[REDACTED - Survivor] v. Alan Dershowitz – Allegations of Sex Trafficking, NPA Manipulation, and Defamation

Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 1 of 28 United States District Court Southern District of New York VIRGINIA L. GIUFFRE, Plaintiff, CASE NO: v. ALAN DERSHOWITZ, Defendant. ________________________ / COMPLAINT Boies Schiller Flexner LLP Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 2 of 28 Plaintiff, VIRGINIA L. GIUFFRE, formerly known as [REDACTED] (“Roberts”), for her Complaint against Defendant, Alan Dershowitz (“Dershowitz”) avers upon personal knowledge as to her own acts and status and upon information and belief and to all other matters: NATURE OF THE ACTION 1. This suit arises out of Defendant’s defamatory statements of and concerning Plaintiff. 2. During 2000-2002, beginning when Plaintiff was 16, Plaintiff was the victim of sex trafficking and abuse by convicted sex offender Jeffrey Epstein. 3. Epstein’s trafficking scheme involved recruiting young girls, often by claiming they would be paid $200 for simply providing a massage to a wealthy billionaire. The young girl would then be brought up to Epstein’s bedroom where Epstein would be on a massage table; Epstein would then sexually abuse the girl. This same pattern was repeated numerous times with numerous children. 4. “From between 1999 – 2007, Jeffrey Epstein sexually abused more than 30 minor girls…in his mansion in Palm Beach Florida, and elsewhere in the United States and overseas… In addition to his own sexual abuse of the victims, Epstein directed other persons to abuse the girls sexually. Epstein used paid employees to find and bring minor girls to him. Epstein worked in concert with others to obtain minors not only for his sexual gratification, but also for the sexual gratification of others.” United States District Court Judge Marra February 21, 2016 Summary Judgement Order at 2, Case No.: 9:08-cv-80786 (internal citations omitted). One of the persons with whom Epstein acted in concert was Dershowitz. 5. Like other minor children who came before and after her, Plaintiff was initially recruited to provide massages, and thereafter to engage in a variety of sexual acts, for Epstein. 2 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 3 of 28 Plaintiff was required to be on call for Epstein for sexual purposes and frequently traveled with him both nationally and internationally. Plaintiff was regularly abused by Epstein and was lent out by Epstein to others for sexual purposes. 6. Defendant Dershowitz was Epstein’s attorney, close friend, and co-conspirator. Dershowitz was also a participant in sex trafficking, including as one of the men to whom Epstein lent out Plaintiff for sex. 7. When Epstein was arrested for sex trafficking in 2006, Dershowitz defended his friend and client by falsely attacking the veracity of his accusers, including calling the children whom Epstein had abused (and, in the case of Plaintiff, the Defendant himself had also abused), liars and prostitutes. 8. Despite his significant criminal activity, Epstein’s criminal charges were resolved by a guilty plea to a single Florida state law charge and a non-prosecution agreement (a “NPA”) with the U.S. Attorney for the Southern District of Florida. Unknown to the public and the victims at the time, Epstein’s lawyers, including Dershowitz, were pressuring the Government to commit to the NPA without informing the victims. Epstein’s multiple victims, including Roberts, were kept in the dark and told to be “patient” while Dershowitz participated in the drafting of the NPA and worked to protect Epstein and other “potential co-conspirators” (including himself) from prosecution. 9. On July 7, 2008, a challenge to the NPA was brought on behalf of two of Epstein’s victims (not including Plaintiff) based on the fact that, contrary to the requirements of the Criminal Victims’ Rights Act (the “CVRA”), the NPA had been concealed from Epstein’s victims. 3 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 4 of 28 10. In December 2014, Roberts, who had not initially been part of the CVRA action, was asked to, and did, provide information to Plaintiffs’ counsel in the CVRA case in which she discussed her sex trafficking by Epstein. On December 31, 2014, Plaintiff’s counsel in the CVRA proceeding (Brad Edwards and Paul Cassell) filed a Motion Pursuant to Rule 21 for Joinder in the Action (“Joinder Motion”) on behalf of Roberts. Ms. Roberts’s joinder motion described how she had been sexually trafficked by Jeffrey Epstein and was forced to have sex with, among others, Alan Dershowitz. 11. Based on Plaintiff’s December 2014 filing, Dershowitz, as he had previously done to Epstein’s victims, publically and viciously attacked plaintiff’s counsel in the CVRA actions, Brad Edwards and Paul Cassell. Dershowitz, in nationally televised news interviews, wrongfully claimed that Edwards and Cassell had engaged in unethical behavior warranting disbarment for filing the Joinder Motion that described Dershowitz’s involvement with Epstein and Roberts. Edwards, who is a prominent attorney for sexually abused women and children, and Cassell who is a former United States District Court judge who left the bench to advocate for criminal victims, sued Dershowitz for defamation. Edwards and Cassell asserted that the factual allegations that Dershowitz had knowledge of and participated in Epstein’s criminal conduct were entirely proper and well founded and that Dershowitz’s statements about Edwards and Cassell were defamatory. 12. In April 2016 Dershowitz settled the Edwards and Cassell defamation claims against him. As a condition of the settlement, Dershowitz required that the financial terms of the settlement be kept confidential. 13. In November 2018, after conducting a lengthy investigation that involved interviewing over eighty (80) women, the Miami Herald published the first in a series of articles 4 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 5 of 28 exposing how Epstein and his lawyers had corrupted the legal system to obtain the NPA and referring to Dershowitz’s sexual abuse of Roberts. Dershowitz’s response on behalf of himself and his client and co-conspirator Epstein has been a desperate barrage of false and increasingly defamatory attacks on Roberts. The purpose and effect of these attacks has been to damage Robert’s reputation and credibility and to try to intimidate her into silence. 14. Defendant’s central assertion is that Roberts has committed perjury, and that in December 2014, Roberts and her attorneys hatched a scheme to falsely accuse Dershowitz of sex trafficking as part of a criminal attempt to extort a settlement from another party. 15. As Defendant and Epstein well knew, Dershowitz’s assertion was false. Dershowitz and Epstein knew that Dershowitz had in fact had sex with Plaintiff. Dershowitz and Epstein also knew that Roberts’s assertions about Dershowitz were not part of any criminal extortion plot. Indeed, Dershowitz and Epstein knew that Roberts had identified Dershowitz as a sexual predator years before December 2014. 16. Defendant’s knowledge of the falsity of his attacks on Roberts have not, however, limited the scope or scale of those attacks. 