File 010887
Motion for Clarification of Confidentiality Order - Dershowitz v. Edwards and Cassell (File 010887)
Alan Dershowitz's motion seeking clarification or relief from a confidentiality order to disclose Virginia Giuffre's deposition testimony to law enforcement authorities, arguing her statements about meeting former President Clinton on Epstein's private island are false based on Secret Service records.
Summary
This legal filing is Dershowitz's motion requesting permission to submit Giuffre's sealed deposition transcript to prosecutors to investigate alleged perjury. Dershowitz argues that Giuffre's public affidavits claiming she met President Clinton on Little St. James Island between 2001-2002 are demonstrably false, citing former FBI Director Louis Freeh's FOIA-based analysis showing no Secret Service records of Clinton's presence on the island. The motion also references sealed testimony Dershowitz believes contains additional false statements by Giuffre. The document includes excerpts from Giuffre's declaration describing her recruitment and abuse by Epstein and Maxwell beginning at age 15 in 1999.
Filing # 37201585 E-Filed 01/29/2016 03:47:44 PMIN THE CIRCUIT COURT OF THESEVENTEENTH JUDICIAL CIRCUITIN AND FOR BROWARD COUNTY, FLORIDACASE NO.: CACE 15-000072BRADLEY J. EDWARDS andPAUL G. CASSELL,Plaintiffs/Counterclaim Defendants,vs.ALAN M. DERSHOWITZ,Defendant/Counterclaim Plaintiff/DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN DERSHOWITZ'SMOTION FOR CLARIFICATION OF CONFIDENTIALITY ORDER OR RELIEFFROM THAT ORDERThe transcript of the deposition of non-party Virginia Roberts Giuffre ("Roberts") iscurrently under seal as a result of the January 12, 2016 Confidentiality Order in this action.Dershowitz seeks clarification that the Confidentiality Order does not preclude him or hiscounsel from submitting the transcript of the deposition to the Office of the State Attorney, theOffice of the United States Attorney, and other appropriate investigative authorities solely forpurposes of requesting that those offices consider opening perjury investigations regardingRoberts's testimony. To the extent that the Confidentiality Order precludes such disclosure,Dershowitz requests that the Court modify it to permit the requested disclosure in the publicinterest.Roberts has stated in an affidavit originally filed publicly in federal court in what theparties have referred to as the CVRA Action that she was present on Jeffrey Epstein's privateisland, Little St. James Island, at the same time as former President Clinton. That affidavit was1HOUSE OVERSIGHT 010887stricken in relevant part from the record by the federal court, but Roberts's counsel filed publiclya pleading in this case contesting Defendant's assertion that her statements in the mediaregarding meeting former President Clinton were untrue. A copy of the public affidavit filed inthe CVRA Action and the excerpted portion of the pleading filed in this action are attachedhereto as composite Exhibit A.Because former President Clinton did not leave office until January of 2001, and Robertshas repeatedly stated in publicly filed affidavits that she "escaped" from Epstein while inThailand in September of 2002, the alleged meeting with former President Clinton must havetaken place between January of 2001 and September of 2002. As explained in the letter attachedas Exhibit B, former FBI Director Louis Freeh made a request pursuant to the Freedom ofInformation Act for documents from the Secret Service regarding Secret Service personneltravelling with former President Clinton to Epstein's private island and the US Virgin Islands.Based on the response by the federal government to this request, and his knowledge of the duties,protocols and operations of security provided to a former President, Mr. Freeh opines in theattached letter that the absence of such records "strongly establishes that former PresidentClinton was not present on Little St. James Island during the period at issue." If Mr. Freeh'sopinion is correct, then Roberts's publicly filed affidavits in which she stated that she metPresident Clinton on the island during that period are obviously false. Dershowitz intends tobring this public information to the attention of the appropriate authorities.Separate from the public information, Dershowitz also believes that Roberts gave falsetestimony at her deposition. The relevant testimony, which Dershowitz intends to provide to theappropriate authorities, is being filed under seal contemporaneously with this motion. In anabundance of caution, Dershowitz and his counsel do not want to disclose