Filing # 37557658 E-Filed 02/08/2016 06:20:47 PM IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION BRADLEY J. EDWARDS, and CASE NO. CACE 15-000072 PAUL G. CASSELL, Plaintiffs, V. ALAN DERSHOWITZ, 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 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 12, 2015 Order. On December 18, 2016, this Court entered a Confidentiality Order holding that non-party Virginia Giuffre’s deposition would be confidential. See Exhibit B, December 18, 2015 Confidentiality Order. On January 16, 2016, Ms. Giuffre testified at her deposition in accordance with this Court’s Order. The deposition was labelled confidential in accordance with this Court’s Order. As the Court knows, Ms. Giuffre was a victim of sexual trafficking when she was a minor child. Indeed, the U.S. Attorney’s Office for the Southern District of Florida has specifically recognized HOUSE_OVERSIGHT_015650

her as a “victim” of federal sex offenses. Unsurprisingly, her deposition contains highly sensitive information about her experiences as a minor child, including detail descriptions of sexual crimes committed against her. ARGUMENT 1. Non-Party Virginia Giuffre Agrees That Her Deposition Should Be Provided Confidentially To Law Enforcement to Investigate All The Crimes Committed Against Her Defendant Dershowitz seeks to have the Court grant an exception to the confidential nature of the deposition so that it can be provided to the Office of the State Attorney and the Office of the United States Attorney for investigative purposes. Specifically, Defendant Dershowitz states in his motion that he is hoping to have law enforcement investigate whether Ms. Giuffre committed perjury by stating in her previously filed affidavit that it is her recollection that she witnessed former President Bill Clinton on Jeffrey Epstein’s island in the United States Virgin Islands (“USVI’)'. Setting aside Defendant Dershowitz’s baseless claims of perjury, Ms. Giuffre agrees that her confidential deposition should be provided to law enforcement, including the United States Attorney and the State Attorney in each jurisdiction where any alleged crimes occurred so that they may investigate all of the crimes committed against her when she was a minor child. To ensure that justice is served and that Defendant Dershowitz’s request is not just another charade designed only to bully a sexual abuse victim, Ms. Giuffre asks the Court to impose the following reasonable conditions relating to the disclosure: e Mr. Dershowitz agrees and is directed to cooperate with authorities and answer all questions relating to the investigation of crimes against Ms. Giuffre. ' Defendant Dershowitz conveniently ignores that publicly available flight logs of Jeffrey Epstein’s private planes demonstrate that President Clinton travelled with Jeffrey Epstein and others to various locations throughout the world including Europe, Africa and Asia. See Exhibit C, Excerpts of Flight Logs from Jeffrey Epstein’s private plane. HOUSE_OVERSIGHT_015651

Mr. Dershowitz agrees to make his client, Jeffrey Epstein, and others with relevant testimony and with whom he has testified he shares a “common interest” — at least Epstein and Maxwell — available to any law enforcement agency reviewing any alleged criminal activities; or in the alternative, to attest to this Court that those necessary witnesses have consented to full cooperation in the investigation Mr. Dershowitz is seeking permission to initiate. Mr. Dershowitz agrees to waive the statute of limitations in all jurisdictions for any criminal conduct he participated in or was aware of relating to Ms. Giuffre so that law enforcement can pursue any necessary charges. Defendant Dershowitz proclaimed that he was willing to waive any statute of limitation for criminal conduct so this should not be an issue. See Exhibit D, January 12, 2016 Deposition Transcript of Alan Dershowitz at 395. “T had talked about the statute of limitations for criminal purpose was what I said, that I would waive the statute of limitations for criminal purposes.” Mr. Dershowitz agrees to provide the names and contact information for each State Attorney and United States Attorney for which he has or is planning to provide information relating to Ms. Giuffre; and agrees to jointly, with Ms. Giuffre’s counsel, request that the State Attorney and United States Attorney, in the relevant jurisdictions, investigate all potential criminal conduct. Both parties may provide any relevant information they have that may assist the authorities with their investigation. For all other purposes non-party Ms. Giuffre’s January 16, 2016 deposition transcript shall remain confidential and sealed other than for confidential disclosure to law enforcement as described above. 2. Mr. Dershowitz Has No “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 from his retained expert that an “absence of records” in response to a FOJA request, establishes that former President Clinton was never on Jeffrey Epstein’s island in the USVI. Defendant Dershowitz misrepresents the government’s response. The government is only required to conduct a reasonable search of readily accessible records. Accordingly, an “absence of records” response does not mean that records do not exist. It simply means that in the course of the search, no records were found. See Cunningham v. U.S. Dept. of Justice, 961 F.Supp. 2d 226, 236 (D.C. 2013) (court reasoning that “t]he adequacy of a search is measured by a standard of reasonableness... The question is not 3 HOUSE_OVERSIGHT_015652

