Case 1:15-cv-07433-RWS Document 751 Filed 03/17/17 Page 1of5 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 Response in Opposition to Plaintiff's Omnibus Motion in Limine 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 Response in Opposition to Plaintiff's Omnibus Motion in Limine. 2. Attached as Exhibit A is a true and correct copy of a statement on behalf of Ms. Maxwell dated January 2, 2015. 3. Attached as Exhibit B 1s a true and correct copy of an article by Sharon Churcher titled “Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill Clinton,” DAILY MAIL, dated March 5, 2011. HOUSE_OVERSIGHT_014797

Case 1:15-cv-07433-RWS Document 751 Filed 03/17/17 Page 2 of 5 4. Attached as Exhibit C (filed under seal) are true and correct copies of 5. Attached as Exhibit D (filed under seal) are true and correct copies of 6. Attached as Exhibit E (filed under seal) are true and correct copies of [I 7. Attached as Exhibit F (filed under seal) is a true and correct copy of 8. Attached as Exhibit G is a true and correct copy of an article by Sharon Churcher titled “The Prince, a paedophile and the sex slave teen” The Daily Telegraph, dated February 28, 2011. 9. Attached as Exhibit H (filed under seal) is a true and correct copy of [i 10. Attached as Exhibit Tis a true and correct copy of an article titled “Buckingham Palace issues second denial of underage sex claims against Prince Andrew,” Fox News.com. 11. Attached as Exhibit J is a true and correct copy of an article titled “Prince Andrew denies sex abuse claims” CNN.com. HOUSE_OVERSIGHT_014798

Case 1:15-cv-07433-RWS Document 751 Filed 03/17/17 Page 3 of 5 12. Attached as Exhibit K is a true and correct copy of an article by Tom Leonard titled “Prince Andrew risks ambassador job as underage sex case girl reveals meeting him” DAILY MAIL, dated March 2, 2011. 13. Attached as Exhibit L 1s a true and correct copy of an article by Wills Robinson titled “Jeffrey Epstein ‘sex slave’ Virginia Roberts was a ‘money-hungry sex kitten’, ex friends claim” DAILY MAIL, dated March 1, 2015. 14. Attached as Exhibit M (filed under seal) are true and correct copies of [A 15. Attached as Exhibit N (filed under seal) is a true and correct copy of [A 16. Attached as Exhibit O (filed under seal) is a true and correct copy of J 17. Attached as Exhibit P (filed under seal) are true and correct copies 18. Attached as Exhibit Q (filed under seal) is a true and correct copy of [A 19. Attached as Exhibit R is a true and correct copy of a press release in the Edwards, et. al vy. Dershowitz matter, dated April 8, 2016, Bates stamped GM_00523-4. HOUSE_OVERSIGHT_014799

Case 1:15-cv-07433-RWS Document 751 Filed 03/17/17 Page 4 of 5 20. Attached as Exhibit S 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). I declare under penalty of perjury that the foregoing is true and correct. Executed on March 17, 2017. s/ Laura A. Menninger Laura A. Menninger HOUSE_OVERSIGHT_014800

Case 1:15-cv-07433-RWS Document 751 Filed 03/17/17 Page 5of5 CERTIFICATE OF SERVICE I certify that on March 17, 2017, I electronically served this Declaration of Laura A. Menninger in Support of Defendant's Response in Opposition to Plaintiff's Omnibus Motion in Limine 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] 2 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_014801

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Case 1:15-cv-07433-RWS Document 751-1 Filed 03/17/17 Page 2 of 2 From: <[email protected]> Date: 2 January 2015 at 20:38 Subject: Ghislaine Maxwell To: Rossacuity Gow <[email protected]> bec: [email protected], [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 GM_00068 HOUSE_OVERSIGHT_014803

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5/2/2016 Case 1:15-cVOP4Aa SSR Why PaWeRhiRsiTEY ABI evEaehaGBy Mpyelret BD Sito Of 8 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, 5 March 2011 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’. GM_00715 http:/Awww.dailymail.co.uk/news/article-1363452/Bill-Clinton-15-year-old-masseuse-I-met-twice-claims-Epsteins-girl.htm| 1/7 HOUSE_OVERSIGHT_014805

5/2/2016 Case 1:15-cVOP4aS SR Why aWeRhiRsiTEYABIAD evEaeaGBy Mpyelret BD Girtors Of 8 Claims: Virginia Roberts says she twice met ex-president Bill Clinton, pictured last month, but was never ‘lent out' 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. ‘Il’d have been about 17 at the time,’ she says. ‘I flew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill in a huge black helicopter that Jeffrey had bought her. Share this article Share‘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. ‘| used 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.‘l only ever met Bill twice but Jeffrey had told me that they were good friends. ‘| asked, “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 GM_00716 http:/Awww.dailymail.co.uk/news/article-1363452/Bill-Clinton-15-year-old-masseuse-I-met-twice-claims-Epsteins-girl.htm| 2/7 HOUSE_OVERSIGHT_014806

9/2/2016 Case 1:15-cTRsOFea BBR WESby PasdenhitrsiieyApstei2 revEdlshquGny wjgeiiyet BID Stinton, Of 8 careful. ‘Bill must have known about Jeffrey’s girls. There were three desks in the living area of the villa on the island. Se ee Speaking out: Virginia, now aged 26, in her new home in Australia "They were covered with pictures of Jeffrey shaking hands with famous people and photos of naked 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. ‘Bill must have known about Jeffrey’s girls. There were three desks in the living area of the villa on the island... covered with photos of naked girls' 'He made me laugh a few times. And he and Jeffrey and Ghislaine told blokey jokes and the brunettes listened politely and giggled. ‘After dinner | gave Jeffrey an erotic massage. | don’t remember seeing Bill again on the trip but | 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? GM_00717 http:/Awww.dailymail.co.uk/news/article-1363452/Bill-Clinton-15-year-old-masseuse-I-met-twice-claims-Epsteins-girl.htm| 3/7 HOUSE_OVERSIGHT_014807

9/2/2016 Case 1:15-cteOa BB-FRWESby PaMeNhirsiTeyABIaP evEdieguGay M7eITet BD StiytorS of 8 ‘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. © AFP/Getty Images Guests: Virginia says she also met former Vice President Al 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. ‘I had no clue that anything was up,’ Virginia says. ‘The Gores seemed like a beautiful couple when | met them. All | knew was that Mr Gore was a friend of Jeffrey’s and Ghislaine’s. Jeffrey didn’t ask me to give him a massage. ‘There might have been a couple of other girls there on that trip but | could never have imagined this guy would do anything wrong. | was planning to vote for him when | turned 18. | thought he was awesome. ’Virginia said that yet another American liberal icon, President Obama’s Middle East peace envoy Senator George Mitchell, frequently visited Epstein’s New York residence. Mr Mitchell, aged 77 — who previously led America’s Northern Ireland peace initiative — ‘was very close to Jeffrey,’ Virginia recalled. ‘He is very clean-cut. You wouldn’t think of him being part of Jeffrey’s crew.’ GM_00718 http:/Awww.dailymail.co.uk/news/article-1363452/Bill-Clinton-15-year-old-masseuse-I-met-twice-claims-Epsteins-girl.htm| 4/7 HOUSE_OVERSIGHT_014808

5/2/2016 Case 1:15-ciOP4aSSR Why PaWeRhiRsiieyABLeD evEaehdGBy Mpyelret BD Girtor6 Of 8 oo : . a © Richard Young / Hg Features GM_00719 http:/Awww.dailymail.co.uk/news/article-1363452/Bill-Clinton-15-year-old-masseuse-I-met-twice-claims-Epsteins-girl.htm| 5/7 HOUSE_OVERSIGHT_014809

5/2/2016 Case 1:15-cleHed BBqRWiESby Padephite, deff py /Apsteip revEdkechquGeag tweet BED £ A tiptori7 of 8 Scandal: U.S. authorities want to interview Jeffrey Epstein (left) and may wish to quiz his friend, Prince Andrew Epstein’s contacts book contains a work and a home telephone number for the senator. Another acquaintance was Israel defence secretary Ehud Barak, whose spokesman told The Mail on Sunday: ‘Mr Barak did attend several small functions in Mr Epstein’s home in New York that were usually attended by leading businessman, university presidents, Nobel Prize Laureates and prominent public figures.’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.‘Il 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 also 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 crew: Middle East peace envoy George Mitchell, right, pictured with President Barack Obama and U.S. Secretary of State Hilary Clinton, frequently visited Epsteings New York residence, Virginia also claims 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 also employed a firm of private investigators to GM_00720 http:/Awww.dailymail.co.uk/news/article-1363452/Bill-Clinton-15-year-old-masseuse-I-met-twice-claims-Epsteins-girl.htm| 6/7 HOUSE_OVERSIGHT_014810