17. Examples of Dershowitz’s knowingly false and malicious defamatory statements made on behalf of himself and Epstein are: (a) November 28, 2018: “the story was 100% flatly categorically made up” and “Roberts and her attorneys fabricated the assertion in order to get money from other powerful, wealthy people”. (Exhibit 1, p. 8). (b) December 1, 2018: “I never met Roberts; I never had sex with her; she simply made up the entire story for money”. (Exhibit 2). 5 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 6 of 28 (c) December 2, 2018: “I was ‘deliberately framed for financial reasons’”; Roberts made her claims about Dershowitz “in order to obtain money from a wealthy businessman and that Roberts had never previously included me among the people with whom she claimed to have had sex”; “one of Roberts’ own lawyers has acknowledged in front of witnesses that Roberts claims against me are ‘wrong’ ‘simply wrong’”; “I never met Roberts; I never had sex with her; she simply made up the entire story for money”. (Exhibit 3). (d) December 4, 2018: Plaintiff is a “certified, complete, total liar”; “I can prove conclusively that she made the whole thing up”. At the same time Dershowitz claimed “that the FBI recognized the evidence showed he was not where she said he was”. (Exhibit 4). (e) December 5, 2018: “Roberts made up the accusations out of whole cloth in order to obtain millions of dollars from Leslie Wexner” and “there is evidence that directly proves I was framed. These include emails between Roberts and a journalist, a book manuscript by Roberts and a legal brief that are smoking guns showing that I was deliberately framed for financial reasons.” (Exhibit 5). (f) March 2, 2019: “My perjuring accusers are [REDACTED] and Sarah Ransome [who reported that Epstein lent her out to Dershowitz for sex at the same time as Dershowitz was, at Epstein’s request, representing Ransome as her lawyer]. Both have long records of lying”. (Exhibit 6). 18. Dershowitz and Epstein knew Dershowitz’s assertions about Roberts, including his assertions referenced in paragraph 17 above, were, and would be taken by persons who read and heard them to be, specific statements of fact. 6 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 7 of 28 19. Dershowitz has repeatedly, publically claimed that he wanted to have a trial that would determine the facts concerning his conduct. He said on national television that he would waive the statute of limitations so that Roberts could sue him for sex abuse. However, when Robert’s counsel asked Dershowitz to do so, Dershowitz refused -- and continues to refuse. 20. Similarly, when Dershowitz was faced with an actual case brought by Edwards and Cassell which would have determined the veracity of Roberts’ claims, Dershowitz settled to avoid that determination. 21. More recently, Dershowitz, perhaps believing that Roberts who is now living with her husband and children in Australia would not be prepared to engage in litigation, has again taken to claiming publically that he demands a trial on the question of whether Roberts committed perjury and made up her statements about him for money. For example on March 2, 2019: My “accusers are [REDACTED] and [REDACTED]…I hereby accuse my false accusers of committing the felony of perjury and challenge them to sue me for defamation.” (Exhibit 6). 22. Mr. Dershowitz now has what he claims to have been looking for. JURISDICTION AND VENUE 23. This is an action for damages in an amount in excess of the minimum jurisdictional limits of this Court. 24. This Court has jurisdiction over this dispute pursuant to 28 U.S.C. §1332 (diversity jurisdiction) in that Roberts and Dershowitz are citizens of different states and the amount in controversy exceeds seventy-five thousand ($75,000), exclusive of interest and costs. 25. This Court has personal jurisdiction over Defendant. Defendant resides in New York City; Defendant conducts regular business in New York City; and this action arose, 7 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 8 of 28 defamatory statements were made, and abuse occurred, within the Southern District of New York. 26. Venue is proper in this Court as (a) the cause of action arose within the jurisdiction of this Court and (b) Defendant resides within this District. PARTIES 27. Plaintiff is an individual who is a citizen of the State of Florida and a resident of Australia. 28. Defendant Dershowitz is an individual who resides in the Southern District of New York at 2 Tudor City Place Apt. 10EN, New York, New York 10017. 29. Jeffrey Epstein is an individual who resides in the Southern District of New York at 9 East 71 st Street, New York, New York, 10021. FACTUAL ALLEGATIONS A. Epstein’s Sex Trafficking Enterprise 30. Plaintiff became a victim of sex trafficking and repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein when Plaintiff was under the age of eighteen. 31. Between 2000 and 2002, Epstein sexually abused Roberts at numerous locations including his mansions in West Palm Beach, Florida, New Mexico, the Virgin Islands, and this District. Epstein also flew Roberts on his plane nationally and internationally numerous times when she was under the age of 18. Only portions of the flight logs of Epstein’s private planes are yet known, and Epstein also flew Roberts frequently on commercial airlines to meet him and others. However, the chart below which shows Roberts’ flights on Epstein’s private plane from the limited logs that are available illustrates the international scope of Epstein’s sex trafficking. 8 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 9 of 28 32. Between 1999 and 2007, with the assistance of numerous co-conspirators, Epstein abused more than thirty (30) minor underage girls, a fact confirmed by state and federal law enforcement. 33. After years of abuse, Epstein sent Roberts to Thailand in September 2002. One of Roberts’ assignments from Epstein was to bring a young girl back to Epstein in the United States. Fearing for her life, and not wanting to subject another young girl to the abuse she was forced to endure, Roberts fled from Thailand to Australia to escape from Epstein. B. Dershowitz’s Role with Epstein and Abuse of Plaintiff 34. Dershowitz has been “a close friend of Mr. Epstein” for many years. (Exhibit 7). In 2003, Dershowitz said “I’m on my 20 th book… The only person outside of my immediate family that I send drafts to is Jeffrey.” “The Talented Mr. Epstein.” Vanity Fair 2003. (Exhibit 8). Dershowitz also described Epstein as his friend “I would be interested in him [Epstein] as a friend if we had hamburgers on the boardwalk in Coney Island and talked about his ideas.” “Vanity Fair Reminds US When Jeffrey Epstein Wasn’t a Creep.” The Atlantic Wire. June 21, 2011. Dershowitz frequently traveled with Epstein, including on Epstein’s private plane. In 9 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 10 of 28 addition, Epstein’s employees have confirmed that Dershowitz visited Epstein’s Palm Beach and New York City mansions often, would stay overnight, and was present when the victims of Epstein’s sex trafficking were there. Dershowitz also visited Epstein’s other homes. 