this non-public2HOUSE OVERSIGHT 010888information even to the responsible public officials with a right and need to know withoutobtaining confirmation from this Court that doing so would not violate the Confidentiality Orderor alternatively relief from that Confidentiality Order.Respectfully submitted,s/ Thomas E. ScottThomas E. ScottFlorida Bar No. 149100Thomas.scott@csklegal.comSteven R. Safi-aFlorida Bar No. 057028Steven.safra@csklegal.comCOLE, SCOTT & KISSANE, P.A.Dadeland Centre II, 14th Floor9150 South Dadeland BoulevardMiami, Florida 33156Phone: (305) 350-5300Fax: (305) 373-2294Richard A. Simpson (pro hac vice)rsimpson@wileyrein.comMary E. Borja (pro hac vice)mborja@wileyrein.comAshley E. Eiler (pro hac vice)aeiler@wileyrein.comNicole A. Richardson (pro hac vice)nrichardson@wileyrein.comWILEY REIN LLP1776 K Street NWWashington, DC 20006Phone: (202) 719-7000Fax: (202) 719-7049Kenneth A. Sweder (pro hac vice)ksweder@sweder-ross.comSWEDER & ROSS131 Oliver StreetBoston, MA 02110Phone: (617) 646-4466Fax: (617) 646-4470Counsel for Alan M. Dershowitz3HOUSE OVERSIGHT 010889CERTIFICATE OF SERVICEI HEREBY CERTIFY that a copy of the foregoing has been electronically filed throughthe Clerk of Broward County by using the Florida Courts eFiling Portal and thus served byelectronic mail: jsx@searcylaw.com, mep@searcylaw.com, scarolateam@searcylaw.com to:Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Plaintiff, 2139Palm Beach Lakes Blvd., West Palm Beach, Florida 33409; jonijones@utah.gov to: Joni J.Jones, Esq., Assistant Utah Attorney General, Counsel for Plaintiff Cassell, 160 East 300 South,Salt Lake City, Utah 84114; brad@pathtojustice.com to: Bradley J. Edwards, Esq, Farmer, Jaffeet al, 425 North Andrews Avenue, Suite 2, Ft. Lauderdale, FL 33301; cassellp@law.utah.edu, to:Paul G. Cassell, Esq.,; smccawley@bsfllp.com, sperkins@bsfllp.com, ftleserve@bsfllp.com to:Sigrid S. McCawley, Esq., Boies Schiller & Flexner, LLP, 401 E. Las Olas Blvd, Suite 1200, Ft.Lauderdale, FL 33301, this 29th day of January, 2016.By: s/ Thomas E. ScottTHOMAS E. SCOTTFBN: 149100STEVEN R. SAFRAFBN: 0570284HOUSE OVERSIGHT 010890EXHIBIT AHOUSE OVERSIGHT 010891Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 2 of 20UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDACASE NO. 08-80736-CIV-MARRAJANE DOE #1 and JANE DOE #2,Petitioners,VS.UNITED STATES OF AMERICA,Respondent./DECLARATION OF1. My name is and I was born in August, 1983.2. I am currently 31 years old.3. I grew up in Palm Beach, Florida. When I was little, I loved animals and wantedto be a veterinarian. But my life took a very different turn when adults began to be interested inhaving sex with me.4. In approximately 1999, when I was 15 years old, I met Ghislaine Maxwell. She isthe daughter of Robert Maxwell, who had been a wealthy publisher in Britain. Maxwell askedthat I come with her to Jeffrey Epstein's mansion for the purposes of teaching me how toperform "massages" and to train me professionally in that area. Soon after that I went toEpstein's home in Palm Beach on El Brillo Way.5. From the first time I was taken to Epstein's mansion that day, his motivations andactions were sexual, as were Maxwell's. My father was not allowed inside. I was brought upsome stairs. There was a naked guy, Epstein, on the table in the room. Epstein and Maxwellforced me into sexual activity with Epstein. I was 15 years old at the time. He seemed to be inhis 40s or 50s. I was paid $200. I was driven home by one of Epstein's employees.1HOUSE OVERSIGHT 010892Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 3 of 2026. I came back for several days following and did the same sorts of sexual things forEpstein.7. After I did those things for Epstein, he and Maxwell said they were going to haveme travel and were going to get an education for me. They were promising me the world, that Iwould travel with Epstein on his private jet and have a well-paid profession. Epstein said hewould eventually match me up with a wealthy person so that I would be "set up" for life.8. So I started "working" exclusively for Epstein. He took me to New York on hisbig, private jet. We went to his mansion in New York City. I was shown to my room, a veryluxurious room. The mansion was huge. I got scared because it was so big. Epstein brought meto a room with a massage parlor. To me, it looked like an S&M parlor. Epstein made me engagein sexual activities with him there.9. You can see how young I looked in the photograph below.HOUSE OVERSIGHT 010893Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 4 of 2010. Epstein took me on a ferry boat on one of the