9/2/2016 Case 1:15-cteOea BB-FRWESby PaMeNhinsiTeyABIa evEdieguGBy M7eITet BD Shytor’ of 8 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.|n 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. GM_00721 http:/Awww.dailymail.co.uk/news/article- 1363452/Bill-Clinton- 15-year-old-masseuse-I-met-twice-claims-Epsteins-girl.htm| 7/7 HOUSE_OVERSIGHT_014811

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aes Case 1:15-cv-07433I RWS. Derseni ene PSsEx FlaveeRa goes /ERAPM Page 2 of 3 Daily Telegraph The Prince, a paedophile and the sex slave teen Sharon Churcher and Chelsea White, DailyTelegraph February 28, 2011 6:00am A MOTHER of three living in Australia has revealed she was a teenage prostitute flown all over the world by a convicted sex offender to meet Prince Andrew. The revelations have rocked Buckingham Palace as the woman, Virginia Roberts, 27, confessed she was the minor identified in FBI and subsequent civil proceedings against wealthy financier and registered sex offender Jeffrey Epstein. A photo of Epstein and the Duke of York, Prince Andrew, together last week compelled Ms Roberts to come forward. First employed as a 15-year-old as Epstein's masseuse, she alleges he groomed her to become a prostitute, paying her for sex with him and his influential friends. While Ms Roberts said there was never any sexual relationship between the Prince and herself, she claims that as a 17-year-old she met the Prince on three occasions - at one of which she was told to sit on his knee while he touched another woman's breast. Pictures: Prince Andrew and Virginia Roberts Latest from Mail on Sunday Ms Roberts told London newspaper The Mail on Sunday she was first flown to England on a private jet to meet the Prince in March 2001. The 17-year-old was told to dance with the Prince and even posed for a photograph. For her time with Epstein and the Prince on that trip, Epstein paid her $US15,000. When she next met the Prince in the US, a 21-year-old woman who was working for Epstein was sitting on Prince Andrew's knee. Ms Roberts said she was instructed to do the same while the Prince touched the older woman's breast as a "joke". http:/Avww.dailytelegraph.com .au/the-prince-a-paedophile-and-the-sex-slave-teen/news-story/8cdeee961 a486febf459eafe00a7f710?sv=68c529bb044b9fdaSbi4f3... 1/2 HOUSE_OVERSIGHT_014817

aes Case 1:15-cv-074331 RWS. Dersenieane PSsEx FaveeRa goes /EReEM Page 3 of 3 The FBI case revealed sexual allegations by at least 20 girls, however, Epstein struck a deal with prosecutors and served 13 months' jail for soliciting child prostitution. Ms Roberts stayed working as Epstein's "masseuse" until she met an Australian martial arts expert named Robert. The pair married, causing an enraged Epstein to cut off the then 19-year-old. Ms Roberts said she was coming to grips with her exploitation. Three years ago she was contacted by the FBI who found photos and secret videos of her during their investigations. The case forced Ms Roberts to deal with her abuse and also reveal it to her husband. "I couldn't bring myself to tell him much. No man wants to know his wife has been traded out,” she told The Mail. While Epstein's plea deal meant her identity was hidden, Ms Roberts said after seeing a picture of the pair shopping she had to go public. "I am appalled. To me, it's saying 'We are above the law'. But Jeffrey is a monster." Both Epstein and Prince Andrew refused to comment. Originally published as Prince Andrew and the sex slave teen http:/Avww.dailytelegraph.com .au/the-prince-a-paedophile-and-the-sex-slave-teen/news-story/8cdeee961 a486febf459eafe00a7f710?sv=68c529bb044b9fdaSbf4f3... 2/2 HOUSE_OVERSIGHT_014818

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Case 1:15-cv-07433-RWS Document 751-9 Filed 03/17/17 Page 2 of 3 Buckingham Palace issues second denial of underage sex claims against Prince Andrew I www.foxnews.com June 6, 2012: In this file photo, Britain's Prince Andrew leaves King Edward VII hospital in London after visiting his father Prince Philip. (AP) Buckingham Palace officials have again denied claims made by a woman who alleged that she was forced to have sex while underage with Prince Andrew, Duke of York. The second denial comes after two Sunday papers in Britain published interviews with the woman in which she claimed that she was forced by American financier Jeffrey Epstein to have sex with Prince Andrew at least three times between 1999 and 2002. The woman alleges that the encounters took place in London, New York, and on a Caribbean island owned by Epstein. A Palace spokesman has said that the allegations are "false and without any foundation." "It is emphatically denied that the Duke of York had any form of sexual contact or relationship with (the woman)," the statement continued. The denials are unusual because royal officials typically do not comment on allegations against members of the royal family. The woman's claims are part of a lawsuit in a Florida court relating to how prosecutors handled a sexual abuse case against American financier Jeffrey Epstein. The woman, identified in court papers only as "Jane Doe No. 3," is one of two new accusers asking a West Palm Beach, Florida, judge to allow them to join the existing lawsuit against Epstein. The royal is not named as a defendant in the case, and no criminal charges or formal allegations have been made against him. 1/2 HOUSE_OVERSIGHT_014821

Case 1:15-cv-07433-RWS Document 751-9 Filed 03/17/17 Page 3 of 3 The women have objected to how U.S. prosecutors handled Epstein's case, and want authorities to reconsider a plea deal that allowed Epstein to avoid much more serious federal charges and potentially longer prison time. Epstein served 13 months of an 18-month sentence after pleading guilty to a single charge of soliciting prostitution before being released in 2009. It was not the first time Prince Andrew has faced media scrutiny over his friendship with Epstein. In July 2011 the royal stepped down from his role as a U.K. trade ambassador after he was photographed with Epstein in New York. Prince Andrew is the second son and third child of Queen Elizabeth II and Prince Philip, Duke of Edinburgh. He is fifth in line to the British throne behind his older brother Prince Charles, nephew Prince William, grandnephew Prince George, and nephew Prince Harry. The Sunday Mirror reported that Prince Andrew was on a skiing holiday in Switzerland, where he had been staying with his ex-wife Sarah Ferguson and their daughters, Princess Beatrice and Princess Eugenie. In a further bizarre twist to the story, prominent attorney Alan Dershowitz, who is also named in the court documents, told the BBC that he is planning legal action against the woman. "If she believes she has been hurt by me and Prince Andrew, she should be suing us for damages," the former Harvard Law professor said. "| welcome that lawsuit. | welcome any opportunity that would put her under oath and require her to state under oath these false allegations." The Associated Press contributed to this report. 2/2 HOUSE_OVERSIGHT_014822