35. In addition to their close friendship, Dershowitz represented Epstein as his attorney. On or about December 2, 2018, Dershowitz stated that he is still Epstein’s attorney (Exhibit 9). 36. During the time period that Roberts was being trafficked by Epstein she was forced to have sex with Alan Dershowitz. Roberts was forced to engage in sexual acts with Dershowitz in, among other locations, Epstein’s mansion located at 9 East 71 st Street, New York, New York 10021. C. The Arrest and Prosecution of Epstein 37. Epstein ultimately pled guilty to procuring a minor for prostitution, and is now a registered sex offender. 38. In September 2007, Epstein entered into a Non-Prosecution Agreement (“NPA”) in which the U.S. Attorney for the Southern District of Florida agreed not to prosecute Epstein for numerous federal sex crimes committed in that District. 39. In the NPA, the United States Attorney for the Southern District of Florida additionally agreed that it would not institute any federal criminal charges against any potential co-conspirators of Epstein. 40. Epstein flippantly referred to his sexual abuse of multiple minors, and the slap on the wrist he had received for it, in a 2011 interview with the New York Post: “Billionaire pervert Jeffrey Epstein is back in New York City – and making wisecracks about his just-ended jail stint for having sex with an underage girl. ‘I am not a sexual predator, I’m an “offender,”’ the 10 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 11 of 28 financier told The Post yesterday. “‘It’s the difference between a murderer and a person who steals a bagel,’ said Epstein.” February 25, 2011, New York Post “Billionaire Jeffrey Epstein: I’m a Sex Offender Not A Predator”. D. The Criminal Victims’ Rights Act Proceeding 41. Rather than confer with the victims about the NPA, the U.S. Attorney’s Office and Epstein, who was represented by Dershowitz at that time, agreed to a “confidentiality” provision in the Agreement barring its disclosure to anyone—including Epstein’s victims. As a consequence, the victims were not told about the NPA. 42. On July 7, 2008, a young woman identified as Jane Doe No. 1, one of Jeffrey Epstein’s victims (other than Roberts), filed a petition to enforce her rights under the Crime Victims’ Rights Act (“CVRA”), 18 U.S.C. ¶ 3771, alleging that the Government failed to provide her the rights promised in the CVRA with regard to the plea arrangement with Epstein. 43. On February 21, 2019, the Court found that the victims’ rights had been violated and granted summary judgment in favor of the victims finding: “It was a material omission for the Government to suggest to the victims that they have patience relative to an investigation about which it had already bound itself not to prosecute.” Order at 31. In its Order the Court acknowledged that: “Jeffrey Epstein sexually abused more than 30 minor girls”. The Court also found: “Among other provisions, the NPA expanded immunity to any ‘potential coconspirator’ of Epstein’s: ‘In consideration of Epstein’s agreement to plead guilty and to provide compensation in the manner described above, if Epstein successfully fulfills all of the terms and conditions of this agreement, the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff or Nadia Marcinkova… From the time the FBI began 11 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 12 of 28 investigating Epstein until September 24, 2007 – when the NPA was concluded – the Office never conferred with the victims about a NPA or told the victims that such an agreement was under consideration.” Order at 2, 8. E. Victims Refuse Silence 44. Ultimately, as a mother and one of Epstein’s many victims, Roberts concluded that she should speak out about her sexual abuse experiences in hopes of helping others who had also suffered from sexual trafficking and abuse, and of possibly protecting future potential victims. 45. On December 23, 2014, Roberts incorporated an organization called Victims Refuse Silence, Inc., a Florida not-for-profit corporation. 46. Roberts intended Victims Refuse Silence to change and improve the fight against sexual abuse and human trafficking. The goal of her organization was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse, and to help others to escape becoming victims of sex trafficking. F. Defendant Acted Maliciously to Defame, Discredit, and Intimidate Roberts 47. Dershowitz made his false and defamatory statements as set forth above on behalf of himself and on behalf of his co-conspirator and client Epstein, in the Southern District of New York and elsewhere, in a deliberate effort to maliciously discredit Roberts and silence her efforts to expose the sexual abuse she suffered. Dershowitz and Epstein did so with the purpose and effect of having others repeat such false and defamatory statements and thereby further damaged Roberts’s reputation. Dershowitz and Epstein knew Dershowitz’s statements were false. 12 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 13 of 28 48. Dershowitz made his statements to discredit Roberts in concert with Epstein and others, including Ghislaine Maxwell, one of Epstein’s long-time procurers, as part of a conspiracy to discredit and try to silence Roberts. Epstein was particularly interested in discrediting and silencing Roberts because he feared a reopening of a federal criminal investigation of him. 49. Dershowitz made his statements pursuant to his conspiracy with Epstein and Maxwell maliciously as part of an effort to conceal sex trafficking crimes committed around the world by Epstein and other powerful persons. 50. Dershowitz and Epstein intended Dershowitz’s false and defamatory statements set out above to be broadcast around the world and to intimidate and silence Roberts from making further efforts to expose sex crimes committed by Epstein and other powerful persons, including Dershowitz. 51. Dershowitz and Epstein intended their false statements to be specific statements of fact. Dershowitz’s false statements were, as he and Epstein intended, broadcast around the world and were reasonably understood by those who heard them to be specific factual claims by Dershowitz that he had not had sex with Roberts, that Roberts was intentionally lying about having sex with Dershowitz, that Roberts committed the crime of perjury, that Roberts had committed the crime of extortion, and that Roberts had intentionally fabricated her assertions about Dershowitz to extort money from others. 52. Epstein also worked with other of his attorneys to attack Roberts’ allegations, including in a false statement they made in a letter to the editor to the New York Times asserting: “The number of young women involved in the investigation has been vastly exaggerated, there 13 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 14 of 28 was no ‘international sex-trafficking operation’ and there was never evidence that Mr. Epstein ‘hosted sex parties’ at his home”. (Exhibit 10). G. Dershowitz’s Lies 53. From the beginning, Dershowitz and Epstein have sought to hide their crimes behind a curtain of lies. In response to Roberts’ description of Dershowitz’s participation in Epstein’s sex trafficking, Dershowitz began a series of intentional, outright lies designed to distance himself from Epstein, to cover up his own wrongdoing, and to discredit Roberts and intimidate her into silence. 