trips to New York City and there hetook the picture above. I was approximately 15 or 16 years old at the time.11. Over the next few weeks, Jeffrey Epstein and Ghislaine Maxwell trained me to dowhat they wanted, including sexual activities and the use of sexual toys. The training was inNew York and Florida, at Epstein's mansions. It was basically every day and was like going toschool. I also had to have sex with Epstein many times.12. I was trained to be "everything a man wanted me to be." It wasn't just sexualtraining - they wanted me to be able to cater to all the needs of the men they were going to sendme to. They said that they loved that I was very compliant and knew how to keep my mouthshut.13. Epstein and Maxwell also told me that they wanted me to produce things for themin addition to performing sex on the men. They told to me to pay attention to the details aboutwhat the men wanted, so I could report back to them.14. From very early on I was fearful of Epstein. Epstein told me he was a billionaire.I told my mother that I was working for this rich guy, and she said "go, go far away." Epsteinhad promised me a lot, and I knew if I left I would be in big trouble. I also knew that I was awitness to a lot of illegal and very bad behavior by Epstein and his friends. If I left Epstein, heknew all kinds of powerful people. He could have had me killed or abducted, and I always knewhe was capable of that if I did not obey him. He let me know that he knew many people in highplaces. Speaking about himself, he said "I can get away" with things. I was very scared,particularly since I was a teenager.3HOUSE OVERSIGHT 010894Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 5 of 2015. I visited and traveled with Jeffrey Epstein from 1999 through the summer of2002, and during that time I stayed with him, as his sex slave, at each of his houses (really morelike mansions) in locations including New York City, New York; the area of Santa Fe, NewMexico; Palm Beach, Florida; an island in the U.S. Virgin Islands; and Paris, France. I had sexwith him often in these places and also with the various people he demanded that I have sexwith. Epstein paid me for many of these sexual encounters. In fact, my only purpose forEpstein, Maxwell and their friends was to be used for sex.16. To illustrate my connection to these places, I include four photographs taken ofme in New Mexico (shown below). The first one is a museum in Santa Fe, New Mexico. Wehad gone sightseeing for the day. Epstein took this picture of me. I was approximately 17 at thetime, judging from the looks of it. At the end of the day we returned to Epstein's Zorro Ranch.The second picture is me on one of Epstein's horses on the ranch in New Mexico. The followingtwo are from wintertime in New Mexico.4HOUSE OVERSIGHT 010895Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 6 of 20li.17. When I was with him, Epstein had sex with underage girls on a daily basis. Hisinterest in this kind of sex was obvious to the people around him. The activities were so obvious5HOUSE OVERSIGHT 010896Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 7 of 20and bold that anyone spending any significant time at one of Epstein's residences would haveclearly been aware of what was going on.18. Epstein's code word for sexual encounters was that it was a "massage". At timesthe interaction between Epstein and the girls would start in a massage room setting, it wasalways a sexual encounter and never just a massage.19. In addition to constantly finding underage girls to satisfy their personal desires,Epstein and Maxwell also got girls for Epstein's friends and acquaintances. Epstein specificallytold me that the reason for him doing this was so that they would "owe him," they would "be inhis pocket," and he would "have something on them." I understood him to mean that whensomeone was in his pocket, they owed him favors. I also understood that Epstein thought hecould get leniency if he was ever caught doing anything illegal, or more so that he could escapetrouble altogether.20. Ghislaine Maxwell was heavily involved in the illegal sex. I understood her to bea very powerful person. She used Epstein's money and he used her name and connections togain power and prestige.21. One way to describe Maxwell's role was as the "madame." She assumed aposition of trust for all the girls, including me. She got me to trust her and Epstein. It turned outthat Maxwell was all about sex all the time. She had sex with underage girls virtually every daywhen I was around her, and she was very forceful.22. I first had sexual activities with her when I was