Epstein Secrets

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

ronic Mail to the individuals identified below. By: /s/Sigrid S. McCawley Sigrid S. McCawley " Thomas E. Scott I hgrna,.scott'd c,klecia I cop; Steven R. Safra Ste_‘ en safraw csk Icgal coin COLE, SCOTT & KISSANE. P.A. 9150 S. Dadeland Blvd., Suite 1400 Miami, Florida 33156 Iteles,pail ,:aiklei2,11 ni

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

end, it would be an abuse of discretion for the Court to deny Dershowitz's request. 15 EFTA00613405 Respectfully submitted, s/ Thomas E. Scott Steven R. Safra, FBN 057028 COLE, SCOTT & KISSANE, P.A. Richard A. Simpson (pro hac vice) Ma E. Bo 'a ro hac vice) Ashle E. Filer ro hac vice) Nicole Audet Ric

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

sition of Jane Doe No. 3. 21 EFTA00582669 Dated: May 2015 Respectfully Submitted, s/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 Steven R. Safra Florida Bar No. 057028 COLE, SCOTT & KISSANE, Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 35

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

sition of Jane Doe No. 3. 19 EFTA00584080 Dated: May 2015 Respectfully Submitted, s/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 Steven R. Safra Florida Bar No. 057028 COLE, SCOTT & KISSANE, Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 35

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

15595 --- PAGE BREAK --- Dated: February 3, 2016 Respectfully submitted, s/Thomas E. Scott Thomas E. Scott, FBN 149100 [email protected] Steven R. Safra, FBN 057028 [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156

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

lief from that Confidentiality Order. Respectfully submitted, s/ 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, Flo

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

) 646-4466 Fax: (617) 646-4470 Respectfully submitted, /s/ Thomas E. Scott Thomas E. Scott, Esq. Florida Bar No. 149100 [email protected] Steven R. Safra, Esq. Florida Bar No. 057028 [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre I], 14th Floor 9150 South Dadeland Boulevard Miam

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