54. Dershowitz’s repeated lies are compelling evidence both of his lack of credibility and his guilt. Only a person seeking to conceal improper conduct would have engaged in the pattern of lies which has characterized Dershowitz’s statements since his sex trafficking was revealed. 55. In attempt to conceal his relationship with Epstein, Dershowitz in January 2015 asserted that “my relationship with him was entirely professional. It is a total bum rap to say that I…was ‘chummy’ with him”. (Exhibit 11). That was a lie, as Dershowitz and Epstein knew (see, e.g., paragraphs 34-35). 56. Both to conceal Dershowitz’s relationship with Epstein, and to discredit Roberts, Dershowitz has repeatedly asserted that he was only at Epstein’s residence once in Palm Beach, and that was with his family. However, Juan Alessi, a long time Epstein household employee, has confirmed that Dershowitz visited Epstein “pretty often. I would say at least four or five times a year” and that he would “typically” stay two or three days. Similarly, Alfredo Rodriguez who worked for Epstein approximately only six months confirmed that during that six months period Dershowitz visited Epstein twice. 14 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 15 of 28 57. Again, both to conceal his relationship with Epstein and to discredit Roberts, Dershowitz has repeatedly asserted that he was never in Epstein’s residence in the presence of young women. As both Dershowitz and Epstein know, that assertion was also false. As Mr. Rodriguez has confirmed, there were “also young ladies in the house at the time he [Dershowitz] was there”. Mr. Rodriguez also confirmed that “Mr. Dershowitz was there” when “women came to Mr. Epstein’s home to give a massage”. Mr. Rodriguez also confirmed that “Alan Dershowitz was at the house” with “the local Palm Beach girls” who he was “told to call masseuses”, although he did not himself know whether or not Dershowitz personally received a massage. 58. [REDACTED] was an employee of Epstein responsible for “manning the front door at his New York mansion and keeping records of people who came to the home” (Exhibit 12, ¶ 2). (a) Ms. Farmer “witnessed a number of school age girls coming to the house, some of the young girls would be wearing their school uniforms”…who “then would be escorted upstairs” (Exhibit 12, ¶ 3). (b) Ms. Farmer was told these young girls “were interviewing for modeling positions” even though “it did not seem credible to me that these young girls were interviewing for modeling positions”. (Exhibit 12, ¶ 3). 59. Ms. Farmer asserts that “Alan Dershowitz was an individual who came to visit Epstein at his New York mansion a number of times when I was working for Epstein. Dershowitz was very comfortable at the home and would come in and walk upstairs. On a number of occasions I witnessed Dershowitz at the NY mansion going upstairs at the same time there were young girls under the age of 18 who were present upstairs in the house” (Exhibit 12, ¶ 4). 15 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 16 of 28 60. Ms. Farmer, like other victims of, and witnesses to, Epstein and Dershowitz’s sex trafficking and abuse has been subjected to attacks and intimidations. (Exhibit 12, ¶¶ 8-9). Her courageous testimony, together with the sworn testimony of victims such as [REDACTED] and witnesses such as Mr. Alessi and Mr. Rodriguez , proves beyond any doubt that Dershowitz’s claims that he was never present where Ms. Roberts was trafficked, and never in the presence of young girls, are a lie intended to cover up his culpability. 61. Again both to conceal his relationship with Epstein and to discredit Roberts, Dershowitz has repeatedly asserted that he has records that prove that it would have been “impossible” for him to be with Roberts because he was never in the same place and time as Roberts. As both Dershowitz and Epstein know, that too was a lie. The testimony of Epstein’s household staff establishes that Dershowitz was repeatedly at Epstein’s residence. Even Dershowitz’s own selected, incomplete, and apparently revised, records demonstrate that Dershowitz was present at locations where Ms. Roberts was with Epstein. 62. Dershowitz’s assertion that Roberts accused him of having sex with her only after her lawyers convinced her to do so in late 2014 is not only false, as both Dershowitz and Epstein knew, but thoroughly disproved by the record. 63. Roberts had identified Dershowitz as a participant in her sexual abuse at the time it occurred. She did so again in 2009. In 2010 Epstein’s co-conspirators were repeatedly asked about Dershowitz. For example: (a) Adriana Ross refused to answer on Fifth Amendment grounds whether “Alan Dershowitz stays at Jeffrey Epstein’s house…when underage minor females have been in the bedroom with Jeffrey Epstein”. 16 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 17 of 28 (b) Nadia Marcinkova refused to answer on Fifth Amendment grounds: “Alan Dershowitz is also somebody that you also know to have been at the house when L.M. was being sexually abused in Jeffrey Epstein’s bedroom, correct?” 64. In 2011 Counsel for Edwards wrote Dershowitz: (a) On August 23, 2011: “We…have reason to believe that you have personally observed Jeffrey Epstein in the presence of underage females”. (b) On September 7, 2011: “Multiple individuals have placed you in the presence of Jeffrey Epstein on multiple occasions and in various locations when Jeffrey Epstein was in the company of underage females subsequently identified as victims of Mr. Epstein’s criminal molestations.” 65. Dershowitz lied and stated that he had never flown on Jeffrey Epstein’s plane with a young woman and always flew with his wife. (Hala Gorani, CNN Live, Jan. 5, 2015). However, even the limited publically available flight logs of Jeffrey Epstein’s private plane demonstrate that Dershowitz flew often on Epstein’s planes without his wife; with young women, including a Victoria’s Secret model; Epstein’s procurer Ghislaine Maxwell; and Sarah Kellen who was identified by the Government as Epstein’s co-conspirator in his sex trafficking. 66. Dershowitz also lied by saying that he “never” got a massage from anybody: “I never got a massage from anybody. It’s made up out of whole cloth.” (NY Daily News, January 21, 2015). However, after it was revealed that Epstein’s household staff identified Dershowitz as one of the recipients of “massages” at Epstein’s Palm Beach mansion, Dershowitz changed his story and admitted he got a massage at Epstein’s Palm Beach home but claimed: “I kept my underwear on during the massage.” (Local 10, January 22, 2015). 17 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 18 of 28 67. Dershowitz lied and said he never saw any naked pictures of females in Epstein’s Palm Beach home during his many visits, yet the police footage that was obtained from the search of Epstein’s home proves that there were naked pictures of females throughout the home including in the common areas. 