approximately 15 at the PalmBeach mansion. I had many sexual activities with her over the next several years in Epstein'svarious residences plus other exotic locations. I had sex with Maxwell in the Virgin Islands,6HOUSE OVERSIGHT 010897Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 8 of 20New Mexico, New York, as well as France and many other locations. I also observed Maxwellhave sex with dozens of underage girls.23. Maxwell took pictures of many of the underage girls. These pictures weresexually explicit. Maxwell kept the pictures on the computers in the various houses. She alsomade hard copies of these images and displayed them in the various houses. Maxwell had largeamounts of child pornography that she personally made. Many times she made me sleep withother girls, some of whom were very young, for purposes of taking sexual pictures.24. Harvard law professor Alan Dershowitz was around Epstein frequently.Dershowitz was so comfortable with the sex that was going on that he would even come and chatwith Epstein while I was giving oral sex to Epstein.25. I had sexual intercourse with Dershowitz at least six times. The first time waswhen I was about 16, early on in my servitude to Epstein, and it continued until I was 19.26. The first time we had sex took place in New York in Epstein's home. It was inEpstein's room (not the massage room). I was approximately 16 years old at the time. I calledDershowitz "Alan." I knew he was a famous professor.27. The second time that I had sex with Dershowitz was at Epstein's house in PalmBeach. During this encounter, Dershowitz instructed me to both perform oral sex and havesexual intercourse.28. I also had sex with Dershowitz at Epstein's Zorro Ranch in New Mexico in themassage room off of the indoor pool area, which was still being painted.29. We also had sex at Little Saint James Island in the U.S. Virgin Islands. I wasasked to give Dershowitz a massage on the beach. Dershowitz then asked me to take himsomewhere more private, where we proceeded to have intercourse.7HOUSE OVERSIGHT 010898Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 9 of 2030. Another sexual encounter between me and Dershowitz happened on Epstein'sairplane. Another girl was present on the plane with us.31. I have recently seen a former Harvard law professor identified as AlanDershowitz on television calling me a "liar." He is lying by denying that he had sex with me.That man is the same man that I had sex with at least six times.32. Epstein made me have sex with Prince Andrew several times. Prince Andrew,Maxwell, and I are shown in the photograph below. I had sex with him three times, includingone orgy. I knew he was a member of the British Royal Family, but I just called him "Andy."33. One day when I was in London (specifically in a townhouse that is underMaxwell's name), I got news from Maxwell that I would be meeting a prince. Later that day,Epstein told me I was meeting a "major prince." Epstein told me "to exceed" everything I hadbeen taught. He emphasized that whatever Prince Andrew wanted, I was to make sure he got.34. Eventually Prince Andrew arrived, along with his security guards. The guardsthen went out of the house and stayed out front in their car. It was just Epstein, Maxwell, and meinside alone with Andy. I was introduced to the Prince, and we kissed formally, cheek to cheek.8HOUSE OVERSIGHT 010899Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 10 of20There was a lot of legal discussion about Andy and his ex-wife ("Fergie"). Then the discussionturned to me. Maxwell said "guess how old she is." Prince Andrew guessed 17.35. Then we all went to a Chinese restaurant for dinner and then to Club Tramp, afancy "members only" night club in central London. Andy arranged for alcohol to be providedto me at the club. Eventually we left. I rode with Epstein and Maxwell back to the townhouse.On the way there, Epstein and Maxwell informed me that the Prince wanted to see "more of me"that night. Andy traveled in a separate car with his guards.36. We all arrived back at the townhome and went upstairs. Epstein took a picture ofme and Andy with my own camera. The picture above is that picture, which has been widelycirculated on the internet. Andy has his left arm around my waist and is smiling. The picture wasdeveloped on March 13, 2001, and was taken sometime shortly before I had it developed. I was17 years old at the time.37. I wanted a picture with the prince because I was keeping in contact with myfamily. I had told my mom and my grandma that I was meeting Prince Andrew and that I'd takea picture for them. They told me to "be