Epstein Secrets

LAINTIFF ALAN DERSHOWITZ’S MOTION FOR CLARIFICATION OF CONFIDENTIALITY ORDER OR RELIEF FROM THAT ORDER The transcript of the deposition of non-party Virginia Roberts Giuffre (“Roberts”) is currently under seal as a result of the January 12, 2016 Confidentiality Order in this action. Dershowitz seeks clarification that the

ranscript of the deposition of non-party Virginia Roberts Giuffre (“Roberts”) is currently under seal as a result o

MOTION FOR CLARIFICATION OF CONFIDENTIALITY ORDER OR RELIEF FROM THAT ORDER The transcript of the deposition of non-party Virginia Roberts Giuffre (“Roberts”) is currently under seal as a result of the January 12, 2016 Confidentiality Order in this action. Dershowitz seeks clarification that the Confident

Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 [email protected] Steven R. Safra Florida Bar No. 057028 [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simps

ts. It is without question that Giuffre was sexually abused as ' Jane Doe No. 3 is Virginia Roberts Giuffre, and will hereinafter be referred to as “Guiuffre.” > See Exhibit 1, CNN International, New Day, January 6, 2015. See also Exhibit 2, Australian Broadcasting System (ABC), January 6, 2015. “My goal

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

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

“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

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

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

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, Florida 33156 Telephone: (305) 350-5300 Facsimile: (305) 373-2294 Couns