68. In a desperate attempt to deflect attention from his own misconduct, Dershowitz fabricated an extortion plot by Roberts and her lawyers. Dershowitz falsely told the media that he was being used as a pawn as part of a fanciful plan to extort money from a billionaire business mogul and colleague of Epstein. Dershowitz’s claim was that he was framed in order to send a message to the billionaire that this is what would happen to the billionaire if the billionaire did not pay Roberts and her attorneys. As Dershowitz knew: (a) (b) (c) No complaint was ever made against the billionaire. No money was either paid or demanded by or from the billionaire. Roberts’ assertions about Dershowitz long predated the time of the alleged extortion plot. 69. Dershowitz also falsely claimed that Roberts’ lawyer had told him that he had concluded that Roberts was “wrong” and “simply wrong” in accusing Dershowitz. Dershowitz, in violation of the canons of ethics and in at least one case in violation of state law, had surreptitiously tape recorded confidential settlement negotiations he had engaged in with Ms. Roberts’ lawyer. Dershowitz then played and described excerpts from those tapes out of context to reporters to try to make it appear that Ms. Roberts’ lawyer’s hypothetical comments, and characterizations of Dershowitz’s assertions, represented that lawyer’s conclusions. As the sworn testimony (Exhibit 13) of Dershowitz’s own lawyer, and the facts set forth below, demonstrate, Dershowitz’s assertions about what Ms. Roberts’ lawyer said are, again, false. 18 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 19 of 28 70. In May 2015 Dershowitz requested confidential settlement negotiations with Ms. Roberts’ lawyers in which Dershowitz sought to convince Ms. Roberts lawyer that Ms. Roberts was mistaken, and that the person to whom Epstein had lent Ms. Roberts was Nathan Myhrvold, not Dershowitz. Dershowitz claimed that he had been at Epstein’s home only once (and that he was there with his family); that he had never been in the vicinity of Epstein’s island; that he had not been at Epstein’s New York mansion; and that he had been at Epstein’s New Mexico ranch only once for a few hours (again with his family). Dershowitz provided a summary of his whereabouts that purported to prove that his assertions were true. 71. Dershowitz was told that, based on what was shown in his summary, it would have been impossible for Ms. Roberts’ assertions about him to be true, and that if his assertions proved out, Ms. Roberts counsel would undertake to convince her that she must have made a mistake. (a) Dershowitz was also told, however, (i) that his assertions would have to be proven, (ii) that Ms. Roberts had always been very clear that she recalled having had sex with Dershowitz multiple times, and (iii) that everyone was convinced that Ms. Roberts was telling the truth as she recalled it. (b) Dershowitz responded that he did not doubt that Ms. Roberts was telling the truth as she recalled it and that she would have no difficulty passing a lie detector test. He said he simply believed Ms. Roberts had made an honest mistake in confusing him with Nathan Myhrvold. 72. Following Dershowitz’ presentations, Dershowitz’s representations were investigated and repeatedly proven false. 19 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 20 of 28 (a) Dershowitz’s alleged backup for his travel summary proved to be incomplete and in some instances apparently altered. (b) Dershowitz’s key claim that he had not stayed at Epstein’s house was proven false, including by the testimony of Epstein’s household employees Juan Alessi (see ¶ 56 above) and Alfredo Rodriguez (see ¶¶ 56-57 above) as well as the testimony of [REDACTED] (Exhibit 14) and [REDACTED] (Exhibit 12). (c) Dershowitz’s claim that Ms. Roberts confused him with Nathan Myhrvold was tested by showing Ms. Roberts pictures of both. She was, and is, clear that it was Dershowitz, not Myhrvold, with whom she had sex. (d) Dershowitz’s claim he had never been on Epstein’s plane without his wife was proven false by plane logs. (e) Dershowitz’s claim that he had never seen pictures of young females at Epstein’s house was proven false by Palm Beach police and FBI reports. (f) Dershowitz’s claim that he had never been in the presence of young females was proven false by the testimony of Epstein’s household employer (see ¶¶56-57) and of young women themselves (see Exhibit 14 [Ransome] and Exhibit 12 [Farmer].) 73. After Dershowitz’s claimed proof of exonerating evidence collapsed, and the evidence of his guilt grew, Roberts’ lawyer’s told Dershowitz in writing that they “had discovered evidence inconsistent with some of [your] representations”, that his travel “records were incomplete”, and that he “should have settled the case when he had a chance”. 74. Roberts’ lawyer explicitly told Dershowitz that neither Roberts nor her lawyer would make any statement saying or implying that Roberts was mistaken in her charge that 20 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 21 of 28 Dershowitz participated in her sexual trafficking and abuse. In his public statements, Dershowitz conspicuously omits any reference to the statements by Roberts’ lawyers after they had investigated his representations and concluded that they were false. 75. Faced with the mounting evidence of his guilt, Dershowitz abandoned his attempt to get Roberts or her lawyer to concede a mistake or that Roberts had been wrong, and desperately sought even a suggestion that an error was “possible”. 76. In December 2015 Ms. Roberts’ counsel again told Mr. Dershowitz that “Virginia is adamant about her current recollection” and that neither Ms. Roberts nor her counsel believed she was mistaken in identifying Mr. Dershowitz as one of the men to whom Epstein had lent her out for sex. In response, Mr. Dershowitz did not claim that Ms. Roberts lawyers had told him that they did not believe her. 77. Instead, the morning of December 9, 2015, Mr. Dershowitz pleaded: “David, Have we given up on a mutually acceptable statement from VR or you. Let’s keep trying. We are not that far apart.” (Exhibit 15). When Ms. Roberts lawyer did not immediately respond, Mr. Dershowitz wrote later the same day: “We should be aiming at a short simple statement such as: “The events at issue occurred approximately 15 years ago when I was a teenager. Although I believed then and continued to believe that AD was the person with whom I had sex, recent developments raise the possibility that this may be a case of mistaken identification.” (Exhibit 15). Mr. Dershowitz went on to write: “It would be acceptable if the statement came from you rather than her, if she prefers.” (Id.) 21 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 22 of 28 78. Wholly absent at this point was any assertion by Mr. Dershowitz that Ms. Roberts was lying, or that she made up her charge as part of an extortion claim, or that after investigating his alleged evidence Ms. Roberts’ lawyer did not believe her. On the contrary, Mr. Dershowitz expressly recognized that Ms. Roberts’ belief was an honest one. All Mr. Dershowitz was pleading for was an acknowledgement that there was a “possibility” that there “may be” a case of mistaken identification. Even that plea was rejected by Ms. Roberts and her lawyers as misleading. 