careful."38. After the picture, Epstein and Maxwell kissed me and said to "have fun." Theyleft Andy and me alone upstairs. We went to the bathroom and bedroom, which were just stepsaway from where the picture was taken. We engaged in sexual activities there. Afterwards,Andy left quickly with his security.39. I chatted with Epstein about this the next day. I told him, "it went great." Epsteinsaid something to the effect of, "You did well. The Prince had fun." I felt like I was beinggraded. It was horrible to have to recount all these events and have to try to meet all these needs9HOUSE OVERSIGHT 010900Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 11 of20and wants. I told Epstein about Andy's sexual interests in feet. Epstein thought it was veryfunny. Epstein appeared to be collecting private information about Andy.40. When I got back from my trip, Epstein paid me more than he had paid me to bewith anyone else — approximately $15,000. That money was for what I had done and to keep mymouth shut about "working" with the Prince.41. The second time I had sex with Prince Andrew was in Epstein's New Yorkmansion in spring 2001. I was 17 at time. Epstein called me down to his office. When I gotthere, Epstein was there, along with Maxwell, Johanna Sjoberg, and Andy. I was very surprisedto see him again. Epstein and Maxwell were making lewd jokes about "Randy Andy".42. I had the impression that Andy had come there to see Epstein and to have sex mewith. There was no other apparent purpose for Andy to be there.43. I was told to go upstairs with Andy and to go to the room I thought of as the"dungeon" (the massage room, but it is really scary looking). I had sex with Andy there. I wasonly paid $400 from Epstein for servicing Andy that time.44. The third time I had sex with Andy was in an orgy on Epstein's private island inthe U.S. Virgin Islands. I was around 18 at the time. Epstein, Andy, approximately eight otheryoung girls, and I had sex together. The other girls all seemed and appeared to be under the ageof 18 and didn't really speak English. Epstein laughed about the fact they couldn't reallycommunicate, saying that they are the "easiest" girls to get along with. My assumption was thatJean Luc Brunel got the girls from Eastern Europe (as he procured many young foreign girls forEpstein). They were young and European looking and sounding.45. Afterwards we all had dinner by the cabanas. The other girls were chatting awayamong themselves, and Epstein and the Prince chatted together. I felt disgusted, and went10HOUSE OVERSIGHT 010901Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 12 of20quickly to my own cabana that night and went to sleep. Prince Andrew must have flown outearly the next morning, as I did not see him when I got up.46. I have seen Buckingham Palace's recent "emphatic" denial that Prince Andrewhad sexual contact with me. That denial is false and hurtful to me. I did have sexual contactwith him as I have described here — under oath. Given what he knows and has seen, I washoping that he would simply voluntarily tell the truth about everything. I hope my attorneys caninterview Prince Andrew under oath about the contacts and that he will tell the truth.47. I also had sexual intercourse with Jean Luc Brunel many times when I was 16through 19 years old. He was another of Epstein's powerful friends who had many contacts withyoung girls throughout the world. In fact, his only similarity with Epstein and the only link totheir friendship appeared to be that Brunel could get dozens of underage girls and feed Epstein's(and Maxwell's) strong appetite for sex with minors.48. Brunel ran some kind of modeling agency and appeared to have an arrangementwith the U.S. Government where he could get passports or other travel documents for younggirls. He would then bring these young girls (girls ranging in age from 12 to 24) to the UnitedStates for sexual purposes and farm them out to his friends, including Epstein.49. Brunel would offer the girls "modeling" jobs. A lot of the girls came from poorcountries or poor backgrounds, and he lured them in with a promise of making good money.50. I had to have sex with Brunel at Little St. James (orgies), Palm Beach, New YorkCity, New Mexico, Paris, the south of France, and California. He did not care aboutconversation, just sex.51. Jeffrey Epstein has told me that he has slept with over 1,000 of Brunel's girls, andeverything that I have seen confirms this claim. Epstein, Brunel, and Maxwell loved orgies with11HOUSE OVERSIGHT 010902Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 13 of20kids — that is, having