Brodsk COFFEY BURLINGTON. P.L. Atto

sed above show a complete lack of investigation into the credibility of the woman making these scurrilous allegations®, what is most remarkable about Jane Doe #3’s Response is what it omits. Approximately six years ago, Jane Doe #3 took advantage of the NPA’s provisions, sued Mr. Epstein and received a monetary

gton.com COFFEY BURLINGTON, P.L. 2601 South Bayshore Drive, PH1 Miami, Florida 33133 Telephone: (305) 858-2900 Facsimile: (305) 858-5261 - and— Thomas Scott, Fla. Bar No. 149100 [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre II 9150 South Dadeland Boulevard, Suite 1400 Miami, Flor