79. Dershowitz’s present PR claim that Roberts’ lawyers disbelieved their client, and that Roberts intentionally committed perjury as part of an extortion scheme, is just another Dershowitz lie. His reliance on statements taken out of context, his failure to include the statements of Roberts’ lawyer after Dershowitz’s supposed evidence had been investigated, and the damning admissions of his own lawyers, reveal Dershowitz’s total lack of support for his allegation that Roberts and her lawyers concocted knowingly false allegation against him as part of a supposed extortion plot. 80. Dershowitz also lied to attempt to deflect [REDACTED]’s revelations about him. Ms. Ransome revealed that during the time she was a victim of Epstein’s sex trafficking, Epstein’s arranged for his lawyer, Dershowitz, to also represent Ms. Ransome. Ms. Ransome also described how, during the time Dershowitz was her lawyer, Epstein lent her out to Dershowitz for sex. (Exhibit 14). 81. Dershowitz asserted that he never had sex with Ms. Ransome, that he never represented Ms. Ransome, that he did not even know Ms. Ransome, and that Ms. Ransome’s statements about him were fabricated by Ms. Roberts’ lawyer in retaliation for a bar complaint that Dershowitz had filed against that lawyer (Exhibit 16). However, as Dershowitz knew: 22 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 23 of 28 (a) (b) (c) He did have sex with Ms. Ransome. He was Ms. Ransome’s lawyer. Ms. Ransome’s statements about her involvement with Dershowitz preceded any contact with Roberts’ attorneys. For example, Ransome’s first contact with any of Roberts’ lawyers was in November 2016, and at least as early as October 2016 Ransome had identified Dershowitz in writing to a reporter as someone who had had sex with one or more of the girls provided by Epstein and that Epstein had arranged for Dershowitz to be Ransome’s lawyer. 82. After settling the case against him brought by Messrs. Edwards and Cassell, Dershowitz told the media he had been vindicated, while at the same time insisting that the term of the settlement remains confidential. Edwards and Cassell responded: “Following the announcement of the settlement of defamation claims against Alan Dershowitz, he has been making public statements suggesting that he has prevailed in the lawsuit and that the terms of the settlement exonerate him of any wrongdoing. Those statements are at best misleading. It is a mistake for anyone to conclude based upon Mr. Dershowitz’s statements that the case against him was abandoned due to lack of factual support. It is a mistake for anyone to conclude based upon Dershowitz’s statements that Bradley Edwards and Paul Cassell had determined that the allegations against Alan Dershowitz made by [REDACTED] were false or unfounded. Neither the terms of settlement nor the agreed upon joint public statement issued as part of the settlement support any such conclusion and it is false to state or suggest otherwise.” Dershowitz Settles Sex Case, But is He Vindicated? The American Lawyer, April 10, 2016. 83. Dershowitz continues to this day to insist that the terms of his settlement with Edwards and Cassell remain confidential -- a position that can only be explained by 23 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 24 of 28 Dershowitz’s knowledge that revealing how much he had paid to avoid a trial of the allegations against him would reveal his guilt. 84. As described above, Dershowitz has also repeatedly asserted that he wanted to have a trial to establish his innocence. By contrast, he paid to settle the case that would have provided that trial. He even lied about his being willing to waive the statute of limitations so that Roberts could sue him for sex abuse -- a lie almost immediately exposed when he was promptly asked to do so and, equally promptly refused. COUNT I DEFAMATION 85. Plaintiff Roberts re-alleges paragraphs 1 – 84 as if the same were fully set forth herein. Dershowitz made his false and defamatory statements deliberately and maliciously with the intent to intimidate, discredit and defame Roberts. 86. In December 2018, and thereafter, Dershowitz, on behalf of himself and Epstein, intentionally and maliciously released to the press his false statements about Roberts in an attempt to destroy Roberts’ reputation and brand her as a liar and cause her to lose all credibility in her efforts to help victims of sex trafficking. 87. Dershowitz and Epstein knew that Dershowitz’s assertions would dilute, discredit, and neutralize Roberts’s public and private messages to sexual abuse victims and ultimately prevent Roberts from effectively providing assistance and advocacy on behalf of other victims of sex trafficking, or expose her abusers. 88. Using his role as a powerful lawyer with powerful friends, Dershowitz’s statements were published internationally for the malicious purpose of further damaging a sexual abuse and sexual trafficking victim; to destroy Roberts’s reputation and credibility; to cause the 24 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 25 of 28 world to disbelieve Roberts; and to destroy Roberts’s efforts to use her experience to help others suffering as sex trafficking victims. 89. Dershowitz, personally, intentionally, and maliciously made false and damaging statements of fact concerning Roberts, as detailed above, in the Southern District of New York and elsewhere. 90. The false statements that Dershowitz made, personally on behalf of himself and Epstein not only called Roberts’s truthfulness and integrity into question, but also exposed Roberts to public hatred, contempt, ridicule, and disgrace. 91. At the time Dershowitz made his false statements, he and Epstein, knew full well that they were completely false. 92. Dershowitz’s false statements constitute libel, as he and Epstein knew that they were going to be transmitted in writing, widely disseminated on the internet and in print. Dershowitz intended his false statements to be published by newspaper and other media outlets internationally, and they were, in fact, published globally, including within the Southern District of New York. 93. Dershowitz’s false statements constitute libel per se, including that they accused her of a crime, and including that they exposed Roberts to public contempt, ridicule, aversion, and disgrace, and induced an evil opinion of her in the minds of right-thinking persons. 94. Dershowitz’s false statements also constitute libel per se, inasmuch, among other reasons, as they tended to injure Roberts in her professional capacity as the president of a nonprofit corporation designed to help victims of sex trafficking, and inasmuch as they destroyed her credibility and reputation among members of the community that seeks her help and that she seeks to serve. 25 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 26 of 28 95. Dershowitz’s false statements directly stated and also implied that in speaking out against sex trafficking Roberts acted with fraud, dishonesty, and unfitness for the task. Dershowitz’s false statements directly and indirectly assert that Roberts lied about being sexually trafficked and abused by Epstein and having sex with Dershowitz, and that Roberts committed the crimes of perjury and extortion. Dershowitz’s false statements were reasonably understood by many persons who read his statements as conveying that specific intention and meaning. 