whether other responsive records may exist, but whether the search was adequate.”); Wilbur v. CLA., 355 F.3d 675, 678 (D.C. 2004) (court explaining that “the agency’s failure to turn up a particular document, or mere speculation that as yet uncovered documents might exist, does not undermine the determination that the agency conducted an adequate search for the requested records.”). Moreover, when dealing with a former President’s security detail travel, there are a number of reasons why the government may not disclose those records. As explained above, public flight records from Jeffrey Epstein’s private plane show that President Clinton traveled with Jeffrey Epstein on multiple occasions. Nevertheless, if Defendant Dershowitz wants to pursue this issue before the Court, then he needs to produce for deposition testimony in this case and the proposed criminal investigation, the other witnesses that were present on the island at the time former President Clinton was alleged to have visited, including his client Jeffrey Epstein, and Ghislaine Maxwell, to whom he has testified he is party to a joint defense agreement. It is worth noting on that point, that despite Mr. Epstein’s counsel’s attendance at depositions in this case, and Defendant Dershowitz’s claim that Mr. Epstein is still his client, Mr. Epstein has taken extreme measures to avoid being deposed in this case despite being ordered to deposition by this Court. Indeed, it is also noteworthy 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, 2016 at 511. Before Defendant Dershowitz could answer, Mr. Dershowitz’s legal counsel interposed an attorney-client privilege objection. /d. Perhaps Mr. Epstein’s defense counsel can provide to the Court an appropriate privilege log regarding that objection — and all the communications between Mr. Epstein and Defendant Dershowitz that would have been revealed in answer to that question — so that the Court will have the benefit of a full record in ruling on this motion. 4 HOUSE_OVERSIGHT_015653

CONCLUSION WHEREFORE, Non-Party Virginia Giuffre respectfully requests that this Court allow a limited release of her confidential deposition transcript to law enforcement subject to the terms set forth above on pages 2-3. Dated: February 8, 2016 Respectfully submitted, BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, Florida 33301 Telephone: (954) 356-0011 Facsimile: (954) 356-0022 By: /s/Sigrid S. McCawley Sigrid S. McCawley, Esq. Florida Bar No. 129305 Attorney for Non-Party Virginia Giuffre HOUSE_OVERSIGHT_015654

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on February 8, 2016, a true and correct copy of the foregoing was served by Electronic Mail to the individuals identified below. By:_/s/Sigrid S. McCawley Sigrid S. McCawley Thomas E. Scott [email protected] Steven R. Safra [email protected] COLE, SCOTT & KISSANE, P.A. 9150 S. Dadeland Blvd., Suite 1400 Miami, Florida 33156 [email protected] [email protected] Richard A. Simpson [email protected] Mary E. Borja [email protected] Ashley E. Eiler [email protected] WILEY REIN, LLP 1776 K Street NW Washington, D.C. 20006 Counsel for Defendant Alan Dershowitz Jack Scarola SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, P.A. [email protected] 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409-6601 Attorney for Plaintiffs HOUSE_OVERSIGHT_015655

EXHIBIT A HOUSE_OVERSIGHT_015656

IN THE CIRCUIT COURT OF THE 17"! JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION BRADLEY J. EDWARDS, and CASE NO. CACE 15-000072 PAUL G. CASSELL, Plaintiffs. Vv, ALAN DERSHOWITZ. Defendant, - ORDER ON BOIES, SCHILLER & FLEXNER LLP AND JANE DOE NO, 3’s MOTIONS TO QUASH SUBPOENAS OR FOR PROTECTIVE ORDER This Cause comes belore the Court on November 2, 2015 upon Boies, Schiller & Flexner L1P’s Motion to Quash Subpoena Or For Pratective Order and Jane Doe No. 3°s Motion to Quash Subpoena Or For Protective Order. Having reviewed the record and being otherwise fully advised, the Court hereby Orders: 1. Non-Party Law Firm Botes, Schiller & Flexner LLP’s Motion to Quash Subpoena is GRANTED. The subpoena to Boies, Schiller & Flexner LLP is quashed in its entirety. to Non-Party Jane Doe No. 3°s Motion to Quash Subpoena or For Protective Order is Denied in Part, Granted in part, as follows: a. The Motion to Quash is Granted as to Requests Nos. 9,17, 18, 20, and 23. The Motion is denied as to the remaining Requests. b. A Confidentiality Order shall be entered. c. The deposition af Jane Doe No. 3 shall be limited to 4 hours without prejudice to request for additional time in the future. d. The deposition will be taken at the law firm representing the witness. Boies, Schiller & Flexner LLP. HOUSE_OVERSIGHT_015657