sexual interactions with many young teenagers at the same time.Sometimes as many as ten underage girls would participate in a single orgy with them. Ipersonally observed dozens of these orgies. The orgies happened on Epstein's island in the U.S.Virgin Islands, in New Mexico, Palm Beach, and many other places. Most of the girls did notspeak English. It was my understanding that the girls had been persuaded to come by Bruneloffering them illegal drugs or a career in modeling. Brunel was one of the main procurers ofgirls.52. In addition to Ghislaine Maxwell,, and were alsoinvolved in the orgies. At this stage, I am hopeful that these other women will come forward andtell the truth about everything because that will help prevent future similar abuse.53. I have seen reports saying or implying that I had sex with former President BillClinton on Little Saint James Island. Former President Bill Clinton was present on the Island ata time when I was also present on the Island, but I have never had sexual relations with Clinton,nor have I ever claimed to have had such relations. I have never seen him have sexual relationswith anyone.54. I now understand that Epstein reached a non-prosecution agreement with thefederal government in 2007 and pled guilty to two state crimes in June 2008. I now know that Iwas identified by the federal government as one of Epstein's and his co-conspirator's sexuallyabused victims. However, no one told me about those events until after they happened.55. On September 3, 2008, the FBI sent a victim notification letter to me. This wasthe first written communication I had received from the FBI. The letter is attached as Exhibit 1.The letter describes an agreement in which compensation would be made victims of Epstein's12HOUSE OVERSIGHT 010903Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 14 of20sexual abuse. The letter also said that the federal government was going to "defer federalprosecution." No one had told me about deferring federal prosecution before this.56. In 2011, two FBI agents, called me in Australia and then came to meet me. Theymet me at the U.S. Consulate in Sidney. They seemed to be very professional and hard working.I thought to myself, "Wow, these people will do the right thing against the bad guys and protectme."57. The agents were mainly focused on Epstein but while there I provided them someinformation about others who were involved in illegal acts as well. I was aware that a falsestatement to these law enforcement officers was a crime and I told the truth — giving them theinformation that I could recall about the individuals they inquired about.58. Epstein also trafficked me for sexual purposes to many other powerful men,including politicians and powerful business executives. Epstein required me to describe thesexual events that I had with these men presumably so that he could potentially blackmail them.I am still very fearful of these men today.59. I will continue to cooperate fully in the investigation and prosecution of Epstein,Maxwell, or any of their friends who participated in the sexual abuse of minors. I also hope thatthis information is treated in a way that will keep me safe from Epstein and others criminalsidentified here so as to encourage more victims of similar crimes to come forward. If thesecrimes are not prosecuted, despite my volunteering this information and cooperation, then it maydeter other similar victims from coming forward.60. In this affidavit, I have tried to focus on how I was trafficked for sexual purposes.I have not described all of the details of the sexual activities Epstein forced me to have. Also, Ihave not described all of the details of the other events discussed here. If a judge wants me to13HOUSE OVERSIGHT 010904Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 15 of20present my information in more detail, including more specific descriptions of the sexualactivities with the men Epstein sent me to, I could do so.61. I have directed my attorneys, Bradley J. Edwards and Paul G. Cassell, to pursueall reasonable and legitimate means to have criminal charges brought against these powerfulpeople for the crimes they have committed against me and other girls. They are representing mein this case pro bono.62. Since I filed my motion in this case, my credibility has been attacked. I am tellingthe truth and will not let these attacks prevent me from exposing the truth of how I was traffickedfor sex to many powerful people. These powerful people seem to think that they don't have tofollow the same rules as everyone else. That is wrong. I hope that by coming forward, I canhelp expose the problem of sex trafficking and prevent the same sort of abuse and degradationthat happened to me from happening to other girls.63. I declare under penalty of peijury that the foregoing is true and correct.Executed thisday of January, 2015.