96. Dershowitz’s false statements were reasonably understood by many persons who read those statements as making specific factual claims that Roberts was lying about specific facts, and committed the crimes of perjury and extortion. 97. Dershowitz specifically directed his false statements at Roberts’ true public description of factual events, and many persons who read Dershowitz’s statements reasonably understood that those statements referred directly to Roberts’ account of the abuse she suffered at the hands of Epstein and Dershowitz. 98. Dershowitz and Epstein intended Dershowitz’s false statements to be widely published and disseminated on television, through newspapers, by word of mouth, and on the internet. As intended by Dershowitz and Epstein, Dershowitz’s statements were published and disseminated around the world. 99. Dershowitz made his false statements on behalf of himself and Epstein in reckless disregard of their truth or falsity and with malicious intent to destroy Roberts’s reputation and credibility; to prevent her from further disseminating her life story; and to cause persons hearing or reading Roberts’s descriptions of truthful facts to disbelieve her entirely. Dershowitz made his false statements on behalf of himself and Epstein wantonly and with the specific intent to maliciously damage Roberts’s good name and reputation in a way that would destroy her efforts 26 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 27 of 28 to administer her non-profit foundation, or share her life story, and thereby help others who have suffered from sexual abuse. 100. As a result of Dershowitz’s and Epstein’s campaign to spread false, discrediting, and defamatory statements about Roberts, Roberts suffered substantial damages in an amount to be proven at trial. 101. Dershowitz’s false statements have caused, and continue to cause, Roberts economic damage, psychological pain and suffering, mental anguish and emotional distress, and other direct and consequential damages and losses. 102. Dershowitz’s and Epstein’s campaign to spread his false statements nationally and internationally was unusual and particularly egregious conduct. Dershowitz and Epstein sexually abused and trafficked Roberts, conspired to avoid having these crimes properly prosecuted and discovered, and wantonly and maliciously set out to falsely accuse, defame, and discredit Roberts to deny and conceal the scope and scale of their crimes. In so doing, Dershowitz’s efforts constituted a public wrong by deterring, damaging, and setting back Roberts’ efforts to help victims of sex trafficking. Accordingly, this is a case in which exemplary and punitive damages are appropriate. 103. Punitive and exemplary damages are necessary in this case to deter Dershowitz, Epstein and others from wantonly and maliciously using a campaign of lies to discredit Roberts and other victims of sex trafficking. PRAYER FOR RELIEF WHEREFORE, Plaintiff Roberts respectfully requests judgment against Defendant Dershowitz, awarding compensatory, consequential, exemplary, and punitive damages in an 27 Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 28 of 28 amount to be determined at trial, but in excess of the $75,000 jurisdictional requirement; costs of suit; attorneys’ fees; and such other and further relief as the Court may deem just and proper. JURY DEMAND Plaintiff hereby demands a trial by jury on all causes of action asserted within this pleading. Dated: April 16, 2019. /s/ Joshua Schiller Boies Schiller Flexner LLP 55 Hudson Yards New York, NY 10001 (212) 446-2300 /s/ Sigrid McCawley Sigrid McCawley Boies Schiller Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 (Pro Hac To Be Filed) 28 Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 1 of 18 EXHIBIT 1 https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 2 of 18 Page 1 of 17 Even from jail, sex abuser manipulated the system. His victims were kept in the dark BY Julie K. Brown NOV. 28, 2018 A decade before #MeToo, a multimillionaire sex offender from Florida got the ultimate break. �� Palm Beach County Courthouse June 30, 2008 Jeffrey Edward Epstein appeared at his sentencing dressed comfortably in a blue blazer, blue shirt, jeans and gray sneakers. His attorney, Jack Goldberger, was at his side. At the end of the 68-minute hearing, the 55-year-old silver-haired financier — accused of sexually abusing dozens of underage girls — was fingerprinted and handcuffed, just like any other criminal sentenced in Florida. But inmate No. W35755 would not be treated like other convicted sex offenders in the state of Florida, which has some of the strictest sex offender laws in the nation. Ten years before the #MeToo movement raised awareness about the kid-glove handling of powerful men accused of sexual abuse, Epstein’s lenient sentence and his extraordinary treatment while in custody are still the source of consternation for the victims he was accused of molesting when they were minors. Beginning as far back as 2001, Epstein lured a steady stream of underage girls to his Palm Beach mansion to engage in nude massages, masturbation, oral sex and intercourse, court and police records show. The girls — mostly from disadvantaged, troubled families — were recruited from middle and high schools around Palm Beach County. Epstein would pay the girls for massages and offer them further money to bring him new girls every time he was at his home in Palm Beach, according to police reports. The girls, now in their late 20s and early 30s, allege in a series of federal civil lawsuits filed over the past decade that Epstein sexually abused hundreds of girls, not only in Palm Beach, but at his homes in Manhattan, New Mexico and in the Caribbean. In 2007, the FBI had prepared a 53-page federal indictment charging Epstein with sex crimes that could have put him in federal prison for life. But then- Miami U.S. Attorney Alexander Acosta signed off on a non-prosecution agreement, which was negotiated, signed and sealed so that no one would know the full scope of Epstein’s crimes. The indictment was shelved, never to be seen again. Epstein instead pleaded guilty to lesser charges in state court, and was required to register as a sex offender. He was sentenced to 18 months incarceration. But Epstein — who had a long list of powerful, politically connected friends — didn’t go to state prison like most sex offenders in Florida. Instead, the multimillionaire was assigned to a private wing of the Palm Beach County stockade, where he was able to hire his own security detail. Even then, he didn’t spend much time in a cell. He was allowed to go to his downtown West Palm Beach office for work release, up to 12 hours a day, six days a week, records show. Read Next https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 3 of 18 Page 2 of 17 LOCAL Sex abuser Jeffrey Epstein was surrounded by powerful people. Here’s a sampling He was permitted to hire his own private psychologist for his required sex-offender counseling, and after his release from jail, his subsequent year of probation under house arrest was filled with trips on his corporate jet to Manhattan and to his home in the U.S. Virgin Islands — all approved by the courts with