Case 1:15-cv-07433-RWS Document 539 Filed 01/06/17 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK pane eee ene een enenenee X VIRGINIA L. GIUFFRE, : Plaintiff, V. 15-cv-07433-RWS GHISLAINE MAXWELL, : Defendant. . ee X Declaration of Laura A. Menninger in Support of Defendant’s Motion For Summary Judgment I, Laura A. Menninger, declare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of Ms. Maxwell’s Motion for Summary Judgment.’ 2. Attached as Exhibit A is a true and correct copy of an article by Sharon Churcher entitled “Prince Andrew and the 17-year-old girl his sex offender flew to Britain to meet him,” DAILY MAIL, dated March 2, 2011. ' At trial, defendant intends to produce either the custodian of record relevant to any disputed document or a certification in compliance with either Fed. R. Evid. P. 803 and/or 902. See Fed. R. Civ. P. 56(c). Apart from deposition testimony, the majority of non-deposition documents herein were either produced by plaintiff or obtained with releases signed by plaintiff. HOUSE_OVERSIGHT_014652

Case 1:15-cv-07433-RWS Document 539 Filed 01/06/17 Page 2 of 7 3. Attached as Exhibit B is a true and correct copy of an article by Sharon Churcher entitled “Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill Clinton,” DAILY MAIL, dated March 5, 2011. 4. Attached as Exhibit C is a true and correct copy of a statement on behalf of Ms. Maxwell dated March 9, 2011. 5. Attached as Exhibit D (filed under seal) 3 6. Attached as Exhibit E is a true and correct copy of an Order Denying Motion to Join Under Rule 21, Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla. Apr. 7, 2016). 7. Attached as Exhibit F is a true and correct copy of a statement on behalf of Ms. Maxwell dated January 2, 2015. 8. Attached as Exhibit G (filed under seal) i 9. Attached as Exhibit H (filed under seal) 10. Attached as Exhibit I (filed under seal) HOUSE_OVERSIGHT_014653

Case 1:15-cv-07433-RWS Document 539 Filed 01/06/17 Page 3 of 7 11. Attached as Exhibit J (filed under seal) 12. Attached as Exhibit K (filed under seal) (i 13. Attached as Exhibit L (filed under seal) 14. Attached as Exhibit M (filed under seal) 15. Attached as Exhibit N (filed under seal) i 16. Attached as Exhibit O (filed under seal) i 17. Attached as Exhibit P (filed under seal) eee 18. Attached as Exhibit Q (filed under seal) i eee HOUSE_OVERSIGHT_014654

Case 1:15-cv-07433-RWS Document 539 Filed 01/06/17 Page 4 of 7 19. Attached as Exhibit R (filed under seal) is 20. Attached as Exhibit S (filed under seal) 21. Attached as Exhibit T (filed under seal) is 22. Attached as Exhibit U (filed under seal) 3 23. Attached as Exhibit V (filed under seal) (is 24. Attached as Exhibit W (filed under seal) 25. Attached as Exhibit X(filed under seal) i 26. Attached as Exhibit Y (filed under seal) i 27. Attached as Exhibit Z (filed under seal) i HOUSE_OVERSIGHT_014655

Case 1:15-cv-07433-RWS Document 539 Filed 01/06/17 Page 5 of 7 28. Attached as Exhibit AA (filed under seal) ii 29. Attached as Exhibit BB (filed under seal) (i 30. Attached as Exhibit CC (filed under seal) is 31. Exhibit DD left intentionally blank. 32. Attached as Exhibit EE (filed under seal) 33. Attached as Exhibit FF (filed under seal) 34. Attached as Exhibit GG (filed under seal) 35. Attached as Exhibit HH (filed under seal) ii 36. Attached as Exhibit II (filed under seal) is HOUSE_OVERSIGHT_014656

Case 1:15-cv-07433-RWS Document 539 Filed 01/06/17 Page 6 of 7 37. Attached as Exhibit JJ (filed under seal) i 7 a et 38. Attached as Exhibit KK (filed under seal) i i a Fe 39. Attached as Exhibit LL is a true and correct copy of the Victims Refuse Silence, Inc. Articles of Incorporation dated December 23, 2014, GIUFFRE001064-5. 40. Attached as Exhibit MM (filed under seal) is CSS a I declare under penalty of perjury that the foregoing is true and correct. Executed on January 6, 2017. s/ Laura A. Menninger Laura A. Menninger HOUSE_OVERSIGHT_014657

Case 1:15-cv-07433-RWS Document 539 Filed 01/06/17 Page 7 of 7 CERTIFICATE OF SERVICE I certify that on January 6, 2017, I electronically served this Declaration of Laura A. Menninger in Support of Defendant’s Motion for Summary Judgment via ECF on the following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 [email protected] [email protected] Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 [email protected] J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 [email protected] /s/ Nicole Simmons Nicole Simmons HOUSE_OVERSIGHT_014658

Case 1:15-cv-07433-RWS Document 539-1 Filed 01/06/17 Page 1 of 9 EXHIBIT A HOUSE_OVERSIGHT_014659

Case 1:15-cv-07433-RWS Document 539-1 Filed 01/06/17 Page 2 of 9 6/14/2016 Prince Andrew and girl, 17, who sex offender friend fiew to Britain to meet him | Daily Mail Online Daily Mail y com Sports | U.S. Showbiz | Australia | Femail | Health | Science | Money | Video | Travel | Columnists sex offender friend flew to Britain to meet him By SHARON CHURCHER UPDATED: 08:02 EST, 2 March 2011 101 View comments » Virginia Roberts reveals she is 'Jane Doe 102’ in Jeffrey Epstein case + Mother-of-three spent four years as millionaire's personal masseuse - She describes being flown across world to meet Prince Andrew « Epstein trained her ‘as a prostitute for him and his friends’ As the UK's special representative for international trade, the Duke of York holds an important position, requiring sound judgement and widespread respect. But those qualities have been thrown into question since photographs of Prince Andrew with his billionaire financier friend Jeffrey Epstein, a convicted child-sex offender who was jailed for 18 months for soliciting underage prostitutes, appeared last weekend. Today, however, even more serious doubts are cast on his suitability after a woman at the centre of the Epstein case revealed to The Mail on Sunday that she had, as a 17-year-old employed by Epstein, been flown across the world to be introduced to the Prince. http:/Avww.dailymail.co.uk/news/article-1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him.html 1/34 HOUSE_OVERSIGHT_014660

Case 1:15-cv-07433-RWS Document 539-1 Filed 01/06/17 Page 3 of 9 6/14/2016 Case 1:15°orO7aSGaRwS7 Dersartret Pne1m toBileid G4 5/1 PalPywOBref 9 Lindsay Lohan flashes her cleavage ina low- cut lilac number as she enjoys romantic day in Zurich with fiancé Egor Tarabasov Lovely in lilac Back in time to celebrate! Kim Kardashian and Kanye West arrive inLA on eve of daughter North's third birthday Whirlwind 24-hour tip Bathing suit babes! Playboy vet Kendra Wilkinson shows off chest in one piace while celebrating 31st birthday with ‘number one ho’ in Arizona Sean Penn's son Hopper, 22, reveals his famous father wanted to name him ‘Steak’ due ta his love of red meat His mom Robin Wright wouldnt have gone for it New romance for Ruby? Rose ‘dating’ businesswoman Harley Gusman after the pair were Spotted cozying up ona date in Hollywood Off the market? Was Patrick Swayze a victim of domestic abuse? Wife denies claims she beat the Dirty Dancing star throughout their 34-year marriage - and aven when he was dying Advertisement First meating: Prince Andrew puts his arms around 17-year-old Virginia, cantre On one of those occasions Virginia Roberts was subsequently paid $15,000 (£9,400). Her shocking account of her four years as Epstein’s personal masseuse is supported by court documents, an eyewitness, photographs and flight details of Epstein’s private jets. One picture, said to have been taken by Epstein during Andrew's first encounter with the girl in March 2001 and published today by The Mail on Sunday, shows the Prince with his arm around her waist. This is not the first time the Duke of York’s judgment and choice of associates have been questioned. He appears to relish the company of super-rich oil billionaires from the Middle East, North Africa and the former Soviet Union. The peculiar sale of his former marital home to a Kazakh businessman for £15 million after it had languished unsold for five years at £12 million has never been satisfactorily explained. In the recent leak of American diplomatic cables it was revealed that he had criticised an official corruption investigation into the huge Al-Yamamah arms deal between Britain and Saudi Arabia, while he is also said to be close to Saif Al-Islam Gaddafi, son of the beleaguered Libyan president, and may have had a role in the early release of Lockerbie bomber Abdelbaset Al Megrahi. But it is Andrew's friendship with Epstein, whom H he has known since at least 2000, and with While on the streets, | Epstein’s confidante Ghislaine Maxwell, daughter i of the late disgraced newspaper baron Robert s | ept with men fo r Maxwell, that gives most concern. mon ey. | was a He was first seen with the pair on holiday in “Tt Thailand, and was pictured cavorting with paed Oop hile's dream Ghislaine at a Halloween fetishthemed party in hitp:/Avww.dailymail.co.uk/news/article-1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him.html 2/34 HOUSE_OVERSIGHT_014661