(Location of signature left undisclosed for security reasons)14HOUSE OVERSIGHT 010905Filing # 33754151 E-Filed 10/27/2015 06:33:15 PMIN THE CIRCUIT COURT OF THE 17THJUDICIAL CIRCUIT IN AND FORBROWARD COUNTY, FLORIDACIVIL DIVISIONBRADLEY J. EDWARDS, andPAUL G. CAS SELL,Plaintiffs,V.ALAN DERSHOWITZ,Defendant.CASE NO. CACE 15-000072CONSOLIDATED REPLY IN SUPPORT OF NON-PARTY JANE DOE NO. 31 ANDBOIES, SCHILLER & FLEXNER LLP's MOTIONS TO QUASH OR FORPROTECTIVE ORDERS REGARDING SUBPOENA SERVED ON THE NON-PARTIESDefendant served virtually identical subpoenas on non-party Giuffre, and her counselBoies, Schiller & Flexner LLP ("BSF"). In an effort to conserve judicial resources, the non-parties are submitting a consolidated reply requesting that this Court quash the unreasonable andoppressive subpoenas pursuant to Florida Rules of Civil Procedure 1.410(c)(1), or alternatively,issue protective orders sharply limiting the scope of the abusive subpoenas pursuant to FloridaRules of Civil Procedure 1.280(c).INTRODUCTIONAfter publicly stating that his main goal in seeking discovery from Giuffre is to put her in"jail"2, Defendant served this non-party with a subpoena containing twenty five (25)unreasonable and oppressive requests. It is without question that Giuffre was sexually abused as1Jane Doe No. 3 is Virginia Roberts Giuffre, and will hereinafter be referred to as "Giuffre."2 See Exhibit 1, CNN International, New Day, January 6, 2015. See also Exhibit 2, Australian Broadcasting System(ABC), January 6, 2015. "My goal is to bring charges against the client and require her to speak in court."1HOUSE OVERSIGHT 010906Jeffrey Epstein. Defendant spends over five (5) pages discussing the federal action and eleven(11) of his subpoena Requests (Jane Doe Subpoena 1, 5, 6, 7, 8, 9, 12, 13, 14, 22 and 24; BSFSubpoena 3, 6, 7, 8, 9, 10, 12, 13, 14, 19 and 22) relate to the federal action or Jeffrey Epstein.For example, Request 24 seeks "All documents concerning, relating or referring to yourassertion that you met former President Bill Clinton, former Vice President Al Gore and/or MaryElizabeth "Tipper" Gore on Little Saint James Island in the U.S. Virgin Islands." Defendantclaims that this discovery would go to the issue of whether or not Giuffre is telling the truthabout Defendant — but that effort at impeachment is clearly collateral at best and fails to addressthe central issue in this case. That issue is whether the Defendant had any basis to support hismedia assault against two lawyers claiming that they fabricated and then publicly filed falsecharges of criminal conduct on the part of the Defendant. It is the Defendant's credibility andnot the credibility of Giuffre that is the focus of this defamation action. Defendant suggests thatGiuffre must be a liar because it would be unheard of for one of Epstein's young girls to havemet President Clinton. Quite the opposite is true. There are a number of accounts documentingClinton's regular visits with Epstein. For example, Chauntae Davies recently showed pictures onThe Inside Edition program of her travels with other young women in the company of BillClinton and Jeffrey Epstein on Epstein's plane. See Exhibit 4, Tolita Express ' MasseuseReveals Lurid Details from Jeffrey Epstein's Private Plane For the Rich, Inside Edition, April27, 2015. The Epstein flight logs also demonstrate that former President Bill Clinton traveledwith Jeffrey Epstein and other young women. See Exhibit 5, The Gauker, January 22, 2015. Allof that information, while no doubt interesting, is irrelevant to the defamation issue before thisCourt except to the extent it casts doubt on the Defendant's own credibility.7HOUSE OVERSIGHT 010907EXHIBIT BHOUSE OVERSIGHT 010908Professor Alan DershowitzHarvard Law School1575 Massachusetts AvenueHauser Hall 518Cambridge, MA 02138Hon. Louis J. FreehMobile: 202.215.8321January 22, 2016RE: FOIA RequestDear Professor Dershowitz:As you know, on April 6, 2015, a request was made to the United States Secret Service under the federalFreedom of Information Act (FOIA; 5 U.S.C. Sec. 552), relating to the period 1/01/01 to 1/1/03, for "anyand all shift logs, travel records, itineraries, reports and other records for USSS personnel traveling withformer President Bill Clinton to Little St. James Island and the US Virgin Islands" (Attachment A).The basis of the above-described FOIA request