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

(305)-373-2294 Attorneys for Defendant Richard A. Simpson (pro hac vice) [email protected] Mary E. Borja (pro hac vice) [email protected] Ashley E. Eiler (pro hac vice) [email protected] WILEY REIN LLP 1776 K St. NW Washington, DC 20006 Phone: (202) 719-7000 Fax: (202) 719-7049 HOUSE_OVERSIGHT_010

fendant. PLAINTIFFS AND NON-PARTY CASE. NO. CACE 15-000072 NOTICE REGARDING THE PARTIES' JOINT SITPULATION OF DISMISSAL Plaintiffs and Non-Party Virginia Giuffre, by and through undersigned counsel, hereby provide the Court with Notice that while the Plaintiff and Defendant submitted a Joint Stipulation of D

N OF DISMISSAL Plaintiffs and Non-Party Virginia Giuffre, by and through undersigned counsel, hereby prov

ITPULATION OF DISMISSAL Plaintiffs and Non-Party Virginia Giuffre, by and through undersigned counsel, here

an Dershowitz _.c(t.. '..-Y Richard A. Simpson 4 C r:iiiii!),,w)(cmsilemteih.cot, #:" Mary E. Soda 4: %) <6.(\S) Tithprja a wileyre*SOM 4' Ashley E. Eiler :mien/ wile41n.coni 42A WILEY REIN, LLP c''' 1776 K Street NW '-'.C".' 44, Washington, D.C. 20006 55' # OTC Counsel fi r Alan Dershowitz ,c(S

s filed a pleading in the Federal Action titled "Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for

his Counterclaim. 30 EFTA00613438 Respectfully submitted, s/ Thomas E. Scott Thomas E. Scott, FBN 149100 • c vice) ary . orja ro iac vice) Ashley E. Eiler (pro hoc vice) Nicole Audet Richardson WILEY REIN LLP ro hac vice) Counsel for Alan M. Dershowitz 31 EFTA00613439 CERTIFICATE OF SERVICE I H

first met Epstein in 1999 and that Epstein "kept Jane Doe #3 as his sex slave from about 1999 through 2002, w

deland Boulevard Miami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson admittec i ce Mary E. Botja (admittet ice) Ashley E. Eiler (admitted m ro/ r tc 4ce) WILEY REIN LLP 1776 K Street NW Washington, DC 20006 Phone: (202) 719-7000 Fax: (202) 719-7049 Counsel for Alan M

first met Epstein in 1999 and that Epstein "kept Jane Doe #3 as his sex slave from about 1999 through 2002, w

iami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson (admitted pro hac vice) Mary E. Borja (admitted pro hac vice) Ashley E. Eiler (admitted pro hac vice) WILEY REIN LLP 1776 K Street NW Washington, DC 20006 20 EFTA00584081 Phone: (202) 719-7000 Fax: (202) 719-7049 Coun

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

n M. Dershowitz began the deposition of non-party Virginia Roberts Giuffre (“Roberts”). Pursuant to this Court’s January 12,

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

e: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson (pro hac vice) [email protected] Marty E. Borja (pro hac vice) [email protected] Ashley E. Eiler (pro hac vice) [email protected] Nicole Audet Richardson (pro hac vice) [email protected] WILEY REIN LLP 1776 K Street NW Washington, D

poena, as to the law firm, is quashed As to the "Jane Doe #3" subpoena: The motion is granted as to request #9

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

ne: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson (pro hac vice) [email protected] Mary E. Borja (pro hac vice) [email protected] Ashley E. Eiler (pro hac vice) [email protected] Nicole A. Richardson (pro hac vice) [email protected] WILEY REIN LLP 1776 K Street NW Washington, DC 2

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

rostitution. RESPONSE: Defendant objects to this Document Request as vague because Defendant is not in a position to determine the willful nature of Jane Doe #3’s prostitution. Defendant further objects to this Document Request because Jane Doe #3 has repeatedly and publicly asserted that she gave her body fo

ons, Defendant responds that he will produce any responsive, non-privileged documents currently in his possession, custody or control. Of Counsel: Ashley E. Eiler [email protected] WILEY REIN LLP 1776 K Street, NW Washington, DC 20006 Phone: (202) 719-7000 Fax: (202) 719-7049 Kenneth A. Sweder ksweder@swede

SETTS 5 MISSISSIPPI ® NEW HAMPSHIRE "NEW JERSEY § VIRGINIA ® WASHINGTON 0G PARALEGALS: VIMIAN AYAN-TEJEDA