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Case 1:15-cv-07433-RWS Document 751-10 Filed 03/17/17 Page 2 of 4 Prince Andrew denies sex abuse claims - CNN.com oa edition.cnn.com Story highlights e Prince Andrew addresses crowd at Davos, backs palace statement e Court documents show attorneys sent a letter asking to interview him under oath e Buckingham Palace has strenuously denied claim that he had sex with Virginia Roberts "Firstly, | think | must, want, for the record to refer to the events that have taken place in the last three weeks. And | just wish to reiterate and to reaffirm the statements which have already been made on my behalf by Buckingham Palace,” he said Thursday at the World Economic Forum. Earlier this month, Buckingham Palace issued a statement which said, "It is emphatically denied that the Duke of York [Andrew] had any form of sexual contact or relationship" with the woman. "Any claim to the contrary is false and without foundation." Andrew is a son of Queen Elizabeth II and a brother of Prince Charles, the next in line for the British throne. The prince is accused of having sex with the woman when she was 17, details of which are is a sworn affidavit in Florida court dated January 19. The woman said that she and the Prince had sex "three times, including one orgy." The court documents showed that her lawyers had sent a letter to Buckingham Palace asking to interview the prince under oath. In her sworn affidavit, the woman described Buckingham Palace's denial that sexual contact ever took place between the pair as "false and hurtful to me." Interview request The woman, identified by Buckingham Palace as Virginia Roberts, first named the prince in a civil motion filed December 30 in the U.S. District Court in southern Florida in which she claims she was forced to have sex with several men. She is referred to as Jane Doe No. 3 in the legal filings. In the letter the woman's lawyers sent to Buckingham Palace, attorneys Paul Cassell and Bradley Edwards asked to interview Prince Andrew "under oath regarding interactions that you had with Jane Doe No. 3 beginning in approximately early 2001. Jane Doe No. 3 was then 17 years old." The letter includes a picture of the woman and Andrew which was taken around that time, they say. The lawyers also want to discuss subsequent interactions with their client in New York City later that year, the letter says. "The interview could be conducted at a time and place of your choosing, and with your cooperation, | believe the interview could be completed in two hours or less," it says. New court pleadings involving the relationship between Jane Doe No. 3 and the prince are being prepared, the letter adds, but their filing will be delayed if Andrew accepts the interview request by January 19. The attorney for her legal team confirmed to CNN that Buckingham Palace had refused to accept the letter to Prince Andrew and that it was returned to them. Buckingham Palace didn't respond Thursday when asked by CNN about the letter. 1/3 HOUSE_OVERSIGHT_014824

Case 1:15-cv-07433-RWS Document 751-10 Filed 03/17/17 Page 3 of 4 But the woman's allegations have previously been firmly rejected by Buckingham Palace. "It is emphatically denied that the Duke of York had any form of sexual contact or relationship with Virginia Roberts. Any claim to the contrary is false and without foundation," the palace said early this month. Statement: | just called him 'Andy' Prince Andrew is named in the court filing in Florida as one of a number of prominent people who allegedly had sexual contact with teenage girls through self-made billionaire Jeffrey Epstein, who pleaded guilty some years ago in Florida to a state charge of prostitution solicitation. CNN was unable to reach Martin Weinberg, Epstein's attorney, on Thursday. In her first sworn statement to the court, Jane Doe No. 3 gave more details of the alleged encounters. "Epstein made me have sex with Prince Andrew several times," she said, according to the court document. "| had sex with him three times, including one orgy. | knew he was a member of the British Royal Family, but | just called him ‘Andy.’ " One day when she was in London, she said, Epstein told her she would be meeting a "major prince." She continued: "Epstein told me 'to exceed' everything | had been taught. He emphasized that whatever Prince Andrew wanted, | was to make sure he got." ‘Sexual interests in feet' When the prince arrived, she was introduced, she said, and "we kissed formally, cheek to cheek." The group went for dinner and to a nightclub where she was served alcohol before returning to the townhouse. The picture referred to in the letter, of the prince with Roberts, was taken there, she said. After the pair were left alone, she said, "We went to the bathroom and bedroom, which were just steps away from where the picture was taken. We engaged in sexual activities there. Afterwards, Andy left quickly with his security." She said she had reported back to Epstein on the encounter next day, telling him, "It went great." "| told Epstein about Andy's sexual interests in feet. Epstein thought it was very funny. Epstein appeared to be collecting private information about Andy," she added. Roberts also gave details of two more alleged occasions when the pair had sex. One was in Epstein's New York mansion in spring 2001, she said, when she was 17. The third and last occasion was at an orgy involving nine girls on Epstein's private island in the U.S. Virgin Islands, her statement said. "| was around 18 at the time. Epstein, Andy, approximately eight other young girls, and | had sex together." The other girls, who appeared to be under 18, were "European looking and sounding" and didn't really speak English, she said. She said she "felt disgusted" after the orgy. ‘Voluntarily tell the truth’ Roberts rejected the palace's denial of the allegations and said she hoped Andrew would agree to be interviewed under oath. "I did have sexual contact with him as | have described here -- under oath," she said. 2/3 HOUSE_OVERSIGHT_014825

Case 1:15-cv-07433-RWS Document 751-10 Filed 03/17/17 Page 4 of 4 "Given what he knows and has seen, | was hoping that he would simply voluntarily tell the truth about everything." Roberts and another woman are seeking to join two other women who are arguing in federal court for the U.S. government to reexamine its case involving Epstein. The investment banker agreed to a state plea deal in 2007 and began serving an 18-month sentence in 2008, according to court documents. He pleaded guilty to solicitation of prostitution and procurement of a minor for prostitution. CNN's Max Foster contributed to this report. 3/3 HOUSE_OVERSIGHT_014826

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Case 1:15-cv-07433-RWS Document 751-11 Filed 03/17/17 Page 2 of 8 Feedback [Fai Daily Mail News com ) Darlymari Friday, Mar i7th 2047 (2PM 70°F &, ahh TF = §-Dey Forecast Home U.K. (0) sports | U.S. Showblz | Australla | Femail | Health | Sclence Money | Video | Travel | Columnists Latest Headlines | Mews | Viorld Mews rte Headlines Pictures | Most read | Wires {EP WINTER PARK fi 4 LODGING ON Gag Of LODGING rp | | ofr WEEKENDS EAT! TO Fe sins MW rerpuresray recued., YOU COULD SAVE bey seo Ltingg Us Pra: Prince Andrew risks losing ambassador job as girl in underage sex case reveals meeting him 4 Ty TOM | TOMARD UPDATED: 08:0) ED, 2 March 2071 mesos = « The Duke of York, 51, pictured with his arm around the bare midriff of Virgin Very fancy caffoo. @12 Roberts = Mother-of-threa spent four years as millionaira's personal masseuse + Epstein trained her ‘as a prostitute for him and his friends’ Heh Follow a] + Serious doubts are being cast on Prinee Andrew's suitability to represent Britain or Laihy baBal following revelatiane that he spent time with a girl of 1¥ while she was being sexually exploitec by one of his billionsire friends. FEMAIL TO * if'youean't beat them, The Duke of York, 51, was pictured with his arm argund the bare midriff of Virginia jet these bow It Roberts. a vulnerable teenager hired to work 35 en ‘erotic masseuse’ and perform Mere ea GU dere! > sexual favours for Americen businessmen Jeffrey Epstein end his friends. Bulnness with William after his wild Hime ' Te ‘ ing in Switzerland Later, she claims, Fpatein’s frienel Ghislsing Maxwell tale her: Yeu did wel. Ae hae! era hy — fun: Smoke break! Weary- Kae and Ashley Slsan enjoy a cigarette outside New ‘Tork Gly office building after it's Tevealed one of them ‘wants kids" Plow choohy of her! Niedel Rachel NeCord leaves VERY little te the imagination as she pases on Mallbu beach ina baraly-there black bikin! } wine hoa! Jennifer Lopez locks senrehing In tiny dress as she heads fer romantic dinner with new beau Alex Redrigwed In Mlaml New bal ou * Sngelina Jolie goes BRALESS a5 she meets Britain's Srchkishop of Canterbury to discuss sexual violance and the rahuges eriele S8 part ef her humanitarian force } Catch a ‘haunted hangover’ mowie, wander the Mallbu cilfts and sip faming Margaritas: How to co Los Angeles a5 2 couple EVONSOMLD } tate ditches her St Patrick's Day hat to [ot hair down a= she and Willa arrive ln Parle for ‘two-day Brexit charm Offensive [Dut stve's Saill wearing tha sama coat} b Sargdert blonde: Hillary and Huma spotted after doy at tho salon with Tintern debuting anew soif and color while Abedin lugs around her boss! £2600 purse » Ab colutaly amazingl Firet meeting: Prince Andrew pute his arme around 17-year-old Virginia, centre Peta Murgatroyd flashes her svelte post-paky belly a she heads to Dancing with the Stars A . att ssa ds : ' at ko : practice with Bacher Andrew, who works forthe Government ag an ambogsader for foreign trade, remaging huni Nick ‘viall clase lo Epstein, 58, anc slayed st his New York mansion as recently as December - despite the financier sdmitting te child sex crimes in 2008 and being olaced on the W'tve got to lose 10bs In V1 dayst": Mama June is U5 sex offende: register. pressured to shed even MORE weight as she's Fie Fil mee ee Seer setae aire oe a: , = stuck at I9Hb=in teaser But the fullextent of the prince's oroximity ta Fpstein’s otfences was nat never until from Hot To Hot Migs Reberts broke her silence this weekend. Ina civil writ eqainet the Hugineseman, Noterprying werkeut she alleged Lhal her duties ncluced being ‘sexuslly exploited by Epstein’s adult male mneine inaealiiclie, } Haavily pregnant Jenna “ous cul Pa! HOUSE_OVERSIGHT_014828