Case 1:15-cv-07433-RWS Document 539-1 Filed 01/06/17 Page 4 of 9 6/14/2016 Manhattan. The photograph that appeared last weekend shows the prince strolling through Central Park with 58-year-old Epstein. Andrew was said to have spent four days at his New York mansion in December, when he was joined by other distinguished guests, including Woody Allen, at a dinner. It is by no means the first New York soiree Andrew has attended as Epstein’s guest. A lengthy profile of the financier in Vanity Fair magazine some years ago reported that Andrew was a guest at a cocktail party thrown by Epstein and Maxwell packed with young Russian models. ‘Some guests were horrified,’ said the article's author, Vicky Ward. it should not be forgotten that Epstein is a registered sex offender after recently completing his sentence for offences relating to child prostitution. However, he avoided trial on more serious charges that carried a potential life sentence. And no one reading The Mail on Sunday's interview with the woman who was prepared to testify against him can be in any doubt of the seriousness of the charges. Epstein, a Wall Street money manager who once counted Bill Clinton and Donald Trump among his friends, became the subject of an undercover investigation in 2005 after the stepmother of a 14-year old girl claimed she was paid $200 (£125) to give him an ‘erotic massage’. The subsequent FBI probe uncovered at least 20 girls levelling sexual allegations against him. Eventually, Epstein struck a ‘plea bargain’ with prosecutors — a practice not permitted under British law — under which he was allowed to plead guilty to two relatively minor charges. Police claim that his donations to politicians and his ‘dream team’ of influential lawyers deterred prosecutors from bringing more serious charges of sex-trafficking. The deal certainly kept the names of a lot of Epstein’s famous friends out of an embarrassing court case. However, an unusual part of the agreement was that Epstein’s alleged victims were allowed to bring civil proceedings against him. He has so far made 17 out-of-court settlements, and some cases are ongoing. One of these girls was to have been a key witness for the prosecution had the case gone to trial. She was just 15 years old when she was drawn into Epstein’s exploitative world in 1998. In her civil writ against him, under the pseudonym Jane Doe 102’ she alleged that her duties included being ‘sexually exploited by Epstein’s adult male peers including royalty’. Now, horrified by the evidence of Epstein and Andrew enjoying each other’s company in New York, Jane Doe 102 has agreed to waive her anonymity and tell for the first time her deeply disturbing story. Her real name is Virginia Roberts and she now lives in Australia, where she is a happily married mother of three. Over the course of a week during which she spoke at length to The Mail on Sunday, she appeared sometimes vuinerabie, and sometimes steely, but always quietly resolute and consistent. Revisiting events from a past that she had hoped she had left behind, Virginia occasionally buried her face in her hands. Some recollections — and, for reasons of taste, not all the details can be included here — caused her to flush with shame. ‘I'm telling you things that even my husband didn’t know,’ she said. Virginia, who has undergone counselling to try to come to terms with her past, is honest about her initiation into Epstein’s depraved world. She was a troubled teenager, whose slender figure, delicate complexion, hesitant voice and soulful blue eyes made her look young for her years. Born in Sacramento, California, in August 1983, Virginia spent her early years on a small ranch on the West Coast of America. This seemingly idyllic childhood ended when she was sexually molested by a man close to her family. The fallout from that led to her parents temporarily splitting up. Blaming herself, Virginia began to get into trouble Aged 11, she was sent to live with an aunt but repeatedly ran away. Living on the streets, she was beaten up and slept with at least two older men in return for food. ‘1 was a paedophile’s dream,’ she says. Three years later, she was reunited with her family and started a new life with her father who had moved to Palm Beach, Florida, where he was maintenance manager at Donald Trump's country club, Mar-a-Lago. Virginia got a part-time job as a changing room assistant -which is where, soon after her 15th birthday, she met Ghislaine Maxwell, who invited her to work as Epstein’s personal masseuse. ‘| was wearing my uniform — a white miniskirt and a skin-tight white polo top — when | was approached by Ghislaine,’ Virginia says. ‘! told her | wanted to become a masseuse and she said she worked for a very wealthy gentleman who was looking for a travelling masseuse. I'd get training and be paid well. Virginia’s father gave his blessing, believing his daughter was being handed the opportunity to learn a skill and to work for a wealthy and respectable employer. He drove her to Epstein’s pink mansion on the Palm Beach waterfront — he also owns a nine-storey home in New York, the city’s biggest private residence; a 7,500-acre ranch called ‘Zorro’ in New http:/Awww.dailym ail.co.uk/news/article- 1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him.htm! Case 1:15°OeOd Se Ray” Dereuerrert Dneig toBileid (G94 51 Halpyg@ningf 9 ‘Nesd a tight tush’: LeAnn Rimes illustrates how to get a firm ‘booty’ as she does yoga in skimpy tank top and leggings Exercise tips ‘twant them raally big!’ Blonde bombshell begs dactors to make her 1,000cc implants - even after they insist her enhanced breasts are ‘perfect’ On Botched ‘it's my fourth favorite reality show! Jessica Alba and Kate Hudson are mean girls as Chris Martin plays for laughs in Sara and Erin Foster’s Barely Famous ‘He's turned into an absolute jark:' Former Celebrity Apprentice star Vivica A. Fox slams Donald Trump... but says he's not a racist She's no longer a fan ‘Idon't see a dark past anymore’: Paris Jackson reveals tattoos have helped cover her ‘scars and self-hatred’ in moving Instagram post How the season's hottest beach babes including Hailee Steinfeld and Kendall Jenner are ernbracing Jewelry at the seashore Chic on the beach This old thing! Duchess of Cambridge recycles a TEN-year-old brocade coat as she plants a tree at garden party From the back of her wardrobe EXCLUSIVE: Alexa Curtin, daughter of Real Housewives star Lynne, is charged with drug possession two months alter accusing O.C. deputy sheriff of raping her during a traffic stop ‘told my mom she's a grandma’: Maria Menounos shared excitement about her frozen embryos in poignant IVF interview... given before negative pregnancy test Gene Simmons’ daughter Sophie says she was told she was ‘nat small enough’ ta be a model and reveals her mam taught her to love her shape HOUSE_OVERSIGHT_014662

Case 1:15-cv-07433-RWS Document 539-1 Filed 01/06/17 Page 5 of 9 6/14/2016 Mexico and Little Saint James, a private 70- acre atoil in the US Virgin Islands. am be =. OM ae 4 qo, A new life: Virgina, naw a mother-of-three, in Australia Virginia says: ‘Ghislaine said | was to start immediately and that someone would drive me home. My father left and | was told to go upstairs.’ She was led by another woman through Epstein's bedroom into a massage room where he lay face down naked on a table. He started to interviewed Virginia. This was unconventional, but Virginia had no suspicions. Presumably, she thought, this was how the wealthy conducted their business. Epstein elicited the information that Virginia had been a runaway, and was no longer a virgin. Virginia was then told to start massaging Epstein, under the instructions of the woman who had shown her in. The massage quickly developed into a sexual encounter. Virginia was uncomfortable, but reluctant to deny such important people. ‘My face was red with embarrassment,’ she says. ‘But | felt under immense pressure to please them. The whole time it was going on, they were promising me the world, that I'd travel with Jeffrey on his private jet and have a well-paid profession.’ Afterwards, she was given two $100 bills and told to return the next day. That was the beginning of the four years she spent with Epstein. For three of those years, she was under Florida’s age of consent, which is 18. Case 1:1 5°CHOVGSGRWVS7. Densuefredet DehSig toBileld G74 5/1 MailPYgaGroef 9 ‘fd cry because thera was nothing I could da to help’: Bella Hadid pens emotional note about her mother Yolanda's Lyme disease battle and shares the impact of her own struggle Has the Queen Bey lost her sting? Beyonce steps out in two questionable outfits as she recycles Super Bow! Reformation look She is still a trailblazer Jenna Bush Hager shares somber message about motherhood as she reveals her daughter was baptized only hours before Orlando shooting Time for Kardashian klass! From ‘bloop' to ‘ratchet’... Kim schools fans in how to talk like a true-blooded member of the family How to be like them Brazilian Miss Bum Bum model raveals she is paralysed fram the waist down after throwing herself from a fourth floor window in suicide attempt Southern Charm stars claim Kathryn Dennis failed drug test in custody battle with wealthy drug-shamed former politician Thomas Ravenel as he takes their kids to NYG Mini-me Barron joins parents Donald Trump and Melania at The Polo Bar for dinner the night before his 70th birthday (and Secret Service chauffeurs them the one block walk home) Lord of the manor! Scott Disick views $2.8million property in Beverly Hills as he hunts for a house to fix up and sell He is 33 Paek-a-boob! Heidi Klum flashes cleavage hitp:/Awww.dailymail.co.uk/news/article- 1361039/Prince-Andrew-girl-17-sex- offender -friend-flew-Britain-meet-him html 4/34 HOUSE_OVERSIGHT_014663

