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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
s.” 65. Dershowitz lied and stated that he had never flown on Jeffrey Epstein’s plane with a young woman and always flew with his wife. (Hala Gorani, CNN Live, Jan. 5, 2015). However, even the limited publically available flight logs of Jeffrey Epstein’s private plane demonstrate that Dershowitz flew often
the mansion “pretty often . . . at least four or five times a year” and would stay “two [or] three days.” (73:22-25). Alessi also testified that Ms. Virginia Roberts Giuffre came to the house when Dershowitz was there. (73:18-20) Alessi answered “yes” when asked whether Dershowitz “had massages sometimes when he was there
Page: HOUSE_OVERSIGHT_016198 →days.” (73:22-25). Alessi also testified that Ms. Virginia Roberts Giuffre came to the house when Dershowitz was the
Page: HOUSE_OVERSIGHT_016198 →3:22-25). Alessi also testified that Ms. Virginia Roberts Giuffre came to the house when Dershowitz was there. (73:
Page: HOUSE_OVERSIGHT_016198 →o be litigated today, nothing in this affidavit is intended to disclose — nor does it disclose — any confidential communications we received from Ms. Giuffre. However, I can report that in approximately May, 2014, I flew from Utah to Fort Lauderdale, Florida, where Mr. Edwards and I conducted a full-day in
Page: HOUSE_OVERSIGHT_016199 →1:19-cv-03377-LAP Document 36-4 Filed 07/03/19 Page 4 of 6 24, After more than six months of follow-up investigation, on Decem rites and | filed Ms. Virginia Giuffre’s allegations of stiee by fivele Dewi a others in the CVRA case as part of a motion for her to join the CVRA case. The decision to file was made by M
Page: HOUSE_OVERSIGHT_016200 →far as the planes are concemed, there are flight manifests. They will prove I was never on any private airplane with any young women.” (Hala Gorani, CNN Live, Jan. 5, 2015). 35. Contrary to these assertions, evidence I possessed showed the following things. 36. On February 9, 1998, Alan Dershowitz appear
Page: HOUSE_OVERSIGHT_016200 →ere it would have been possible to have sex with Jane Doe #3."). In media statements, Dershowitz has repeatedl
5, 2015 ("She claims I had sex with her in the airplanes, manifests of the flights will show I was never on the airplanes with her."); Halo Gorani — CNN Live, Jan. 5, 2015 ("As far as the planes are concerned, there arc flight manifests. They will prove I was never on any private airplane with any young
Entered on FLSD Docket 12/30/2014 Page 10 of 13 Jane Doe #3's and Jane Doe #4's participation is also directl
5, 2015 ("She claims I had sex with her in the airplanes, manifests of the flights will show I was never on the airplanes with her."); Hula Gorani —CNN Live, Jan. 5, 2015 ("As far as the planes are concerned, there are flight manifests. They will prove I was never on any private airplane with any young
ay. The prince had also visited Epstein on several occasions, in | Palm Beach as well as in New York. And if allegations Virginia ‘eighteen months. Roberts made in her 2015 declaration are to be believed, Epstein rent that Jeffrey Epstein had gotte 0 stein, Alfredo Rodriguez served hit is did not ask fo
Page: HOUSE_OVERSIGHT_022118 →land as well as in New York and in London. Invariably, the photograph of Prince Andrew with his arm around the bare midriff of a very young-looking Virginia Rob- 3 erts ran with stories that appeared in the tabloids. i “It is emphatically denied that the Duke of York had any form 7 of sexual contact or relation
Page: HOUSE_OVERSIGHT_022119 →land. The Guardian reported that the manager of two Virgin Islands—based corporations owned by Epstein happened to be the wife of the governor of the Virgin Islands. There were allegations involving a million-dollar dona- tion that Epstein had made to the governor's reelection cam- paign. And then there w
Page: HOUSE_OVERSIGHT_022119 →e woul owever, for the avoidance of doubl ty with underage minors is categou HOUSE_OVERSIGHT_022140 --- PAGE BREAK --- CHAPTER 64 Declaration of Virginia Roberts Giuffre, filed on January 19, 2015 by attorneys representing Jeffrey Epstein’s victims (continued) 20. Harvard law professor Alan Dershowitz was around Eps
Page: HOUSE_OVERSIGHT_022141 →--- CHAPTER 64 Declaration of Virginia Roberts Giuffre, filed on January 19, 2015 by attorneys represen
Page: HOUSE_OVERSIGHT_022141 →GE BREAK --- CHAPTER 64 Declaration of Virginia Roberts Giuffre, filed on January 19, 2015 by attorneys represen
Page: HOUSE_OVERSIGHT_022141 →12, 2016, and in support thereof states the following: On January 16, 2016, Defendant Alan M. Dershowitz began the deposition of non-party Virginia Roberts Giuffre (“Roberts”). Pursuant to this Court’s January 12, 2016 Confidentiality Order, that transcript currently is under seal. The Confidentiality Order shou
Page: HOUSE_OVERSIGHT_015590 →n M. Dershowitz began the deposition of non-party Virginia Roberts Giuffre (“Roberts”). Pursuant to this Court’s January 12,
Page: HOUSE_OVERSIGHT_015590 →support thereof states the following: On January 16, 2016, Defendant Alan M. Dershowitz began the deposition of non-party Virginia Roberts Giuffre (“Roberts”). Pursuant to this Court’s January 12, 2016 Confidentiality Order, that transcript currently is under seal. The Confidentiality Order should be modi
Page: HOUSE_OVERSIGHT_015590 →poena, as to the law firm, is quashed As to the "Jane Doe #3" subpoena: The motion is granted as to request #9
Page: HOUSE_OVERSIGHT_015614 →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
Page: HOUSE_OVERSIGHT_015622 →Entities connected to both Virginia Giuffre and CNN Live

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
Joe Biden
PERSONthe Southern District
LOCATION
Marc Rich
PERSON
Prince Charles
PERSON
Stephen Hawking
PERSONMaria Farmer
PERSON
Colorado
LOCATION