PERS meray yam pe SHARE THIS ARTICLE RELATED ARTICLES Pictured: Prince Andrew and the 17-year- old girl his sew... Sordid friende and why he ian ‘tit for the job: Dulce of... Here. Tern Leangrd reveels the astonishing oackground bo tre ogse. The new Gatsby Even by Lhe rags-lo-riches-lo-rags mythology of New York, Jelfrey Eostein's ascc: and subsecyuent sumbling has been breathtaking. The sen of a parks department employee, he wes plucked from obscurity as 3 Manhattan private schoo! maths teacher by a pupil's father who oot him a job on Wall Street in 1976. He rose rapidly al the investment bans r Beer Steers out left in 14681 be sel up on hig own, managing the fortunes af clients with $15i ian ar more. Enigmatic and mysterious about his business ociivities, (some compare him to the [ictions| millianaire The Great Gatsby) he hes only ever identified one of his clients patron Le his menter and main ie Wexner whose ousiness ei includes ihe upmerket Vietoria’s Secret linceria chain. How rich Fostein has became is ¢ metter of conjecture but even h talk about his wealth with 32.000 sq [t. nine-lloor 40-racm mansion on Fast Fist Street is supposed) the bicgqest private residence in Mannattan. The paventent aviside is hested fram peneath te mell the snow. He also owns 3 7. 500-acre ranch in New Mexico, a mansion in Palm Beach, s house in Westin inatéer, ar apartment in fwenue Pooh, Paris, and Little $t James, one of the US Virgin Islands. His fleet of girerall includes @ Gullslreem jet, holicoorer and a Roding 727 on which he famously lew Bill Clinton anel Kevin Spacey onan Aids mission to Alrigs, Heisé noted patron of sci awed observers - has a orillians mind. One saye: Yeu spend time in Jeffrey's company and you come away enriched, and net ciminished Anew lite: Virgina, now.a mother-of-three, in Australia Epstein’ friends include net only Mr Clinton bul Donale Trump. former israeli prime minister Fhud Barak, top White House economist Larry Summers and s host of Nobe! Prize winning scientists. The Maxwell Connection Despite his wealth, Epstein was for years a pare sighting om Manrattan’s money- obsessed social scene, [hat ended in 1992 after he met Ghislaine Maxwell, glamorous and well-connected caughter of tne osgrased British lyaoon Roberk Mancwelll. Some believe she wes attracted by his resemblance ta her similarly dominant and flamboyant father, but their ramanee reportedly ended because she wanted to marry and he wanted to see other women. Bonkrolled by Costein, however, she estoolished herself as aleacding New vor’ sootelite end repaid [he favour by pulling Epstein in Louch with her own welkheeled friends in Britsin. She intrecuced him to Fines Andrew in early 2000, quite probably during s helicay at the Mar-a-Lageo Clubin Palm Beach, owned by Donald Trump. Fostein joinec them on four other breaks over the year, including a beach oolicay in Pruket. Thailand, smother holiday in Plarida ane twe ocessions in Britain. The fist wis June engagement ot Windsor Case lo celebrate the Queen's birthday, Lhe second 3 weekend house perly sl Sancdringharn six months later which the prinee arranged to celebrate Miss Maxwell's oth birthelay. In cetween, she took him ta an infernous ‘hookers and pimps’ party sts New vork niertclub hested by the former lingerie model Heicli Klum ina back ates SAM ourfir. SSS ee JAMESON puts HUGE haby bump on display in fevealing JMMpsult during lunch date with Aanee Lise Bitten F From sampling wild mectto watching movies Ina graveyard, the coal and crazy things you didn't knew yeu could doin LA SCONROHLL + EXCLUSIVE: William has new "stemach-pat ritual’ to help him cope when he ls anxious teweals body language Apert at she gives verdict on royal pair below could William enbarrase Kate ne publicly? J4M MOIR says the Prince's ski tip exposes the Duchess to speculation about their marnlage They were afraid | wae. going oo be toc fat": Pius-siz2 medel Ashley Graham details torment’ of being dumped ky ex- boy'runds because of her body shape b Miley Cyrus and fiance Liam Hemswerth show off thair fit forms during hike In Los Anges... days after her family Aenled that palr had married in secret * its like looking ina mirror’ Scarkest Johansson seems delighted with fan-made drawing of her gifted at South Korean premions ef Ghost in The Sheil b The heneymoen wae perfact opportunity to ratch up on sleep": Princess Ol's theughts just days after marrying Prince Ghares reveatedt in private letters, b Emma Watson 'satta Barr S45nallllon from Beauty And The Beast! Me co-star Dan Sevens Teveals his daughter Willow, 7, helped design Belle's yellow dress Fit i's good enough for Her hlajesty! Gra expert and coréetiere to Britain's Guean Elizabech reveals Hew yeu ean achiews the PERFECT fit ' Showing him what he's missing! Kouraiay Kardashian shares view Of her chest as she continums to spand time away trom ‘sex adder Sentt Case 1:15-cv-07433-RWS Document 751-11 Filed 03/17/17 Page 3 of 8 HOUSE_OVERSIGHT_014829

Troubled teenager: Virginia en the billionaire's Zone ranch in New Mexico in 2001 The prince was also al a Manhattan cocktail party thrown that year by Miss Wexwel) which was fille with young Russian trocels’ - some of the other guests wore ‘horrified’, said an anlooker. If tee prince get the chance ta party with a super-rich, never-married olaysoay wha loved te surround himse h benutiful younc women, the quid pre que for Fostaic was less obvious. American frends noticed his delight in introducing ‘Andrew’ end waiting for them to make the royal connection, There nave even been unsubstantiated rumours - most probably started by Epstein and on which Buckingharn Palace would net comment — that he advised the Queen on her finances. Murray Gell-Mann, « Nebel Prize-winning physicist and recipient af F pst ssid he was certainly given the impression by Epstein thet she was 3c in largesse, Young girls in Palm Beach Epstein’s world began te implace in March 2003 when the mother of s 4eyeur-ole girl went to police in Palm Beach accusing him of sexually assaulting her deughter. The teenager teld police she was te<cen to Cpstein’s mansion by an older gir end paio $300 after stripping ta her knickers and massaging the man while he abused himeel!, When police searched the mansion Lhey found ridden cameras, photos of nakesd young girls on the walls and genilalia-shaped soag in the bathiream. Atleast 40 girls aged 13 to 17 heve come borward with similar stories, sere saying Epstein sexually assaulted trem during the massage, According to Brad Edwards, a lawyer for some of the acousers, Epstein was molesting under-age girls every day he was ie Palm Beach. Police, who had wanted te pursue possib/e sex-traticking charees, wees furious anc blamed Fosiein’s nigh-placed friends when he was ollowed to atrike.a plea bargain under which he admitteo bwo minor charges and was jailed for just 13 months. “lL it you or | did this, we'd Be im prison for life, said Mr Edwards. However, the girls have been ellowed to take civil action and Epstein has so far made 410 hefty aut-ot- court settlements. Several girls said Ghislaine Maxwell had grocured them. Virginia’s story OF all tre allegations made by anonymous girls againal Epstein, one stood oules particulary carth- shettering. Jane Doe 102, #5 she was known, claimed she had not only been abused by Epstein out had jected around the weorlo with him and was ‘sexuelly exploites by [his] adult male peers, including royalty, peliticians, academicians, businessmen ond/or professional ynd personel acousintances’, She has now been identified a5 Virginia Roberts. a blonde, blue-eyed mother of three now living im Aust a Atthe age of 15. she wes working asa changing room ass stamt at the Mar-g- Lage club in Palm Beason, She seid she was approached by Ghislaine Maxwell, who offered her the chince te work fora wealthy gertlaman’ who needed s travel ing messcuse. Conviction: Joffrey Epstein They visited Epstein’s pink mansion where, according to court papers. she was ordered ta strip and straddle his naked! barly. mae bose ' ee ee : ‘ ' Case 1:15-cv-07433-RWS Document 751-11 Filed 03/17/17 Page 4of8 } Back on Broadway! Mork Fuualo cuts an impressive figura on Stage at The Price pening night alengsida Jeetlea Heene and Danny Davita FA goss for lifel Gigi Hadid i= hare to miss in biightorange sweater as she heads to early MOMUNG ote Shoes | New York City sportrg bg shades Marilyn in color: Footage of Monrca shot I by teurlat benween takes "i" f of Some Like It Hot shows how movie might have looked I? Itweren't black and white 2 te eloped Pregnant Amanda Seyired’s beau Thomas Sadeshi reveals. the couple have marta in secret as she puts nude phote hack behind her } Oh so chic: BellaHadid "Tog puts a French twist on her look with leatver beret and carries tote from her handbag laber ation E'S ahvaws OUEY oh » He's met ble marten! Tom Cruise, 64, will ge up against Superman star Henry Cavill, 33, In Nission: Impossible & b Glowing with pride! Anas Paquin isaks radiant as sha poses with husband Stephen Mover ot screening of his miniseries Shots Fired F Bieber looks Ike Ne stuck transfer tatts on bo GOMpensate hie emall a0: Model who joined austin on Ble party boat ‘this week takes 2 dig at G the pop-star's manhood = } Busty Jennifer Hudson battles bra wardrobe malfunction as sha POESE In thy Mint Skirt outside radie studies F Supermodel Ella Macpherson's personal walner shares hisdpsen ' how you can lose 10 pounds In two weeks. and you don't have to give up wine: Gearup & PLAY ONL& .! d title nine * Christina Millan glves an eye-popping display by Taunting her om ple azsets in quirky ruffled dress as she atnencds nightclub opening in Los Angeles Pelam blessed to call yew my son's Kris Jenner shares loving tribute to Rob Mardashlan en his 30th birthday... but there's no word trom Chyna b Grange is the now black: DWTS dancer Chery! Burke goes underwear free in very ey CUI-OUN strapless dress at TAG launch in HOUSE_OVERSIGHT_014830