Case 1:15-cv-07433-RWS Document 539-1 Filed 01/06/17 Page 6 of 9 6/14/2016 Case 1:1 5°OreGTd SG RaVS”. Dercurtremt DIGI Filed Oe" Troubled teenager: Virginia on the billionaire's Zorra ranch in New Mexico in 2001 Virginia was fascinated by his life story: the son of a humble New York City parks worker, he was a teacher before becoming a Wail Street broker and friends with the upper echelons of the political, financial and academic establishment. As a confused teenager, Virginia easily fell into the practice of sexually gratifying him for money. He guaranteed her a minimum of $200 each time she gave him what he called an ‘erotic massage.’ Virginia said: ‘I would always receive the money immediately. He would give me the cash from a wad he carried in a black duffel bag or an assistant paid me. ‘And, because of the way Epstein had warped her sensibilities, every time she took the cash, Virginia felt even more indebted to him. Secretly, he was also preparing her for an even more disturbing role. ‘Basically, | was training to bea prostitute for him and his friends who shared his interest in young Epstein had trained me irls,’ sh : ‘After about two , he started Baek mets antartain his friends. estene to do whatever men It started when Epstein called Virginia at the Pam Wanted. | told myself | Beach apartment he had rented for her. r was special She recalls: ‘He said, “I've got a good friend and | need you to fly to the island to entertain him, massage him and make him fee! how you make me feel.” He didn’t spell out what | had to do. He didn’t have to. ‘He'd trained me to do whatever a man wanted. | was shocked but | told myself he was sharing me around because he trusted me and | was special. | was worried, but | would do anything to keep Jeffrey happy and to keep my place as his number one girl. He would keep telling me how lucky | was with the life | was leading and the money ! was making. It was easy to fall into his grasp. ‘The way it usually worked was I’d be sent to meet a man on the private island Jeffrey owned in the Caribbean, or at his ranch in New Mexico, which was really isolated.’ She was ‘given’ to men ranging in age from their 40s to their 60s. They included a well-known businessman (whose pregnant wife was asleep in the next room), a world-renowned scientist, a respected liberal politician and a foreign head of state. None appeared to think the arrangement was unusual. Virginia says there were many other girls in Epstein’s circle and that she was paid extra money to help recruit them. ‘They would lounge around the Palm Beach house, the ranch or the island, nude or topless,’ she says. ‘But | was one of the very few he trusted as “special” and chosen to “entertain” his friends.’ Virginia took the sedative Xanax to detach herself from sordid reality. ‘lt was an escape drug,’ she says. ‘It made me caim and helped me forget about what | had to do. | was up to eight pills a day.’ Epstein had no objection to Virginia's use of prescription drugs, no doubt recognising that they made her even more malleable. ‘I didn’t want to go back to the life I'd had before’ she says. ‘That made me totally obedient.’ Despite the fact that Epstein was, essentially, her pimp, this life now seemed normal to Virginia. ‘l felt that he and Ghislaine really cared for me,’ she said. ‘We'd do family things, like watch Sex And The City and eat popcorn. ‘A lot of it was very glamorous. | met famous friends of his such as Al Gore and Heidi Klum and Naomi Campbell. He introduced me as his “travelling masseuse.” Some people mistook me for his daughter. ‘When we were in New York or Palm Beach, Ghislaine and | would shop all day. hitp:/Avww.dailymail.co.uk/news/article- 1361039/Prince-Andreaw-girl-17-sex-offender-friend-flaw-Britain-meet-him.htm! Si PaIPgoGret 9 as she leaves her blouse undone across her chest during NYC outing with her children Mom-offour e’s almost as tall as her mom! Gourteney Cox's daughter Caco Arquette wears high heels and polka dot dress for her 12th birthday at Nobu ‘it's hard on me": Liev Schraiber talks struggle of working in LA while Naomi Watts and their two kids are in NYC as he sits down with Ellen He misses them ‘twas too big’: Khice Kardashian reveals stylists refused to work with her before she lost 40lbs as she wows in stunning natural shoot for Harper's Bazaar Curb Your Enthusiasm is back! Larry David's beloved comedy series willreturn for a ninth season The beloved HBO comedy series Super-sized diamond Hor Majesty calls ‘Granny's Chips’ and the solitaire seed that grow @ into a flower: Queen's brooches and earrings have a glittering history Sporty! Channing Tatum wears a backward baseball cap and matching vest as he leaves NYC hotel The Magic Mike star was hard to miss Rollin’ and strollin'! Chilled Bobby Cannavatie gets behind the wheels of baby son Rocco's classy ride as he runs errands Star of HBO's Vinyl HOUSE_OVERSIGHT_014664

Case 1:15-cv-07433-RWS Document 539-1 Filed 01/06/17 Page 7 of 9 Case 1:15°CeGa Se RWS” Dencuehreiet Desig toiled G94 HM DalPYwOTinaf 9 6/14/2016 Jeffrey bought me jewellery — diamonds were his favourite — and wonderful furniture. He was paying me very well because I'd give him sex whenever he wanted it.’ She was, she says, delighted when Epstein invited her to accompany him on a six-week trip in 2001. ‘He said we'd be going to Europe and North Africa to meet architects and interior decorators because he wanted to redo his New Mexico house. | threw my arms around him and gave hima peck on the cheek.’ They flew to Paris, then Spain, then Tangier. Finally, they went to London. ‘After we landed, we drove straight to Ghislaine’s house,’ says Virginia. ‘Il was given a small upstairs bedroom. The following morning, Ghislaine came in. She was chirpy and jumped on the bed saying, “Get up, sleepyhead. You've got a big day. We've got to go shopping. You need a dress as you're going to dance with a Prince tonight.” ‘She said | needed to be “smiley” and bubbly because he was the Queen’s son. Ghislaine and | went to Burberry, where she bought me a £5,000 bag, and to a few other designer stores where we bought a couple of dresses, a pair of embroidered jeans and a pink singlet, perfume and make-up. We got back to Ghislaine’s house at around 4pm and | ran straight upstairs to shower and dress. When | went downstairs, Ghislaine and Jeffrey were in the lounge. There was a knock at the door. Ghislaine led Andrew in and we kissed each other on the cheek. ‘Ghislaine served tea from a porcelain pot and biscuits. She knew Sarah Ferguson and they talked fondly about Andrew's daughters. Then Ghislaine asked Andrew how old he thought | was and he guessed 17 and they all laughed. Ghislaine made a joke that | was getting too old for Jeffrey. She said, “He'll soon have to trade her in.” It was widely known that he liked young girls.’ The four of them went out to dinner and on to Tramp nightclub where, she says, Andrew danced with her. ‘After about an hour-and-a-half, we drove back to Ghislaine’s. Counselling: Virginia at her mother’s home at Palm Beach in 1998 All of us went upstairs and | asked Jeffrey to snap a picture of me with the Prince. | wanted something to show my Mom. Ghislaine and Jeffrey left us after that, and later Andrew left. ‘In the morning, Ghislaine said, “You did well. He had fun". We flew straight back to the States.’ The Mail on Sunday has confirmed that the tycoon’s jet flew to Paris on March 6, 2001, continuing to Granada, Tangier and London, before returning to New York. On the fast leg of the trip, Virginia was paid about $15,000 (£9,400) by Epstein. ‘It was amazing money, more than I'd ever made on a trip with him before. He didn’t say there was any special reason, but | felt like I'd done everything he wanted. He was very pleased.’ There is no suggestion that there was any sexual contact between Virginia and Andrew, or that Andrew knew that Epstein paid her to have sex help me for get what | had to with his friends. do. It made me calm. However, the Prince must have been aware of Epstein’s conviction when he stayed with him in New York in December. Virginia says she met Andrew for a second time around Easter 2001 at Epstein’s Manhattan mansion. ‘When | got fo the mansion, | was told, “Get ready. You are meeting someone in the office” — which is what they called the library. Andrew was sitting there in a big leather armchair. | took eight pills a day to Ghislaine had just given him a present, a big toy that was his Spitting Image puppet. 'He was smiling ear-to-ear. He looked like a kid whose parents were taking him to Disney World. A beautiful girl called Johanna Sjoberg who worked for Jeffrey was sitting on Andrew's knee. Ghislaine guided me over to Andrew and | think he recognised me, though | don’t know if he remembered my name. ‘Tm dating a separated married man.’ Bethenny Frankel reveals she want to high schoo! with wife of new boyfriend Dennis Shields Skinny Girl founder Get in there! Prince Harry and Zara Tindall can't contain their excitement as they watch their horses gallop to victory at Royal Ascot "This isn't about you and your fake a® kiss for publicity’: Madonna is slammed for her 'self- promoting’ tweets fallowing Orlando massacre Jason Momoa's mini- me! Game of Thrones hunk enjoys family outing with cutie clone Nakoa-Wolf Seven-year-old’s mom is Lisa Bonet Craving a little Mexican! Rob Kardashian's pregnant flancée Blac Chyna digs into a bowl of tortilla soup during Snapchat video Another Bachelor baby! Peyton and Chris Lambton are 'thrilled’ to be expecting their first child after four years of marriage The two wed in 2012 Lil Wayne ‘guzzlad three bottles of cough syrup mix lean’ before suffering TWO seizures...as rapper now ‘stable and in good Spirits’ Cowgirl chic! Alessandra Ambrosio shows off toned legs with mini skirt as the stunner goes for a denim-on-denim look Victoria’s Secret Angel Madonna and Guy Ritchie on brink of deal over custody of their 15- year-old son Rocco as judge agrees to call off showdown court hearing for more talks Gillian Anderson looks demure in sophisticated navy knee-length dress as she attends star studded charity gala On behalf of Action on Addiction Charlie Sheen cuts a casual figure while out and about in Stockholm... After becoming the new face http:/Avww.dailym ail.co.uk/news/article-1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him.htm! HOUSE_OVERSIGHT_014665