e. There shall be a special master, paid by the Defendant, present at the deposition, to rule on objections. f. The Defendant Alan Dershowitz can be present at the deposition. a. The deposition will be limited to the issues of this case without prejudice for another deposition, if required, in the future. The issues and said limitations will be determined by the special master. DONE AND ORDERED in Broward County, Florida on this day of November, 2015. ec: Counsel of Recard ry i¥ " eT oa ee Honorable Judge Themias Lynch Cireuit Judge HOUSE_OVERSIGHT_015658

EXHIBIT B HOUSE_OVERSIGHT_015659

IN THE CIRCUIT COURT OF THE 17'" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION BRADLEY J. EDWARDS, and CASE NO. CACE 15-000072 PAUL G. CASSELL, Plaintiffs, V. ALAN DERSHOWITZ, Defendant. / ORDER ON BOIES, SCHILLER & FLEXNER LLP’S MOTION TO SEAL This Cause comes before the Court on December 18, 2015 upon Boies, Schiller & Flexner LLP’s Motion to Seal “Exhibit B, Affidavit of Alan M. Dershowitz Regarding Meetings with David Boies” to Defendant Alan M. Dershowitz’s Motion in Limine to Overrule Objections As to Application of Settlement Rules, Filing # 35429605 E-Filed 12/11/2015 at 10:08:04 a.m. Having reviewed the record and being otherwise fully advised, the Court hereby Orders: 1 ‘ ; " i is Ne i _ . —_— es — ciittitronin itl a rs DONE AND ORDERED in Broward County, Florida on this + | Chaay of December, 2015, HOMa. M, Honorable Judge Thomas Ly neh me Circuit Court Judge © Con. ce: Counsel of Record HOUSE_OVERSIGHT_015660

EXHIBIT C HOUSE_OVERSIGHT_015661

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EXHIBIT D HOUSE_OVERSIGHT_015667

334 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, DERSHOWITZ, Defendant. VIDEOTAPE CONTINUED DEPOSITION OF ALAN M. DERSHOWITZ VOLUME 3 Pages 334 through 461 Tuesday, January 12, 2016 9:46 a.m. - 11:59 a.m. Tripp Scort 110 Southeast 6th Street Fort Lauderdale, Florida Stenographically Reported By: Kimberly Fontalvo, RPR, CLR Realtime Systems Administrator www.phippsreporting.com (888) 811-3408 HOUSE_OVERSIGHT_015668

394 Virginia believes she has been hurt by you or Prince Andrew, she should be suing for damages? MR. SCOTT: Objection, form. A. Et dent tecgalil. BY MR. EDWARDS: Ox Have you ever said, "I welcome that lawsuit"? MR. SCOTT: Objection, form. You should identify what you're publishing from. MR. EDWARDS: I'm asking if he's ever made the statement to anybody other than his lawyers. A. I know I said that I welcome any opportunity to put Virginia Roberts under oath and to have her cross examined to establish that everything she's said about me is totally false, which I'm confident we can do. BY MR. EDWARDS: Q. After making that statement, were you presented by Mr. Scarola, I believe, with a waiver of the statute of limitations in order to oblige you on filing that lawsuit? A. Mr. Scarola wrote me a nasty letter that I didn't think it was appropriate to respond to. What I did do is state under oath that she was lying and www.phippsreporting.com (888) 811-3408 HOUSE_OVERSIGHT_015669

10 deck LZ L3 14 LS 16 7 18 LS 20 Zl 22 Zo 24 25 state under oath that I did not have sex with her, thereby opening myself up -- MR. EDWARDS: This again is nonresponsive to the question. SPECIAL MASTER POZZUOLI: Let me stop -- repeat the question so we can get an answer. BY MR. EDWARDS: Q. The question is, were you sent a waiver of the statute of limitations to sign so that Virginia Roberts could bring that lawsuit? Were you? A. I don't believe that's right. I don't believe that's right. I don't believe that I was sent a -- something that would give her the opportunity -- a waiver to file that lawsuit. That's not my recollection. If you show it to me, maybe my recollection will be refreshed. I had talked about the statute of limitations for criminal purpose was what I said, that I would waive the statute of limitations for criminal purposes. If a prosecutor were to investigate this case and come to the conclusion that there was probable cause that I had committed any offense with Virginia Roberts, I would then waive the statute of limitations. ©. . Okay. www.phippsreporting.com (888) 811-3408 HOUSE_OVERSIGHT_015670