MY Tae Was eC WITN EMoamrassmMent OUT I TSIC LINGEr IMMENse pressure Ta aiease them, she told the Mailon Sunday “The whole lime ibwas going on, they were pramising me the world, thet lcd trevel weith Jellrey on his private jet and have a well-paid orelession’ Epstein paid her $200 for whal he celled he ‘eretic message’ and Lold her Lo return the next day. She spent the next four years with Epstein. for three of which she was under Florida’s age of consent - 18. “Basically. | was training to be a prostitute for him and his friends who shared is interest in young girls! she sovs. That stage of his alleged sbuse sturted after twe years when he sskec her tea iy to his Cernbbean island and makes briend of his ‘feel how you make me eel’. She seys she was given to men. aged [ram Lheir 40s lo heir Gs, erther on the island oron Epstein’s Mew Mexico ranch, Pampering a prince Virginia says she met Prince Andrew three times. First, when she accompanied Fpstein on a six-week trip to Furope and North Africa in 2001, they went te Ghislaine Maxwells London house. The following day, Andrew arrived and Migs Maxwell served tea and biscuits lo the four of ther. Miss Maxwell invited the prince to guess Virginia's age end he correctly said “77'. at which Miss Maxwell joked that Jeffrey would ‘soon have ta trade her in’. Atter dinner and a trip te Tramp nightclub where she danced with the orinee. trey returned to Miss Maxwell's house. They allwent upstairs and Virginia askec Fpstein to take a oicture of her with Andrew bo ‘shew my mer’. She adds: ‘Ghisiaine and Jeffrey lef us after that, and ister Ancrew left! The following morning, Maxwell bold her: “You did well. He had fun nthe last leg of the trip, Epstein paid her $13,000 which she described es ‘smazing money, more than I'd ever made ona trip with him betere’. She seys she met 4ndr leatne “a second time at Easter 2001, fincing him sitting in a armchair at Epsteie's Manhattan home. Miss Maxwell hacl civen him the prince a Spitting Image puppet of himself anc another member of Eostein’s entourage, Johann Sjoberg, was sitting on his knee Miss Sjoberg, who was 21, herself described the incident to the Mail on Sunday three yesrs ago. She said Miss Maxwell made Virginia siLon Andrew's olher knee and then she ‘put the ouppet’s hand on Virginia's oreast. then Andrew put his hand en my breast’. She added: ‘it was a great joke. Fverybody laughed? [he Joke’ earned virginia $400 from Epstein. Her final sneeunter with the prince wae on Eseteins Carisbean island, by which time she was 18. There is na suggestion that there was ever any sexusl contest between her and the prince or that Andrew know Fpstein had paid her to howe sexual contact with his Iriends. By now, she seys, Cpstein wes hinting she wes ‘too old! for him altrough he ane Miss Maxwell onee disgusted her by suggesting she hada child oy him. “They seid | would hove te sien a contract relinquishing rights te the child and consenting to setfrey having as many relationships as he iked she says. “Ihweae a smack in the face! For her 19th birthday, Eoglein flew ber lo Thailand to take # massege course. She meter Australian martial arts expert there ane married hire ten days larer. Counselling: Virginia at her mother's hame at Palm Beach in 1958 Fostein’s plea bargain spared Virginia the ordeal of naving Le testify against him in court. But she says she is ‘appalled’ by Lhe light senlence he recemed. ‘Ta me il’s seying, “We are abowe the law", Jottey is a monster An offender not a predator Frigads ing st Epstein is looking tor @ new beginning’ butit has net started with any show of remorse from the soatoriously arraqant tyeoon. Stogped by a reonrter in New York last week. be insisted: ‘I'm net a sexual predater, Im en offender... it’s the dillerence between a murderer ance 9 oerson who steals 2 bagel! Case 1:15-cv-07433-RWS Document 751-11 Filed 03/17/17 Page5of8 Hollywood Michelle steps back inta the spodight: Mes Obama makes guest appaaranca on MaseerChet Junior talling young chat: te peck healthier food + OMGigi! Supermodel Hadid displays hier deavage, taut abs and Jean legs Ina range of anticing ansambles 2s she poses for new fashion eampaign } Harper Beckham is her mathar's blggeed fan ae ‘the five-year-old reveals that shejs‘escited’ fo wear Wieterla's new designs for Target Poe's my soulmate’: Victoria Eieckham prslese her IMeredlale husband! David as she reveals she's inspired by his Hindneas avery day berm not sure he'll be Changing diapers: Cindy § Crawford's husband Rande Gerber weighs In anthotype of dod his pal George Clooney. 53, wills * Fake locksmith secretly § filmed Brigitte Bardot before trying to-sell footage of intimate moments after ticking hic way ita her St The pez home b Hey gid! Dazeling Eva Mendes returns to thie spotlight sfter spending six montis wih her children while Ryan Gosling hit the La La Land pramo trail + EXCLUSIVE: Meat Dushanka Foon, busty night club promoter who hand-peked sexy models for Justin Bieber's Aussie boot party Fltwas 2 bly shock" Maksim Cheerkovskiy reveals ‘crazy’ health seare aftar baby son Shal aiken te ER Rowranikey facia heint pee D MWeeP! Julia Louis Drevius goes wild as Stunning last second mistake allows. Northwestern and her Son to dalm first ever Merch Madnass win * Gwyneth Paltrews and Chris Martla FIMALLY sell their NVC penthouse after B4million cut anda year on the market Tancnsell belies sar it onmier Tor tor irendiy exes } tars Reid looks. glam In sequin blazer os sha Sores up te mystery man at opening af TAC venue in Hollywood Go Green Fire all 4 SEARCH ST. RATRICK'S ERSORIES } Ryan Lochts pools cn the PDA with his pregnant lances Kayla Rae Reid az couple enjoy cate night af LA bash Liscralet swiryrer Firs about 25 percent of thair income’: Kim, Kourmey, and Khioe Kardashian make SIX FIGURES for sponsored post on social madi HOUSE_OVERSIGHT_014831