was a claim by Virginia Roberts, in court papers filed inearly 2015 in Florida federal court, that she and former President Clinton were on Little St. James Islandat the same time during the 1/01/01 to 1/1/03 period.As set forth in a January 16, 2016 letter from Kim E. Campbell, United States Secret service SpecialAgent In Charge, Freedom of Information Act and Privacy Act Officer, the "USSS has conducted areasonable search for responsive records. It appears, from a review of USSS main indices, that there areno records pertaining to your request that are referenced in these indices" (Attachment B).I therefore conclude from this response that former President Clinton did not in fact travel to, nor was hepresent on, Little St. James Island between January 1, 2001 and January 1, 2003.Based upon my experience and knowledge of the duties, protocols and operations of USSS ProtectiveDetails, the Special Agents accompany and escort former President Clinton 24 hours per day, and wouldhave certainly went with him to Little St. James Island during the period at issue. If the Agents hadaccompanied the former President to that location, they would had been required to make and file shiftlogs, travel vouchers and related documentation relating to the visit.The total absence of any such records and documentation, in my opinion, strongly establishes that formerPresident Clinton was not present on Little St. James Island during the period at issue.Best Regards,Louie FreehHOUSE OVERSIGHT 010909DEPARTMENT OF HOMELAND SECURITYUNITED STATES SECRET SERVICEWASHINGTON, D.C. 20223Freedom of Information Act and Privacy Act BranchCommunications Center245 Murray Lane, SW, Building T-5Washington, D.C. 20223Date:Patti Bescript3711 Kennett Pike, Suite 130Wilmington, DE 19807File Number: 20150826Dear Requester:This is the final response to your Freedom of Information Act/Privacy Acts (FOIA/PA) requestoriginally received by the United States Secret Service (USSS) on April 16, 2015, for informationpertaining to any and all shift logs, travel records, itineraries, reports, and other records for USSSpersonnel traveling with former President Bill Clinton to Little St. James Island and the US VirginIslands.In response to your request, the USSS has conducted a reasonable search for responsive records. Itappears, from a review of USSS main indices, that there are no records pertaining to your requestthat are referenced in these indices. Enclosed is a copy of your original request.Alternatively, if you deem our decision an adverse determination, you may exercise your appealrights. Should you wish to file an administrative appeal, your appeal should be made in writing andreceived within sixty (60) days of the date of this letter, by writing to: Freedom of InformationAppeal, Deputy Director, U.S. Secret Service, Communications Center, 245 Murray Lane, S.W.,Building T-5, Washington, D.C. 20223. If you choose to file an administrative appeal, pleaseexplain the basis of your appeal and reference the case number listed above.If you have any questions or would like to discuss this matter, please contact this office at(202) 406-6370. FOIA File No. 20150826 is assigned to your request. Please refer to this filenumber in all future communication with this office.Enclosure: Copy of Original RequestS CampbellbotalL--raI Agent In Charge1171(Freedom of Information Act & Privacy Act OfficerHOUSE OVERSIGHT 010910Patti Bescript3711 Kennett PikeSuite 130Wilmington, DE 19807302 824 7144April 6, 2015Delores BarberDeputy Chief FOIA Officer, Director, Disclosure & FOIA, The Privacy OfficeDepartment of Homeland SecurityHeadquarters & Privacy OfficeBuilding 410 - STOP-0655245 Murray Drive, SWWashington, DC 20528-0655FOIA REQUESTDear FOIA Officer:Pursuant to the federal Freedom of Information Act, 5 U.S.C. § 552, I request access toand copies of For the period 1/1/01 to 1/1/03, any and all shill logs, travel records,itineraries, reports, and other records for USSS personnel traveling with former PresidentBill Clinton to Little St James Island and the US Virgin Islands.I agree to pay reasonable duplication fees for the processing of this request.If my request is denied in whole or part, I ask that you justify all deletions by reference tospecific exemptions of the act. I will also expect you to release all segregable portions ofotherwise exempt material. I, of course, reserve the right to appeal your decision towithhold any information or to deny a waiver of fees.I look forward to your reply within 20 business days, as the statute requires.Than you for your assistance.SiqcdreIY.Patti BescriptHOUSE OVERSIGHT 010911