Case Document 5 6/14/2016 Organiser: Ghislaine Maxwell looks on as Andrew put his arm around Virginia. Robert Maxwell's daughter k as E i invited her to ersonal masseuse soon after her 15th birthday We kissed on the cheek and Ghislaine placed me on his other knee.’ Johanna spoke to The Mail on Sunday three years ago about this incident, which took place when she was 21. She said: ‘Ghislaine put the puppet’s hand on Virginia's breast, then Andrew put his hand on my breast. It was a great joke. Everybody laughed.’ After this, Virginia was paid, by Epstein, around $400 (£250).’ She met Andrew for the third and final time on Epstein’s Caribbean island, Little Saint James. Virginia was never under the British legal age of consent when she met Andrew. She was 17 during the first two encounters and 18 at the third. By now, however, Epstein, had started to hint that she was getting ‘too old’ for him. But during one trip to the island, Epstein and Ghislaine made their most astonishing proposition, and one which repulsed her. ‘They said Jeffrey wanted me to have his child,’ she says. ‘They said | was part of their family and | was beautiful,young, loyal and nurturing and would be a great mother. They said | would have to sign a contract relinquishing rights to the child and consenting to Jeffrey having as many relationships as he liked. In return | would have my own mansion in Palm Beach and a large monthly payment, a percentage of his income.’ This, finally, was a wake-up call to Virginia and she began to see the way in which she had been groomed. ‘It was a smack in the face,’ she says. ‘I finally realised this wasn’t ever going to be a real relationship but | knew if | refused, I'd be thrown back on the streets. So | said, “I'm too yaung. | want to get my massage credentials, then maybe we'll do it”.’ The tycoon took her at her word and, for her 19th birthday in August 2002, flew her to Thailand where he enrolled her in a massage course. Shortly after arriving there, she met an Australian martial arts expert called Robert. They fell in love and, just ten days later, married in a Buddhist ceremony. ‘| cailed Jeffrey and told him I'd fallen madly in love,’ Virginia says. ‘| was hoping he’d be delighted. But he said, “Have a nice life,” and hung up on me.’ The couple now have two sons, aged five and four, and a daughter who recently turned one. ‘The first few months ajter | married Robert were the worst,’ she says. ‘I couldn’t bring myself to tell him much. No man wants to know his wife has been traded out. ‘I felt very alone. | was having panic attacks and seeing a psychiatrist and was on anti-depressants. ‘ Virginia was beginning to put her Epstein days behind her when, three years ago, she was phoned by the FBI. http:/Avww.dailymail.co.uk/news/article-1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him html L:1SECROTR SH RIV’. VD RRMIPF ROM PPGIM toBileid (OSIt 51 HailPsOsnof 9 of condom brand Lelo Hex Wave goodbye to the rain! The deluge FINALLY stops as the Queen arrives at Ascot with Philip and Harry after thousands of racegoers got drenched Two nations standing together: Wills and Kate sign book of condolence to pay their respacts to the victims of Orlando nightclub killer Paying respects Time for an upgrade? David Arquette lists his historic Los Angeles mansion for $8.5m Selling Hancock Park seven-bedroom home which he boughtin 2014 She's her own best advert! Jessica Alba's tresses glint in the sun as she promotes her Honest Company’s new hair care range in New York Katharine McPhee flashes a hint of sideboob in a plunging unbuttoned black dress as she poses at the Monte Carlo Television Festival Lat the trading bagin! Independence Day's Liam Hemsworth and Vivica A. Fox ring the NASDAQ bell and help celebrate the Army's birthday in NYC Ava Sambora puts on an eye-popping display for sizzling phote shoot as she parades her enviable bikini bod in Malibu Daughter of rocker Richie Sambora How does Adele make YOU feel? Sad songs provide ‘enjoyment, comfort or pain to different people’ Great comfort from ssomingly sad songs Daisy Lowe and rumored boyfriend Darius Campbell appear in high spirits as they leave star-studded charity event She is 27 Sir Paul McCartney leads tributes as Wings guitarist Henry 734 HOUSE_OVERSIGHT_014666

Case 1:15-cv-07433-RWS Document 539-1 Filed 01/06/17 Page 9 of9 8/14/2016 Case 1:1 5°oreG7aaeRivS7. Dercuetredet DenGig tobi (Oe4 Hi Palpygyadgnef g ‘They said they had found photos of me at Jeffrey’s Paim Beach house,’ she says. ‘[Epstein had] hidden cameras watching me the entire time even when | was in the bathroom. | was so embarrassed. ‘l told the FBI that my true purpose was sexual. They told me everything he did was illegal because | was under age.’ (The age of consent in Florida is 18). ‘They said that if it had to go to trial, they'd need me because I'd lived with him and that made me a key witness. | was very afraid, because he had so much power, but eventually | agreed to testify. | was glad he’d finally been found out. He shouldn't be hurting other girls. Following Epstein’s arrest, investigators are believed to have found a list of men’s names on his computer and asked him whether they had been ‘treated’ to sexual encounters with his menage of minors. Conviction: Jeffrey Epstein ‘He took the Fifth Amendment, refusing to answer, indicating that if he were to answer the question, it could be incriminating,’ a source told The Mail on Sunday. Epstein struck a deal resulting in what commentators characterised as a ‘slap on the wrist’ for him, and ended up serving 13 months of his sentence, much of it in a liberal work-release programme Lawyer Brad Edwards, who represented several of Epstein’s victims, said: ‘Rather than punish him the way they would an average Joe, they sent a clear message that with enough money and power and influence, the system can be bought.’ Virginia was spared her the humiliation of having to go before a jury, and has kept her feelings bottled up until last weekend's photograph of Andrew with Epstein triggered distressing memories. Virginia says: ‘| am appalled. To me, it’s saying, “We are above the law.” But Jeffrey is a monster.’ Last night, neither Epstein, Ghislaine Maxwell nor Prince Andrew would comment on Virginia’s story. Share or comment on this article Need Business Capital? Get These Rare Historical Photos What Marcia Brady Looks Unsecured Loansin 24 hours That Will Leave You Like Now Is Incredible Snapcap.com Speechless Definition History Fanatic McCullough who played on Live and Let Die Bond theme dies aged 72 Remembering his pal Bargain shopper! Dre Barrymore sports colorful silk jacket as she loads up a trolley with knick-knacks at tlea market She's a mom-of-two ‘Actually done!’ Arial Winter arrives to her high school graduation ceremony In form-fitting nude dress Alandmark day for the 18-year-old actress Kevin Hart has $500k af possassions stolen as thieves raid his LA home while he's away in Miami Break-in at his Tarzana home over the weekend ‘Nothing makes me happier’: Alyssa Milano reunites with Who's The Boss? co-star Judith Light... 24 yoars after the show ended Catching up No show: Mets pitcher Bartolo Colon skips court hearing over dispute with once-secret ex-girlfriend and their two love children ‘Tve embraced the Bi/Queer label lately’: Matilda star Mara Wilson reveals her sexuality on Twitter Also starred in Mrs Doubifire Prettiest delivery girl aver! Makeup-tree Heidi Klum, 43, carries three large coffees in NYC after revealing beau Vito gifted her 10 dozen red roses Sizzling Katie Holmes gives a rare glimpse at her sultry side as she poses nude in gorgeous throwback snaps from jewelry campaign She is 37 A Givenchy girl! Model Lily Aldridge steps out in $1,250 designer SWEATSHIRT as she shows off slim lags in NYG Victoria's Sacret Angel hitp:/Avww.dailymail.co,uk/news/article-1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him.html 8/34 HOUSE_OVERSIGHT_014667

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Case 1:15-cv-07433-RWS Document 539-2 Filed 01/06/17 Page 2 of 5 6/15/2016 Bill Clinton and the 15-year-old 'masseuse': | met him twice, claims Epstein's girl | Daily Mail Online y com Home | U.K. Sports | U.S. Showbiz | Australia | Femail | Health | Science | Money | Video | Travel | Columnists Teenage girl recruited by paedophile Jeffrey | [ | Epstein reveals how she twice met Bill Clinton By SHARON CHURCHER and POLLY DUNBAR FOR MAILONLINE UPDATED: 19:53 EST, § March 2011 24 View comments As a New Yorker from humble beginnings, Jeffrey Epstein played on his blue-collar credentials and enormous wealth to extend tentacles of influence throughout America’s liberal political elite. During the outcry over the Epstein case, it emerged that another man with a notorious appetite for young women, Bill Clinton, travelled with Epstein to a number of destinations, including three times on the billionaire’s private aircraft. On one occasion, Epstein flew the former President, Hollywood actor and staunch Democrat Kevin Spacey and another actor friend of Mr Clinton’s, Chris Tucker, to Africa, to ‘discuss AIDS policy’. Epstein, who has donated more than £75,000 over the years to candidates from the Democratic Party, also flew with Mr Clinton in November 2003 to destinations including Russia, Oslo, Hong Kong, Shanghai and Beijing. Yet Virginia Roberts stresses that she was never ‘lent out’ to Mr Clinton. On one occasion, she adds, Epstein did invite two young brunettes to a dinner which he gave on his Caribbean island for Mr Clinton shortly after he left office. But, as far as she knows, the ex-President did not take the bait. ‘I'd have been about 17 at the time,’ she says. ‘I flew to the Caribbean with Jeffrey and then Ghislaine Maxweil went to pick up Bill in a huge black helicopter that Jeffrey had bought her. out’ SHARE THIS RELATED ARTICLES ARTICLE FBI to reopen case = Epstein’s Girl Friday http:/Awww.dailym ail.co.uk/news/article- 1363452/Bill-Clinton- 15-year-old-masseuse-|-met-twice-claims-Epsteins-girl.htm! 1/31 HOUSE_OVERSIGHT_014669