Case 1:15-cv-07433-RWS Document 751-11 Filed 03/17/17 Page 6 of8 This particular bagel thief has been put in the highest re-offending risk cateqery in the US sex olfenders’ p er But while Leslie Wex his billiongire client, has cispensed with his services, other less wealthy friends are more than heapy still to fraternise with the conycted paedophile. They include Prince Sncrew, who spent tive days staying at Epstein’s Manhattan mansion in Decem oer. He was quest of honour ata party thrown by Epstein and attended by Woecly Allen, CBS News presenter Catie Couric ond severg| other broadeascers. all of them light- heartedly pestering tor invitations to Prinse William's weeding. Organiser: Ghislaine Maxwell lookson as Andrew put his arm around Virginia, Robert Maxwell's daughter invited her ta work as Epstein's personal masseuse soon after her 15th birthday Rosa Manckton, the jeweller ond former confidante of Diana, Princess of Wales, has been a inend of Eostein since they met ala dinner pearly in Londen in the 1980s. She said she was nol surprised thal Prince Andrew was still willing to associate wilh him, ‘It shows he's a good friend’ she says. Jetfrey is an extraordinarily loyal friend, and if somebody's layal te you, you're loyal back. Whatever Jeffrey did, he's bean punished! for, Ag for Ghislaine Moawell, she is still cloge to Epstein although cording bee a member of stall al her New York home yesterday, she had conveniently ‘gone away until next week. Epstein himself is picking up the reins of 4 business without its mein client (Mr Wesner|, Friencs confide that ‘it isa difficult time for hirer. Grad Edwards, the lawyer representing same of his accusers in Florida, is sceptical over whether Epstein will be oble te gel over cis hankering for ine sexual Ministrstions of poor, casily-exoloited young girls - whatever his friencs say. ‘Ta me. it's 9 touch habit to bresk, he says. Share or comment on this article mOOe=c FROM THE WEB 5 avec Lin ict Just Typa In Your Nama, Walt Angelina Jolle's New Go-To Tha impossibly Comfortable 0 Seconds, Then Brace Travel Shoe Is Surprisingly Indoor-Outdoor Slipper Yoursolt Affordable r m sar Purple Seanch 5 ubse * Micole Scheralnger looks worse for wear as she leaves party wearlng Fy very busty lmather 4 ensemble... after flashing hor underwear in sami- sheer ourtit P Micky Hilton somes glamour in dazzling silver flocr-length gown a5 she attends prestigious sociecy ball In Mew York Shelnukead shunning b What do you maan, a quiet lumen? Hilsreus phote shows Justin \ Bieber eating chicken 2c My cat’ as crowed of wore watch... before he frandeally sprints away F gusty Bleber canthide y his: breakouts as he eats BBO chicken after McDonald's run the day before... while he gece dose te another sexy model * Charlotte McKinney brings bombshell loak In black mini dress at Hollywood development grand opening party [ne So year clo scwese sarin * Arnie Schwarzenegger shuts down talk about Tramp during Interview by changing subject ta boctytoullelling. .. after saying he wanted to ‘smash’ Donald's face + Double D-Je Channel Jeffries flaunts ample ateets in bondiage-eeque — bustier as she gets ready to spin discs at Los P Angeles nighsclub opening | ear designer nip slip! Chrissy Telgen almost suffers wardrobe maHunesion In $7,000 Gucci outfit = she fice out of LA with John Legend and baby Luna * 90210 star Annalynne NcGord looks stunning Ina glittering semi-sheer dress and thigh high boots a5 She parties at boouty bash in LA } Peneloge Cruz look: chic in pinstripe suit a3 she arrives hand in hand with husband Javler Bardem to celebrote lookalike Sister hlanica's 80th birthday } Tha Lord of fina diningl Scott Disick bonds with his kids and Nerth West az he takes them to upscale sushl lunch at Hob (UEIty time with hes kids * Mow: that's a Full Housal Lori Loughlin lists neo-Meclkerranean Bel-6ir mansion for £46 MILLION Ia quite the renovation yearn } Gritain’s Princess Beatrice ls the royal baile of the ball as she Mingles with Mew Tork, City socicty ot The Frick Collection Young Follows Ball * Qewnte-corth model Hailey Baldwin hungrily tucks Inte peppercnl pizza in comic Shapchat..otter turning = = heads in silver glitzy gown at parcy Tiny Dancer! Kim and Janya's kid North West looks the ploture of euieness as she pirquettes alengduring 9 tunllled family outing in pes Molibu Mommy on duty? Candles Swanepeel takes 3 break from her high Rushton shoot in Brazil ta breastfeed son Anaca..while rocking 3 LED ¥ Baby Joyl Maren Cotillard. 41, welcomes a AaALnTeT with narmer a HOUSE_OVERSIGHT_014832

Lupe Horie CHEF et Ever Wondered Why Donald Denver: This Meal Service is Trump Doesn't Talk About His = Cheaper Than Your Local Store Daughter Tiffany? Here's Why = How : 21* Secrets About Air Force ne That Onty The President Knows. Never Use A Bad Realtor Agaln The Root Of All Bally Probleris HomelLight.com BiG 82% Cant Pass This Art Quiz. an You? 44 Supplement MOST WATCHED NEWS VIDEOS e) Horific moment man attacks woman from (Good samaritan 5: poles daputy by Dancing Prince seen talking fo mystery wath emetion and fired ex 3 Signs of a Fatty Liver Watch Now deuplalselubn con Britain's youngest ambangss Katese | tham, join them! mummy's esther: matherto-he ip Comments 127 Share venat you tink Oldest Best rated The comments below fave Seen moderated in advance. asl Trev, Henilte (he is Ihe QGueurr's favours child - oe wall slay where ” 7 ANQU0T to get upset ab concieim Mayne Gharles ar Wil can get nc, but act nnw Clektortce <F © tT 8 “Wny I heonot banned trim ontenng the WKY [hoy are nanoing a radio talk shrw host who is ultrs conséirvabye. not id abuser at all juste tak show host. das banned but you led this filthy pic nly your bool. One ef you shoud meke a corel Clichtorate “? 7 dh 8 | bine Tailor) gard Ayeers at duh, 4 schon! laaver who became Peitain's Trace Previa is A joke on itself Get cid of thi dais nel fewer for meriual ob bl eslone bepress i i was loom werent There Are PANY WEIL QUAIINEC fespectable paoce anc one shiner coud sere responsibly wrthaut acy Tues. This idiul Lakes allel ead ant maring boned wherever te gues lo placer! cos counly es élece crwey meamhy 6 Ircebnes (recri och Anabes and Blows ull eee deals oy lalkerig * AR ane Trbeed thnegn othes stat wrnin 3 scathing amcie and pemted our tn vey Andy talks and cparsta tis mission abroad. Having reed this artcle in the Daily Mail not |ong-eao I thought Gis men if rolwert le sows as bis counblys bede ervey, Clichtorae 4} HB tb 4 na Sementa Aneto Case 1:15-cv-07433-RWS Document 751-11 Filed 03/17/17 Page 7 of8 Guillaume Conet [ne Fr Tees salar send willy Paizo] Pall in) Ube: Viee Aled On top ofthe wortd! Elisabetta Canalis wows. in her new swimwear lina whh she help of one of Los Angeles’ most famous homes Tenge Chimneys ae b Gewnton Abbay's ¥ Laura Garmichaelloaks jy funky in feral sweater os | fhe cozleeup te ax eo- sar Dan Stevens for Beauty and The Beast fashton launch * Holly Madison purs on avery busty display as she joins star-studded = Ea grand openingef TAO = Eo Hollyweed development T natal icles qu } Paris and her prom dare! Jackson Is all smiles as she walks hand-in-hand with BFF Melissa Lauren who she Took 00 last year’s Tormal dance b This Is Us co-stars: Mandy Meera ana Chrissy Metz light ue red carpet in contrasting outfits at Beverly HIlls tu s ' sre DeSmind } Robin Thicke picks up son Julian accompanied by gintrlend April Love G } Hats off to her! Frincess Anne's daughter Zara Tindall makes an elegant appasrance in blue at Cheltenham for the FOURTH day ina row * Shouldn't thas be & Guinness? Prince Charles shuns traditional St Patrick's Day tine for a plnt of ala 2s he visits a brewery Ih Willtshire Miske way fer the minis! Kata Holmes flaunts her lean legs in plush dress ag Halley Baldwin sparkles in sequins at Star-Studded opening of TaO in La * Kylim Jenner proudly Shows off her bling on Snapchat... just befara Kendall had $200k worth of jewalry stelen | Gasca ie tel al onesie ee fings PWe're all wery excttecl": Jessica Hall of Kendra: On Top reveals sine 1s ga pacting baby number ‘twe with huskand Fregnant by her husband Kye Cl ) Hugh Jackman wraps up in putfa Jacke: as he braves the chilly New York Clty weather te tHliv The Greatest Showman one oT Haliwoced s al Soleo F SPOILER ALERT: Gray's Anstemy's OF Apnl Kepner enjoys rendezvous with Or Jackson Avery in malor ‘twist Lramste develop mert * Letting |e all hang out! Coce Austin dances in lew-eur anil peter jumpsuit at $2 Patriek's Day party Flunaing nt hlins rovcaice fer c Isai } Dancing With The Siors Bre Anna Trebunskays reveals sha is expecting baby nuriber two with boyiriand Nevin Millan Shower at her tet F'Lat's do it" Rachel Lindsay sparkles in behind the scenes shots shared by The Bachelorette creator Nike Flaiss HOUSE_OVERSIGHT_014833