Case 1:15-cv-07433-RWS Document 539-2 Filed 01/06/17 Page 3of5 6/15/2016 against sex offender friand of Prince... ‘fixer’: Dead tycoon's daughter... ‘She'd always wanted to fly and Jeffrey paid for her to take lessons, and | remember she was very excited because she got her licence around the first year we met. ‘Lused to get frightened flying with her but Bill had the Secret Service with him and | remember him talking about what a good job she did. ‘Lonly ever met Bill twice but Jeffrey had told me that they were good friends. ‘Lasked, “How come?” and he laughed and said, “He owes me some favours.” Maybe he was just joking but it constantly surprised me that people with as much to lose as Bill and [Prince] Andrew weren't more careful. ‘Bill must have known about Jeffrey's girls. There were three desks in the living area of the villa on the island. Speaking out: : Virginia, now aged 26, in her new home i in Australia ‘They were covered with pictures of Jeffrey shaking hands with famous peapls 3 ant photos oh neKea girls, including one of me that Jeffrey had at all his houses, lying in a hammock. ‘We all dined together that night. Jeffrey was at the head of the table. Bill was at his left. | sat across from him. Emmy Tayler, Ghislaine’s blonde British assistant, sat at my right. ‘Ghislaine was at Bill's left and at the left of Ghislaine there were two olive-skinned brunettes who'd flown in with us from New York. ‘I'd never met them before. I'd say they were no older than 17, very innocent-looking. ‘They weren't there for me. They weren't there for Jeffrey or Ghislaine because | was there to have sex with Jeffrey on the trip. ‘Maybe Jeffrey thought they would entertain Bill, but | saw no evidence that he was interested in them. He and Jeffrey and Ghislaine seemed to have a very good relationship. Bill was very funny. ‘He made me laugh a few times. And he and ‘Bill must have known about Jeffrey and Ghislaine told blokey jokes and the lant brunettes listened politely and giggled. Jeffrey Ss girls. There were three desks in the living area of the ‘After dinner | gave Jeffrey an erotic massage. | . ° . don’t remember seeing Bill again on the trip but ~~ Villa on the island... covered with photos of naked girls’ | assume Ghislaine flew him back.’ According to prison records, when Epstein was serving his jail term, his visitors included a long- time — and highly controversial — Clinton acquaintance, Arnold Prosperi. ‘In the final hours of the Clinton presidency, in January 2001, Prosperi was facing three years in prison after being convicted of tax fraud. Mr Clinton commuted his sentence to house arrest. ‘Clinton, Prosperi and Epstein make an odd threesome on the face of it,’ says a law enforcement source. ‘Was Prosperi visiting Epstein as some kind of intermediary for Bill? ‘Maybe Bill wanted to know if Epstein knew anything that could embarrass him. Or did Bill commute Prosperi’s sentence as some kind of favour for Epstein?’ Virginia disclosed that Mr Clinton’s vice-president Al Gore and his wife, Tipper, were also guests of Epstein on his island. Case 1:15! GrO Tash VES 0 Dercerrne rit 2 Hb Bicokz pings SEMI] OMe Grind 5 Cambridge can't contain her excitermant as her horse wins at Royal Ascot races Whooped and cheered CONFIRMED: Nicola Brown Simpson DID have an affair with OJ's best friend Marcus Allen -and OJ ‘threatened to kill her if she saw him again... one month before her death’ ‘I've been doing him forever:' Awkward moment Sonja Morgan discovers Luann de Lesseps’ ‘soul mata’ is her old ‘hook up’ Thomas D'Agostino She really IS a lady in waiting! Amelia Windsor ~ Tatler’s most beautiful royal - swaps high glamour for WAITRESSING as she helps out at a launch New beau? Ashley Olsen, 30, is romantically linked to artist George Condo, 59, alter they are spotted ‘looking romantic’ at NYC's Mercer Hotel Dad bod! Adam Sandler, 49, shows off his naked chest while wrapped in towal during Miami vacation with his wife of 13 years Couple looked blissful Kim Kardashian’s naked ambition is taid bare again as she strips off to celebrate her post- baby body with GQ cover Gave birth in December Kake-gate! Kim Kardashian tries to cheat on family cake makers Hansan's by asking her followers for new bakery recommendations ‘lworked my a** off: Kim Kardashian spills secrets to losing 60lbs after pregnancy as she admits Gam gym sessions and ‘militant diet’ did trick Advertisement http//Avww.dailymail.co.uk/news/article-1363452/Bill-Clinton- 15-year-old-masseuse-l-met-twice-claims-Epsteins-girl.htm! 2/31 HOUSE_OVERSIGHT_014670

8/15/2016 Case 1:18) (BP FRIES Ol yercepene hin R Hie. $GicoFipines BEMBVAG! OMyyed Ghigb 5 » AFP/Getty Images Guests: Virginia says she also mot former Vico President Ai Gore, pictured right with Mr Clinton Last summer, the Gores abruptly announced that they were ending their supposedly fairytale marriage and, just weeks later, it emerged that Mr Gore — the famously sanctimonious global- warming disciple ~ had been accused of trying to force sex on a woman with whom he had booked a therapeutic massage at an Oregon hotel. ‘Lhad no clue that anything was up,’ Virginia says. ‘The Gores seemed like a beautiful couple when | ‘We just want them to met them. All| knew was that Mr Gore was a friend of Jeffrey’s and Ghislaine’s. Jeffrey didn'task me have anormal life’. to give him a massage. Blake Lively reveals her parenthood plans now ‘There might have been a couple of other girls there on that trip but | could never have imagined this _—that baby no.2 is onits guy would do anything wrong. | was planning to vote for him when | turned 18. | thought he was way and why she fell in awesome.’ love with Ryan Reynolds Virginia said that yet another American liberal icon, President Obama's Middie East peace envoy Senator George Mitchell, frequently visited Epstein’s New York residence. ene be Miley yrus and Liam Mr Mitchell, aged 77 ~ who previously led America’s Northern ireland peace initiative — ‘was very Hemsworth temporarily close to Jeffrey,’ Virginia recalled. ‘He is very clean-cut. You wouldn't think of him being part of go their separate ways. Jeffrey's crew.’ atter very public dinner date in NYG Ivanka Trump shares morning snap of baby Theo watching her get ready as she admits in that she wakes up at 6:30am and goes to work with her hair wet They couid be sisters! Princess Mary of Denmark and Duchess of Cambridge look strikingly similar as they enjoy a catch up at Royal Ascot Brooke Shields’ stalker GRINS walking into court with trial entering third day after Judge hears actress's tearful testimony about man coming to her home Mixing business with t ™ Richard Young pleasure! Bodysuit-clad : : sas EJ Johnson gets in Scandal: U.S. authorities want to interview Jeffrey Epstein (left) and may wish to quiz his friend, Prince Andrew some retail therapy aoe nsnntinien es nuntsantninvaranne nes recent nl ne arn ene raster rare auaanetnti memes efoeg filming his yat-4o- Epstein’s contacts book contains a work and a home telephone number for the senator. air New York reality , hi Another acquaintance was Israel defence secretary Ehud Barak, whose spokesman told The Mail anew on Sunday: ‘Mr Barak did attend several small functions in Mr Epstein’s home in New York that were vers ’bana? usually attended by leading businessman, university presidents, Nobel Prize Laureates and ze all nee prominent public figures.’ ontitnlor Night 9 hitp:/Avww.dailymail.co.uk/news/article-1363452/Bill-Clintor- 15-year-old-masseuse-|-met-twice-claims-Epsteins-girt.htm! 3/31 HOUSE_OVERSIGHT_014671

6/15/2016 Epstein’s many Hollywood pals include Matt Groening, creator of The Simpsons. ‘Jeffrey once had me give Matt a foot massage when he was flying on the jet with us,’ Virginia says. ‘He laughed and did drawings of Bart and Homer for my little brother and my dad. ‘lL also met Naomi Campbell at a birthday party of hers on a yacht in the South of France. She is a friend of Ghislaine’s but she was a real bitch to me. "She was very fake. She turned away from me when we were introduced by Ghislaine and Jeffrey. ‘Donald Trump was aiso a good friend of Jeffrey's. He didn’t partake in sex with any of us but he flirted with me. He'd laugh and tell Jeffrey, “You've got the life.” ' Palm Beach Police say Epstein seemed utterly unfazed by the allegations against him when they began their long and detailed investigation. ‘Jeffrey's craw: Middle East peace envoy George Mitchell, right, pictured with President Barack Obama and But he also took his defence very seriously indeed. Epstein engaged his friend, the Harvard law professor Alan Dershowitz — whose celebrity clients have included Mike Tyson, Patty Hearst, Claus von Bulow and O.J. Simpson ~ to run his legal defence. He aiso employed a firm of private investigators to investigate the backgrounds of the girls. Detectives painstakingly built a case which they believed showed that Epstein systematically paid teenage girls to recruit other teenage girls to his sex ring. However, as the investigation continued, they found that Epstein’s team had already spoken to key witnesses, suggesting that the financier would reward those who helped him. In addition, Epstein's defence team agreed to the unusual move of suggesting that the alleged victims sue Epstein in the civil courts. The result was a plea bargain in which Epstein admitted a single charge of soliciting an underage girl for prostitution ~ a deal which infuriated many police officers who worked on the case. More than 20 of Epstein’s girls are said to have sued him for damages. At least 17 have settled out of court. Mr Clinton, Mr Gore and Mr Mitchell were all contacted about their friendship with Epstein but declined to comment. Share or comment on this article hitp:/Avww.dailymail.co.uk/news/article-1363452/Bill-Clinton- 15-year-old-masseuse-|-met-twice-claims-Epsteins-girl html U.S. Secretary of State Hilary Clinton, frequently visited Epsteings New York residence, Virginia also claims Case 1:15-cv-07433-RWS Document 539-2 Filed 01/06/17 Page5of5 Case 1:15 Gyo 7ahehs RWS oC yercerraerin 2 Hie sGicer pings BG I/9:6! Depa! Spline 5 show - but admits the presidential hopeful wasn't going to come on anyway WITS Real Housewives of Beverly Hills to ‘bring back privacy’ to her life after dramatic season that documented her divorce and accusations she was faking iliness Victoria Beckham shows a hint of sideboob and flash of leg as she flaunts her sartorial sass for cover of Vogue Korea Striking shoot A mellow day! Rumer Willis dresses downina grey maxi dress as she hangs out with a friend in West Hollywood Taking a break from the presidential campaign Catherine Zeta-Jones’ daughter Carys is her doppelganger as the pair arrive in London with Michael Douglas and son Dylan Family trip Stephen Colbert compares Trump toa NAZI as he draws a swastika on chalkboard while trying to ‘figure out’ Obama’s response to Orlando massacre Grieving Adam Levine is pictured playing golf in first outing since Christina Grimmie's death... after offering to pay for the Voice star’s funeral Does North West have her own glam squad? Kim Kardashian ‘hires daughter $5k a week team including hairstylist and manicurist’ The smile’s back! Demi Lovato appears happy at airport while looking chic in olive coat as she recovers from Wilmer Valderrama shock split Wore classic combo ‘Fm not killing off Harrigon Ford’: Steven Spielberg reveals he won't end Indiana Jonas’ life in next film as he gives rare interview Good news for Ford! HOUSE_OVERSIGHT_014672

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Case 1:15-cv-07433-RWS Document 539-3 Filed 01/06/17 Page 2 of 2 a ; Share this P R Hub Subscribe by Email... page Breaking News | Entertainment | Sports | Business | Politics | Science | Technology | Odd News | Health | Law More Older News SMTWT FS 20 2122 23 24 25 26 2728 1234 5 Getiton 6 78910 1 12 LONDON, March 10, 2011 - Ghislaine Maxwell denies the 4 Googie’ play various allegations about her that have appeared recently in the media. These allegations are all entirely false. Statement on Behalf of Ghislaine , TYORS, PRNE RCH g. 2044 It is unacceptable that letters sent by Ms Maxwell's legal representatives to certain newspapers pointing out the truth Ee and asking for f.-Linda Craft the allegations to be withdrawn have simply been ignored. © 41016-569-3956 MOBILE In the circumstances, Ms Maxwell is now proceeding to take legal action against those newspapers. "I understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage, “why let the truth get in the way of a good story.” However, the allegations made against me are abhorrent and entirely untrue and I ask that they stop,” said Ghislaine Maxwell. Record call “A number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. Iam now taking action to clear my name," she said. Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-251 Email: [email protected] Media contact: Ross Gow, Acuity Reputation, Tel: +44-203- 008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com tiled under: Government and Policy, Law, Media ‘Vags: Devonshires Solicitors, London, March 10, United Kingdom GOVERNMENT AND POLICY .- MARCH to NEWS ~~ NEWS CSA Group Selecis Frankfurt, Germany for Tech Mahindra Opens a new European Headquarters new Development Centre in Bonn, The First International Gateway to Africa Conference in Geneva: Africa's Challenges Today and Tomorrow Website Optimisation Central Saint Martins and Method Launch 7 gos aes arketing ‘Accelerator to Drive Innovation and Support UK Economic Growth Sir Paul McCartney Supports BUAV North East Lincolnshire Council Campaign toendCruel * Emplovees' Ideas Win Votes ampaign fo endl rue EXHIBIT 4 Giuttre. AGREN BLANDO REPORTING 5/alie KAM Germany GTUFFRE00 1067 HOUSE_OVERSIGHT_014674

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Case 9:6ase-doFeeKarsBbd eR aaumentieaaonhiied 9 Weeldet oFage2 26 1 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:08-CV-80736-KAM JANE DOE | and JANE DOE 2, Petitioners, VS. UNITED STATES OF AMERICA, Respondent. / ORDER DENYING PETITIONERS’ MOTION TO JOIN UNDER RULE 21 AND MOTION TO AMEND UNDER RULE 15 This cause is before the Court on Jane Doe 3 and Jane Doe 4’s Corrected Motion Pursuant to Rule 21 for Joinder in Action (“Rule 21 Motion”) (DE 280), and Jane Doe 1 and Jane Doe 2’s Protective Motion Pursuant to Rule 15 to Amend Their Pleadings to Conform to Existing Evidence and to Add Jane Doe 3 and Jane Doe 4 as Petitioners (“Rule 15 Motion”) (DE 311). Both motions are ripe for review. For the following reasons, the Court concludes that they should be denied. I. Background This is an action by two unnamed petitioners, Jane Doe | and Jane Doe 2, seeking to prosecute a claim under the Crime Victims’ Rights Act (CVRA), 18 U.S.C. § 3771. (DE 1). Generally, they allege that the respondent Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein, who subjected them to various sexual crimes while they were minors. (Id.). Petitioners initiated this action in July 2008. (Id.). GIUFFRE002844 HOUSE_OVERSIGHT_014677

Case 9:08a8e doF SO KAAS BEA er? QoumentiaaSdonted 9 Heeket oF age28 of 1 Page 2 of 10 On December 30, 2014, two other unnamed victims, Jane Doe 3 and Jane Doe 4, moved to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280). Petitioners (Jane Doe | and Jane Doe 2) support the Rule 21 Motion. (Id. at 11). Jane Doe 3 and Jane Doe 4 argue that they “have suffered the same violations of their rights under the [CVRA] as the” Petitioners, and they “desire to join in this action to vindicate their rights as well.” (Id. at 1). The Government vehemently opposes joinder under Rule 21. (DE 290). The Government argues that Rule 15 is the proper procedural device for adding parties to an action, not Rule 21. (Id. at 1). “[O]Jut of an abundance of caution,” Petitioners filed a motion to amend their petition under Rule 15, conforming the petition to the evidence and adding Jane Doe 3 and Jane Doe 4 as petitioners. (DE 311 at 2). The Government opposes the Rule 15 Motion as well. (DE 314). Among other things, the Government argues that amending the petition to include Jane Doe 3 and Jane Doe 4 should be denied because of their undue delay in seeking to join the proceedings, and the undue prejudice that amendment will cause. (Id.). After considering the parties’ submissions and the proposed amended petition, the Court finds that justice does not require amendment in this instance and exercises its discretion to deny the amendment. IL. Discussion “The decision whether to grant leave to amend a complaint is within the sole discretion of the district court.” Laurie v. Ala. Ct. Crim. Apps., 256 F.3d 1266, 1274 (11th Cir. 2001). “The court should freely give leave when justice so requires.” Fed. R. Civ. P. 15(a)(2). Justice does not require amendment in several instances, “includ[ing] undue delay, bad faith, dilatory motive GIUFFRE002845 HOUSE_OVERSIGHT_014678

Case 9:6ase-doFeeKardsBbis eR aaumentieaaon tied 9 Weeldet oFage2b 26 1 Page 3 of 10 on the part of the movant, . . . undue prejudice to the opposing party by virtue of allowance of the amendment, [and] futility of amendment.’” Laurie, 256 F.3d at 1274 (quoting Foman v. Davis, 371 U.S. 178, 182 (1962)). In addition to considering the effect of amendment on the parties, the court must consider “the importance of the amendment on the proper determination of the merits of a dispute.” 6 Wright & Miller, Fed. Prac. & Fed. P. § 1488, p. 814 (3d ed. 2010). Justice does not require amendment where the addition of parties with duplicative claims will not materially advance the resolution of the litigation on the merits. See Herring v. Delta Air Lines, Inc., 894 F.2d 1020, 1024 (9th Cir. 1989). A. Rule 21 Motion Jane Doe 3 and Jane Doe 4’s first attempt to join in this proceeding was brought under Rule 21. (DE 280). “If parties seek to add a party under Rule 21, courts generally use the standard of Rule 15, governing amendments to pleadings, to determine whether to allow the addition.” 12 Wright & Miller, Fed. Prac. & Fed. P., p. 432 (3d ed. 2013); see also Galustian v. Peter, 591 F.3d 724, 729-30 (4th Cir. 2010) (collecting cases and noting that Rule 15(a) applies to amendments seeking to add parties); Frank v. U.S. West, Inc., 3 F.3d 1357, 1365 (10th Cir. 1993) (“A motion to add a party 1s governed by Fed. R. Civ. P. 15a)... .”). Rule 21, “Misjoinder and Non-joinder of Parties,” provides the court with a tool for correcting the “misjoinder” of parties that would otherwise result in dismissal. Fed. R. Civ. P. 21. Insofar as Rule 21 “relates to the addition of parties, it 1s intended to permit the bringing in of a person, who through inadvertence, mistake or for some other reason, had not been made a party and whose presence as a party is later found necessary or desirable.” United States v. Com. Bank of N. Am., 31 F.R.D. 133, 135 (S.D.N.Y. 1962) (internal quotation marks omitted). GIUFFRE002846 HOUSE_OVERSIGHT_014679