Case 1:15-cv-07433-RWS Document 751-11 Filed 03/17/17 Page 8 of 8 oF, my HILT S INITIO TO Tae enya WERCIN WI proceinry Ton he witnorsin Clicktorate “* BY <p 2 Crue tery, Wel ‘Why doeact he ge hack co dearol: Sanda? she might suck 1s toes for vim, and she | gata fmt ‘seul al "you keow whl, Clichtoram <j 2 de Aud ul comese fell mu ee Cengia wars olTering iy services fur nuney Clichtorm “F TM se 4 061, Hot Phere is ae suqae: Aud ew know Fostein had pac har ta have sexual contact wath his fiaads Thal seng the nase then this ss galky neta jouraistic suury ie i? Cr is guill by aseecialion mow a cn ne? Clicktorsm <j} & + 2 Leavis, & MH, G jeare’ Sco Bnlish Gusinesses wll probaaey fall aperl willioul bie esdershiipe Wel bres weorcea Tul crn) previa s (he uly ns & pt ane Ciicktorsce <j 9 <p 18 hale, Ila ALL! she knew whal she wes doing - bewice ty a Lihue: and shes Sul ving wo gel meriey ane snlloer ston Makes qo te tange she sroms to nave no share Clickionace > 11 thease gins cid dascribad as "macsage"l Mone of tham k veel oroelobes woo lowched rari wilht no ides or inte {wander wee hawe te batin sues preyudien when newspy chair activitias, Clicktores <P 2 te 4 The views expressed in the contents above arethose of our users and de not necessarily reflect the views of Mail nine. We Sre mo bonger at: eating SoMmiments cathe Stile. MORE TOP STORIES lf you can't beat them, join them! Now it's Kate's turn to hit the bar as she swigs a pint of Guinness with ‘dad-dancar’ William al Garnibodge ape sen puniy Me on St Babs ary 1 rion, before... > IGE byidex Trump's warm welcame for Merkel: President greets German chancellor for face te face talks - after he accused her of ruining her country... Trump caned fcr! are bnaldiiniy ber ks sal Ue Hose today Phy) hawcs joint prose meniornes fos afarnoan whees tha topic ot @ 268cucnes Tat vites Frantic search for stalen Secret Service agent's laptop that has ‘sensitive’ dacuments on it including Trump Tower floor plans and... A Bering agel's laplop was reporeedly sloters trom rvehirie parked on her drveway io Brooklyn Maw York Thunsdiy iriver 1 @ Gains Trump says North Korea is ‘behaving very badly' — after secretary of state draws new red ling threatening pre-emptive strike if Kim's regime... Trinpis secretary ot scate had already ssid fay ne necessary ba tae pre anniptva military accion if th} bewal fon Peongyarig's weapons. @) Thtcommerts GO 1 vdeo Inching towards nuclear war? It's terrifying. North Korea's use of missiles threatens a new global Alaghnnint whieh could auck in Silt af Thllas alltiew } Hostes with the mostesr Tyra Banks returning as host of Ameries’® Met Tap Medel. after being named a= Nick Cannon's feplacement on AGT * Shad Michael Murray wears a smart blue suit a5 Ne Talk abour golng nude on his news TY sarles Sum Record Veber. feemn-ftttirg suit ks ply Ure shen * Gorgeous Candice Swanepodl gees hell for leather in NYC after revealing Vogue stoaot In Brazil ‘Vietons € Sac net Angel ickealonevirg, } Mommy and mo time! Ashlee Simpacn an dawghter dagger are coordinating denim dlwas as they run anrands around town Headend oui topeiher * shes a bono babe! Wolin Akarman goas hippie ehle a8 she steps out with sen Sabastian days after going public with new actor beau ack Donnelly } Taking a bite out of canter: Cindy Crawtord goss casual for launch of charity burger with husband Pande Accompanied oy her wsbard Rarde & } Anti-marriage” Wonderbra mode! Evo Herzigova announces sngagement to father of her three children Tin: Secastebenn Ensily age fing ihe kret b Smeking het romance! Adriana Lima lights up before packing on POA with bad boy NY Mets pitcher Matt Harvey... after salitting with Jullan 9 Edelman b Thm reyal traztmant! Frince Albert of Monace's daughter Jazmin Grace Grimalel packs on PDA with boyériend lan Vellencame In La * Fabulous at fi! Halle Barry shows fit physique In fan k-Top and leggings while picking up skin care supplies: fiscar winning attres iecheng berilarsle All business! Jessica Biel leaves Her kld- friendly Hollywood eatery In chit ensemble of black sweater and whilte pencil skirt * An sight-cor garage, Inflaley past. FIVE bedrooms and avery SEXY ensuite bathroom: Inside the manslon Justin Bieber is ranting during his Sydney stay F Mane attraction! Vanessa Hudgens shows off new sertansions during horseback riding lessons In LA THaal kospal IBresiiinystise 6 . Making friends? Justin Bleber enjoys a pleasant aa change with an Iggy Azalea lookallke fan dressed in 2 netted erop ‘Top and black bra in Sydney * desy Melson fiercely denies feud with Little Mx bandmate Perrie Edwards... ax it's dalmed she ditched girs’ night for date with new love Chis Clark’ Pie looks Ike Jvetin Ras a thing for yuramy mommies! Meet model Sarah Fiagerald... ce maried mom Bieber parted! with during cruise b Shete not nest imans! HOUSE_OVERSIGHT_014834

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Case 1:15-cv-07433-RWS Document 751-12 Filed 03/17/17 Page 2of3 Jeffrey Epstein ‘sex slave’ Virginia Roberts was a 'money- hungry sex kitten’, ex friends claim re www.dailymail.co.uk Jeffrey Epstein 'sex slave’ lived a lavish lifestyle and enjoyed her role as his ‘travelling masseuse’, former friends claim e Virginia Roberts claims she was recruited to Epstein's harem in 1999 e Named Prince Andrew and Alan Dershowitz as men she had to ‘service’ e Her friends say there was no indication she was being held captive e Asked other women if they knew anyone 'slutty’ to bring to Epstein e Would allegedly use cash she gained from sex to live a luxury lifestyle By Wills Robinson For Dailymail.com Published: 12:49 EDT, 1 March 2015 | Updated: 07:09 EDT, 2 March 2015 Shocking: Virginia Roberts' friends claim she was a money-hungry sex kitten’ who enjoyed her lavish lifestyle The woman who has accused Jeffery Epstein of keeping her as a sex slave was actually a money-hungry sex kitten’ who enjoyed her lavish lifestyle, former friends have claimed. Virginia Roberts is currently in the midst of a lawsuit claiming she was recruited to join Epstein's harem of underage women in 1999, naming Prince Andrew and attorney Alan Dershowitz as two of the men she was made to service’. But those who used to be close to the 31-year-old say she relished her role as his ‘travelling masseuse’ and never acted like she was being held captive. Philip Guderyon, who used to date Roberts and would drive her to Epstein's Pal Beach, Florida, mansion told the New York Daily News: 'She was like the head b***h. She’d have like nine or 10 girls she used to bring to him. ‘She never looked like she was being held captive,’ he added. 'She and the other girls would walk out of there smiling, with their little bathing suits on, like they had just come from the beach. ‘She'd have like $4,000. And then I’d take them all to the mall and they'd get their nails done.’ He also said while making thousands of dollars from the relationship, she would buy fancy clothes and drive around in Epstein's Mercedes. Crystal Figueroa, whose brother dated Roberts in the early 2000s, told the Daily News Roberts would ask if she knew anyone 'slutty’ so they could be sent to Epstein. In 2001 she was sharing a Palm Beach apartment with Anthony Valladares. He told the Daily News that she bragged about going to the 'millionaire's house’ for a day or two, before returning with cash. He did say that she tried to get out of the sex business, but was dragged back in. Last month it was revealed Roberts accused two male acquaintances she was raped, bringing her credibility into 1/2 HOUSE_OVERSIGHT_014836