Case 9:6ase-doFeeKardsBbd eR aaumentieaaon tied 9 Weeldet oF ages 26 1 Page 4 of 10 In their Rule 21 Motion, Jane Doe 3 and Jane Doe 4 do not claim that they were omitted from this proceeding due to any “inadvertence” or “mistake” by Petitioners; rather, they seek to join this proceeding as parties that could have been permissively joined in the original petition under Rule 20 (“Permissive Joinder of Parties”). As courts generally use the standards of Rule 15 to evaluate such circumstances, the Court will consider the joinder issue as presented in the Rule 15 Motion.’ The Court will consider the arguments presented in the Rule 21 Motion as if they are set forth in the Rule 15 Motion as well. Because the arguments are presented in the Rule 15 Motion (and because the Court is denying the Rule 15 Motion on its merits, as discussed below), the Rule 21 Motion will be denied. The Court also concludes that portions of the Rule 21 Motion and related filings should be stricken from the record. Pending for this Court’s consideration is a Motion for Limited Intervention filed by Alan M. Dershowitz, who seeks to intervene to “strike the outrageous and impertinent allegations made against him and [to] request[] a show cause order to the attorneys that have made them.” (DE 282 at 1). The Court has considered Mr. Dershowitz’s arguments, but it finds that his intervention is unnecessary as Federal Rule of Civil Procedure 12(f) empowers the Court “on its own” to “strike from a pleading an insufficient defense or any redundant, immaterial, impertinent, or scandalous matter.” Fed. R. Civ. P. 12(f). Petitioners’ Rule 21 Motion consists of relatively little argumentation regarding why the Court should permit them to join in this action: they argue that (1) they were sexually abused by ' The Court notes that, regardless of which motion it considers, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 GIUFFRE002847 HOUSE_OVERSIGHT_014680

Case 9:6ase-doFeeKarsBbs eR aaumentieaaoniied 9 Weeldet oF age 26 1 Page 5 of 10 Jeffrey Epstein, and (2) the Government violated their CVRA rights by concealing the non- prosecution agreement with them. (DE 280 at 3; see id. at 7-8). However, the bulk of the Rule 21 Motion consists of copious factual details that Jane Doe 3 and Jane Doe 4 “would prove” “[ilf allowed to join this action.” (Id. at 3, 7). Specifically, Jane Doe 3 proffers that she could prove the circumstances under which a non-party introduced her to Mr. Epstein, and how Mr. Epstein sexually trafficked her to several high-profile non-party individuals, “including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.” (Id. at 3-6). She names several individuals, and she offers details about the type of sex acts performed and where they took place. (See id. at 5) At this juncture in the proceedings, these lurid details are unnecessary to the determination of whether Jane Doe 3 and Jane Doe 4 should be permitted to join Petitioners’ claim that the Government violated their rights under the CVRA. The factual details regarding with whom and where the Jane Does engaged in sexual activities are immaterial and impertinent to this central claim (i.e., that they were known victims of Mr. Epstein and the Government owed them CVRA duties), especially considering that these details involve non-parties who are not related to the respondent Government. These unnecessary details shall be stricken. The original Rule 21 Motion (DE 279) shall be stricken in its entirety, as it is wholly superseded by the “corrected” version of the Rule 21 Motion (DE 280). From the corrected Rule 21 Motion, the Court shall strike all factual details regarding Jane Doe 3 between the following sentences: “The Government then concealed from Jane Doe #3 the existence of its NPA from > Jane Doe 4’s proffer is limited to sexual acts between Mr. Epstein and herself. (See DE 280 at 7-8). GIUFFRE002848 HOUSE_OVERSIGHT_014681

Case 9:8ase-doPeeKaMdsSbs eR aaumentieaaoniied 9 Weeldet oF age20 26 1 Page 6 of 10 Jane Doe #3, in violation of her rights under the CVRA” (id. at 3); and “The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it listed her as a victim in the attachment to the NPA” (id. at 6). As none of Jane Doe 4’s factual details relate to non-parties, the Court finds it unnecessary to strike the portion of the Rule 21 Motion related to her circumstances. Regarding the Declaration in support of Petitioners’ response to Mr. Dershowitz’s motion to intervene (DE 291-1), the Court shall strike paragraphs 4, 5, 7, 11, 13, 15, 19 through 53, and 59, as they contain impertinent details regarding non-parties. Regarding the Declaration of Jane Doe 3 in support of the Rule 21 Motion (DE 310-1), the Court shall strike paragraphs 7 through 12, 16, 39, and 49, as they contain impertinent details regarding non- parties. Jane Doe 3 1s free to reassert these factual details through proper evidentiary proof, should Petitioners demonstrate a good faith basis for believing that such details are pertinent to a matter presented for the Court’s consideration. As mentioned, Mr. Dershowitz moves to intervene “for the limited purposes of moving to strike the outrageous and impertinent allegations made against him and requesting a show cause order to the attorneys that have made them.” (DE 282 at 1). As the Court has taken it upon itself to strike the impertinent factual details from the Rule 21 Motion and related filings, the Court concludes that Mr. Derschowitz’s intervention in this case is unnecessary. Accordingly, his motion to intervene will be denied as moot.? Regarding whether a show cause order should * This also moots Mr. Dershowitz’s Motion for Leave to File Supplemental Reply in Support of Motion for Limited Intervention. (DE 317). Denying Mr. Dershowitz’s motion to intervene also renders moot Petitioners’ motion (DE 292) to file a sealed document supporting its response to Mr. Dershowitz’s motion. It will accordingly be denied as moot, and DE 293 (the sealed response) will be stricken from the record. GIUFFRE002849 HOUSE_OVERSIGHT_014682

Case 9:08a8e doFSOKAKAS BEA er? QumentiaaSdonted 9 Heeket oP age28 of 1 Page 7 of 10 issue, the Court finds that its action of striking the lurid details from Petitioners’ submissions is sanction enough. However, the Court cautions that all counsel are subject to Rule 11’s mandate that all submissions be presented for a proper purpose and factual contentions have evidentiary support, Fed. R. Civ. P. 11(b)(1) and (3), and that the Court may, on its own, strike from any pleading “any redundant, immaterial, impertinent, or scandalous matter,” Fed. R. Civ. P. 12(f). B. Rule 15 Motion Between their two motions (the Rule 21 Motion and Rule 15 Motion), Jane Doe 3 and Jane Doe 4 assert that “they desire to join in this action to vindicate their rights [under the CVRA] as well.” (DE 280 at 1). Although Petitioners already seek the invalidation of Mr. Epstein’s non-prosecution agreement on behalf of all “other similarly-situated victims” (DE 189 at 1; DE 311 at 2, 12, 15, 18-19), Jane Doe 3 and Jane Doe 4 argue that they should be fellow travelers in this pursuit, lest they “be forced to file a separate suit raising their claims” resulting in “duplicative litigation” (DE 280 at 11). The Court finds that justice does not require adding new parties this late in the proceedings who will raise claims that are admittedly “duplicative” of the claims already presented by Petitioners. The Does’ submissions demonstrate that it is entirely unnecessary for Jane Doe 3 and Jane Doe 4 to proceed as parties in this action, rather than as fact witnesses available to offer relevant, admissible, and non-cumulative testimony. (See, e.g., DE 280 at 2 (Jane Doe 3 and Jane Doe 4 “are in many respects similarly situated to the current victims”), 9 (“The new victims will establish at trial that the Government violated their CVRA rights in the same way as it violated the rights of the other victims.”), 10 (Jane Doe 3 and Jane Doe 4 “will simply join in motions that the current victims were going to file in any event.”), 11 (litigating Jane Doe 3 and GIUFFRE002850 HOUSE_OVERSIGHT_014683

Case 9:6ase-doPeeKardsDbd eR aaumentieaaron tied 9 Heeldet oF age 26 1 Page 8 of 10 Jane Doe 4’s claims would be “duplicative”); DE 298 at 1 n.1 (“As promised . . . Jane Doe No. 3 and Jane Doe No. 4 do not seek to expand the number of pleadings filed in this case. If allowed to join this action, they would simply support the pleadings already being filed by Jane Doe No. 1 and Jane Doe No. 2.”); DE 311 at 5 n.3 (“[A]II four victims (represented by the same legal counsel) intend to coordinate efforts and avoid duplicative pleadings.”), 15 (Jane Doe 3 and Jane Doe 4 “challenge the same secret agreement 1.e., the NPA that the Government executed with Epstein and then concealed from the victims. This is made clear by the proposed amendment itself, in which all four victims simply allege the same general facts.”)). As the Does argue at length in their Rule 15 Motion, Jane Doe 1’s original petition “specifically allege[s] that the Government was violating not only her rights but the rights of other similarly-situated victims.” (DE 311 at 2). The Court fails to see why the addition of “other similarly-situated victims” is now necessary to “vindicate their rights as well.” (DE 280 at 1). Of course, Jane Doe 3 and Jane Doe 4 can participate in this litigated effort to vindicate the rights of similarly situated victims there is no requirement that the evidentiary proof submitted in this case come only from the named parties. Petitioners point out as much, noting that, regardless of whether this Court grants the Rule 15 Motion, “they will call Jane Doe No. 3 as a witness at any trial.” (DE 311 at 17 n.7). The necessary “participation” of Jane Doe 3 and Jane Doe 4 in this case can be satisfied by offering their properly supported and relevant, admissible, and non-cumulative testimony as needed, whether through testimony at trial (see DE 280 at 9) or affidavits submitted to support the relevancy of discovery requests’ (see * The non-party Jane Does clearly understand how to submit affidavits. (See DEs 291-1, 310-1). GIUFFRE002851 HOUSE_OVERSIGHT_014684