Case 1:15-cv-07433-RWS Document 751-12 Filed 03/17/17 Page 3of3 question. Roberts' lawyers says the latest allegations do not contend the fact she was used for underage sex. Attorney Sigrid McCawleysaid : "To say that our client acquiesced in this abuse, or that the abuse was OK because she was paid for it — leaves out the fact that this is why we have laws in the United States to protect minor children who are groomed and sexually trafficked by adults." Epstein served 13 months in a Florida prison after pleading guilty in 2008 to soliciting a minor for prostitution. Allegations: The 31-year-old is currently in the midst of a lawsuit claiming she was recruited to join Epstein's harem of underage women in 1999, naming Prince Andrew and attorney Alan Dershowitz as two of the men she was made to 'service' The scandal resurfaced in January when Roberts named Prince Andrew in a lawsuit, accusing him of using her for underage sex. According to court records connected with Roberts’ current lawsuit, she maintains that she was recruited to join Epstein's harem in 1999 by his friend, the socialite Ghislaine Maxwell. She says during the three years she worked for Epstein, she was made to entertain his friends and named Prince Andrew and Dershowitz as two men she had sex with. Both men have denied having sex with Roberts, and Dershowitz is trying to get his name removed from the suit, claiming Roberts made the entire story up. Read more: e www.nydailynews.... Share or comment on this article Sorry we are not currently accepting comments on this article. 2/2 HOUSE_OVERSIGHT_014837

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Case 1:15-cv-07433-RWS Document 751-18 Filed 03/17/17 Page 2 of 3 FOR IMMEDIATE RELEASE Contact: Richard A. Simpson, [email protected] April 8, 2016 Lawyers Acknowledge Mistake In Filing Sexual Misconduct Charges Against Professor Dershowitz Professor Alan M. Dershowitz released the following statement regarding resolution of the case styled Bradley Edwards, et al. v. Alan M. Dershowitz, Case No. CACE 15-000072 (Cir. Ct., Broward Cnty., Fla.). STATEMENT OF ALAN M. DERSHOWITZ | am pleased that the litigation has concluded and | am gratified by the Joint Statement issued today by Jeffrey E. Streitfeld on behalf of the parties, in which “Edwards and Cassell acknowledge that it was a mistake to have filed sexual misconduct accusations against Dershowitz and the sexual misconduct accusations made in all public filings (including all exhibits) are hereby withdrawn.” Mr. Streitfeld’s announcement and the Joint Statement are copied below. ANNOUNCEMENT BY JEFFREY E. STREITFELD, FLORIDA SUPREME COURT CERTIFIED CIRCUIT CIVIL MEDIATOR (Streitfeldlaw.com) It is my pleasure to report that Bradley J. Edwards, Paul G. Cassell, and Alan M. Dershowitz have resolved their disputes and have agreed to settle the claims raised in an action pending in the Broward County, Florida Circuit Court. Since being appointed by Circuit Court Judge Thomas Lynch IV last fall, it has been a privilege to act as the mediator and assist the parties and their counsel toward this agreed resolution. | want to extend my appreciation for the professionalism exhibited by the parties and their counsel with whom | worked directly: Jack Scarola, Rick Simpson, Tom Scott, and Ken Sweder. As part of their agreement, the parties have issued the attached Joint Statement. JOINT STATEMENT OF BRAD EDWARDS, PAUL CASSELL AND ALAN DERSHOWITZ REGARDING SETTLEMENT Brad Edwards, Paul Cassell and Alan Dershowitz have today settled their pending defamation claims in which Edwards and Cassell sued Dershowitz and Dershowitz counterclaimed against Edwards and Cassell. The case was about Dershowitz’s public claims that Edwards and Cassell, as the attorneys for Virginia Roberts, had failed to perform the necessary due diligence before filing the allegations of their client, not whether the acts of alleged misconduct in fact occurred. Edwards and Cassell vigorously denied the contention that they had acted improperly and asserted that it defamed them. Dershowitz countersued Edwards and Cassell, alleging they had falsely accused him of sexual contact with Roberts—a claim he vigorously denied and that Dershowitz asserted defamed him. Edwards and Cassell maintain that they filed their client’s allegations in good faith and performed the necessary due diligence to do so, and have produced documents detailing those efforts. Dershowitz completely denies any such misconduct, while not disputing Roberts’s statements that the underlying alleged misconduct may have occurred with someone else. Dershowitz has produced travel and other records for the relevant times which he relies on to establish that he could not have been present when the alleged GM_00523 HOUSE_OVERSIGHT_014844

Case 1:15-cv-07433-RWS Document 751-18 Filed 03/17/17 Page 3of3 misconduct occurred. He has also produced other evidence that he relies upon to refute the credibility of the allegations against him. The parties believe it is time to take advantage of the new information that has come to light on both sides during the litigation and put these matters behind them. Given the events that have transpired since the filing of the documents in the federal court and in this action in which Dershowitz was accused of sexual misconduct, including the court order striking the allegations in the federal court filings, and the records and other documents produced by the parties, Edwards and Cassell acknowledge that it was a mistake to have filed sexual misconduct accusations against Dershowitz; and the sexual misconduct accusations made in all public filings (including all exhibits) are hereby withdrawn. Dershowitz also withdraws his accusations that Edwards and Cassell acted unethically. Neither Edwards, Cassell, nor Dershowitz have any intention of repeating the allegations against one another. HHH # Editor’s note: Wiley Rein LLP represents Alan M. Dershowitz in this matter. GM_00524 HOUSE_OVERSIGHT_014845

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Case 9:08 aé807E5-d0A07 4 oR nilketinteniteréd-49 FES@ DSGCket104/7dg615 ofPidge 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.). HOUSE_OVERSIGHT_014847

Case 9:08 a8 07E5-d0A07 4 oR nilaetinteniterésd-49 FES@ DSGCkét104/P7dge15 ofPidge 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 1 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). “TOJut 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. II. 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 HOUSE_OVERSIGHT_014848

Case 9:0&aé807E5-d0A07 4 oR nileetinteniteréd-49 FES@ DSGCkét104/P7d ge ofPidge 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 is governed by Fed. R. Civ. P. 15(a)....”). 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 is 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). HOUSE_OVERSIGHT_014849

Case 9:0&aé807E5-d0A07 422A nilketinteniteréd -9 FES@ DSGCkét104/P7d ge 1 ofPidge 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 HOUSE_OVERSIGHT_014850

Case 9:0&aé807E5-d0A07 4 oA nilkxeinteniteréd-49 FES@0 DGCkét104/7dQ616 ofPidge 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” “[i]f 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). HOUSE_OVERSIGHT_014851

Case 9:0&aé807E5-d0A07 4 oR niLketinteniterésd-49 FES@ DGCket104/P7dge 15 ofPidge 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 is 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. HOUSE_OVERSIGHT_014852

Case 9:0&aé807E5-d0A07 4 oA nilkxetinteniterésd-49 FESb0 DGCkét104/7dg615 ofPidge 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 patties 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 HOUSE_OVERSIGHT_014853

Case 9:0&aé807E5-d0A07 4 oR nileeinteniterésd-49 FES@0 DSCkét104/P7d Qe 1S ofPidge 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]ll 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). HOUSE_OVERSIGHT_014854

Case 9:0€-ase8D T5é6cK AWK 3B RU BenDs6edmémieieh bh ALB De/dk4i 04/BAGH15 oP&ébe 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 HOUSE_OVERSIGHT_014855

Case 9:0&aé807E5-d0A07 4 oR nila nteniter6d -d9 FESé DGCkéti04/PaQgeral didde 10 of 10 agrees, and it concludes that justice does not require amending the petition this late in the proceedings. Il. 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. KENNETH A. MARRA United States District Judge 10 HOUSE_OVERSIGHT_014856