Case 9:Gase-bd PaevOKS ERM cRegumenhesee of HeGOLINGLE: Ragr/AOiof Ibage 9 of 10 id. at 10). Petitioners do not contend that Jane Doe 3 and Jane Doe 4’s “participation in this case” can only be achieved by listing them as parties. As it stands under the original petition, the merits of this case will be decided based on a determination of whether the Government violated the rights of Jane Doe 1, Jane Doe 2, and all “other similarly situated victims” under the CVRA. Jane Doe 3 and Jane Doe 4 may offer relevant, admissible, and non-cumulative evidence that advances that determination, but their participation as listed parties is not necessary in that regard. See Herring, 894 F.2d at 1024 (District court did not abuse its discretion by denying amendment where “addition of more plaintiffs .. . would not have affected the issues underlying the grant of summary judgment.”); cf. Arthur v. Stern, 2008 WL 2620116, at *7 (S.D. Tex. 2008) (Under Rule 15, “courts have held that leave to amend to assert a claim already at issue in [another lawsuit] should not be granted if the same parties are involved, the same substantive claim is raised, and the same relief is sought.”)” And, as to Jane Doe 4 at least, adding her as a party raises unnecessary questions about whether she is a proper party to this action.® Petitioners also admit that amending the petition to conform to the evidence by including references to the non-prosecution agreement itself is “unnecessary” as the “existing petition is broad enough to cover the developing evidence in this case.” (DE 311). The Court > The Court expresses no opinion at this time whether any of the attestations made by Jane Doe 3 and Jane Doe 4 in support of their motion will be relevant, admissible, and non- cumulative. ° The Government contends that Jane Doe 4 is not a true “victim” in this case because she was not known at the time the Government negotiated the non-prosecution agreement, and accordingly she was not entitled to notification rights under the CVRA. (See DE 290 at 10). Any “duplicative” litigation filed by Jane Doe 4 would necessarily raise the issue of whether she has standing under the CVRA under these circumstances. 9 GIUFFRE002852 HOUSE_OVERSIGHT_014685

Case 9:06ase- doPeeKaMAsBrs eR acumenteaaonAted 9 Deeldt oFage2bof age 10 of 10 agrees, and it concludes that justice does not require amending the petition this late in the proceedings. Ill. Conclusion Accordingly, it is hereby ORDERED AND ADJUDGED as follows: the Rule 21 Motion (DE 280) is DENIED; the Rule 15 Motion (DE 311) is DENIED; Intervenor Dershowitz’s Motion for Limited Intervention (DE 282) and Motion for Leave to File Supplemental Reply in Support of Motion for Limited Intervention (DE 317) are DENIED AS MOOT; Petitioners’ Motion to Seal (DE 292) is DENIED AS MOOT; the following materials are hereby STRICKEN from the record: . DE 279, in its entirety. . DE 280, all sentences between the following sentences: “The Government then concealed from Jane Doe #3 the existence of its NPA from Jane Doe #3, in violation of her rights under the CVRA” (DE 280 at 3); and “The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it listed her as a victim in the attachment to the NPA” (DE 280 at 6). . DE 291-1, paragraphs 4, 5, 7, 11, 13, 15, 19 through 53, and 59. . DE 310-1, paragraphs 7 through 12, 16, 39, and 49. . DE 293, in its entirety. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 6" day of April, 2015. ea fo “in KENNETH A. MARRA United States District Judge 10 GIUFFRE002853 HOUSE_OVERSIGHT_014686

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Case 1:15-cv-07433-RWS Document 539-6 Filed 01/06/17 Page 2 of 2 From: <[email protected]> Date: 2 January 2015 at 20:38 Subject: Ghislaine Maxwell To: Rossacuity Gow <[email protected]> bcc: [email protected], P,[email protected], [email protected], [email protected], [email protected], [email protected] To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is Virginia Roberts - so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts that Alan Derschowitz is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. Sent from my BlackBerry® wireless device g EXHIBIT ; Mawel] 10 fi O2-I (oom es GM_00068 HOUSE_OVERSIGHT_014688

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a Case 1:15-cv-07433-RW AIS DEINE EP on Shs Page 2 of 4 In compliance with Chapter 617, F.S., (Not for Profit) ARTICLE I NAME The name of the corporation shall be: Victims Refuse Silence, Inc. ARTICLE IT ____ PRINCIPAL OFFICE Principal street address: Mailing address, if different is: 425 North Andrews Ave. Suite 2 Fort Lauderdale, FL 33301 ARTICLE WT __ PURPOSE : — ._,... Victims Refuse Silence, Inc. is organized exclusively for charitable and The purpose for which the corporation is organized is: educational purposes including, for such purposes, the making of distributions to organizations that qualify as exempt organizations under section 504 (c)(3) of the Internal Revenue Code, or the corresponding section of any future federal tax code. The corporation is organized to provide assistance to victims of sexual abuse as well as victims of human trafficking. Upon the dissolution of Victims Refuse Silence, Inc., assets shall be distributed for one or more exempt purpose within the meaning of section 501(c)(3) of the Internal Revenue Code, or corresponding section of any future federal tax code, or shall be distributed to the federal government, or to a state or local government, for a public purpose. ARTICLE IV ___ MANNER OF ELECTION ___The manner in which the directors are elected and appointed: The manner in which the directors are elected or appointed is provided in the bylaws of the Corporation. ARTICLE _V INITIAL OFFICERS AND/OR DIRECTORS Name and Tite. Virginia Roberts, Director Name and Title: den i A my en or Suite 2 S25 Fort Lauderdale, FL 33301 wae SS Name and Title: Bradley J. Edwards, Director Name and Title: on Sulte2 Fort Lauderdale, FL 33301 Brittany N. Henderson, Director ... and T Address: Name and Title: Suite 2 Fort Lauderdale, FL 33301 itle: Address: GIUFFRE001063 HOUSE_OVERSIGHT_014691

Case 1:15-cv-07433-RWS Document 539-8 Filed 01/06/17 Page 3 of 4 Name and Title. , Name and Title: Address Address: Name and Title: Name and Title: Address Address: ARTICLE VI___ REGISTERED AGENT The name and Florida street address (P.O. Box NOT acceptable) of the registered agent is: Bradley J. Edwards 425 North Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 Name: Address: ARTICLE VIT__INCORPORATOR -_ The name and address of the Incorporator is: ‘an He Brittany N. Henderson eS 425 North Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 Sé:cl Wd €2 330 4k fa Wes Name; Address: Having been named as registered agent to accept service of process for the above stated corporation at the place designated in this certificate, I a iliar with and accept S registered agent and agree to act in this capacity I2-/7-1¢ Date Required Signa gent i submit this document and affirm that the facts stated herein are true. 1 am aware that any false information submitted in a document to the Department of State constitutes a third degree felony as provided for in s.817.155, F.S. IZ TAG Required Signature of Incorporator Date GIUFFRE001064 HOUSE_OVERSIGHT_014692

2015 FLORIDA NOP FOR PROM T CORBORA TOR AMINE ANNUAle? CVO6/L7 Page fens 4 REPORT Apr 22, 2015 DOCUMENT# N14000011657 Secretary of State Entity Name: VICTIMS REFUSE SILENCE, INC. CC7801725405 Current Principal Place of Business: 425 NORTH ANDREWS AVE., SUITE 2 FORT LAUDERDALE, FL 33301 Current Mailing Address: 425 NORTH ANDREWS AVE., SUITE 2 FORT LAUDERDALE, FL 33301 FEI Number: 47-2627774 Certificate of Status Desired: Yes Name and Address of Current Registered Agent: EDWARDS, BRADLEY J 425 NORTH ANDREWS AVE., SUITE 2 FORT LAUDERDALE, FL 33301 US The above named entity submits this statement for the purpose of changing its registered office or registered agent, or both, in the State of Florida. SIGNATURE: Electronic Signature of Registered Agent Date Officer/Director Detail : Title PRESIDENT, DIRECTOR Title VP, DIRECTOR Name GIUFFRE, VIRGINIA L Name GARVIN, MARGARET A Address 425 NORTH ANDREWS AVE., SUITE 2 Address 425 NORTH ANDREWS AVE., SUITE 2 City-State-Zip: FFORTLAUDERDALE FL 33301 City-State-Zip: FORT LAUDERDALE FL 33301 Title SECRETARY, DIRECTOR Name HENDERSON, BRITTANY N Address 425 NORTH ANDREWS AVE., SUITE 2 City-State-Zip: FORTLAUDERDALE FL 33301 | hereby certify that the information indicated on this report or supplemental report is true and accurate and that my electronic signature shall have the same legal effect as if made under oath; that | am an officer or director of the corporation or the receiver or trustee empowered to execute this report as required by Chapter 617, Florida Statutes; and that my name appears above, or on an attachment with all other like empowered. SIGNATURE: BRITTANY N HENDERSON DIRECTOR 04/22/2015 Electronic Signature of Signing Officer/Director Detail Date GIUFFRE001065 HOUSE_OVERSIGHT_014693

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