no objections from the state. On the morning of his sentencing in 2008, none of Epstein’s victims were in the courtroom to protest his soft jail term or the unusual provisions of his incarceration and probation — and that was by design. Palm Beach multimillionaire Jeffrey Epstein is a free man, despite sexually abusing dozens of underage girls according to police and prosecutors. His victims have never had a voice, until now. By Emails and letters contained in court filings reveal the cozy, behind-the-scenes dealings between federal prosecutors and Epstein’s indomitable legal team during the run-up to his federal plea deal, as they discussed ways to minimize his criminal charges and avoid informing the girls about the details of the deal until after the case was resolved. That arrangement benefited Epstein in a number of ways. Unlike other high-profile sex crime cases, federal prosecutors agreed to keep his sentencing quiet, thereby limiting media coverage. His underage victims — identified in FBI documents — weren’t told about the plea deal so they weren’t in court, where they could voice their objections and possibly sway the judge to give Epstein a harsher sentence or reject the agreement altogether. Most important, Epstein’s crimes would be reduced to felony prostitution charges, giving him the ability to argue that the girls weren’t victims at all — they were prostitutes. Four accomplices named in Epstein’s non-prosecution agreement — Nadia Marcinkova, Sarah Kellen, Adriana Ross and Lesley Groff — were also given immunity from federal prosecution. Marcinkova was a young girl when Epstein brought her from Yugoslavia to live with him. Several victims told police that she was involved in orgies with Epstein and underage girls. Ross, Groff and Kellen, now known by her married name, Vickers, were schedulers who arranged his underage sex sessions, according to the FBI and police. Marcinkova and Kellen, through their attorneys, declined to comment for this story. The Herald was unsuccessful in reaching Ross and Groff. https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 4 of 18 Page 3 of 17 Acosta, who is now President Donald Trump’s secretary of labor, told lawmakers last year at his confirmation hearing that he did not know that Epstein would receive such liberal treatment while incarcerated. But court records show that federal prosecutors under his authority acquiesced to many of Epstein’s demands, including that he not go to federal or state prison. “I can’t remember how I found out that he had taken a plea,’’ said [REDACTED], identified by the FBI as one of more than three dozen underage girls — some of them as young as 13 — who had been molested by Epstein at his waterfront estate between 2001 and 2005. “We were purposefully misled into believing that his sentencing [in state court] had nothing to do with the federal crimes he committed against me or the other girls.’’ Epstein, now 65, was released in 2009 after serving 13 months. Wild, who was 14 when she met Epstein, is suing the federal government, alleging that prosecutors kept her and other victims in the dark as part of a conspiracy to give Epstein — described in the lawsuit as “a powerful, politically connected multimillionaire” — one of the most lenient deals for a serial child sex offender in history. [REDACTED] is suing the federal government, claiming that prosecutors deliberately kept her and other victims of Jeffrey Epstein in the dark about the status of his case. The U.S. Attorney’s Office signed a non-prosecution agreement with the multimillionaire. Emily Michot EMICHOT@MIAMIHERALD.COM Now 31, Wild is Jane Doe No. 1 in “Jane Doe 1 and Jane Doe 2 vs. the United States,” which seeks to overturn Epstein’s plea agreement on the grounds that it was executed in violation of the federal Crime Victims’ Rights Act. The measure affords crime victims a series of rights, including to confer with prosecutors and to be notified about plea negotiations and sentencing. That lawsuit — and an unrelated state court case scheduled for trial on Dec. 4 — could expose more about Epstein’s crimes, as well as who else was involved and whether there was any undue influence that tainted the federal case. https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 5 of 18 Page 4 of 17 Support investigative journalism The Miami Herald obtained thousands of FBI and court records, lawsuits, and witness depositions, and went to federal court in New York to access sealed documents in the reporting of "Perversion of Justice." The Herald also tracked down more than 60 women who said they were victims, some of whom had never spoken of the abuse before. Your digital subscription, starting at $0.99 for the first month, supports investigative journalism like this. CLICK TO SUBSCRIBE Some of Epstein’s victims will finally have an opportunity to testify for the first time as part of the Dec. 4 case in state court in Palm Beach County. It pits Fort Lauderdale attorney Bradley Edwards against Epstein, who had accused Edwards of malfeasance in his representation of several victims. Jack Scarola, the attorney representing Edwards, said Epstein should be held accountable for his unrelenting attacks against Edwards — as well as others who were involved in his case. “We are going to demonstrate through this case that no one — no matter how much money they have — can abuse children and then attempt to bully those who come to the defense of children,’’ said Scarola, a former state prosecutor. Florida and beyond Few people had as much insight into Epstein’s lifestyle — and its international reach — as [REDACTED]. By age 16, Roberts had lived a life that was beyond that of most high school girls. At 11, she says, she was sexually molested by a family friend. At 12, she was smoking pot and skipping school. At 13, she was in and out of foster homes, and at 14, she was on the street. In Miami, the runaway became a captive of a 65-year-old sex trafficker, Ron Eppinger. For months, she says, she was sexually abused, kept in an apartment and pimped out to pedophiles. After his indictment in 2000 on trafficking charges, Roberts returned to West Palm Beach and tried to heal. https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 6 of 18 Page 5 of 17 [REDACTED], now Giuffre, says she was 16 and working as a locker room attendant at Donald Trump’s Mar-a-Lago resort when she was approached by Ghislaine Maxwell, Jeffrey Epstein’s associate, about becoming a masseuse for Epstein. COURTESY OF [REDACTED] That summer, when Roberts was 16, she said her father helped her get a job as a locker room attendant at the spa at Donald Trump’s Mar-a-Lago resort in Palm Beach, records show. Her father worked at the resort as a maintenance man. There she said she met Ghislaine Maxwell, an Epstein friend and socialite daughter of the late British publishing magnate Robert Maxwell. She offered Roberts an opportunity to become a massage therapist, working for Epstein. In a sworn court affidavit and in a recent interview with the Herald, Roberts described how Epstein and Maxwell began grooming her — not just to perform massages, but to sexually pleasure them and others. “It started with one and it trickled into two and so on,’’ Roberts told the Herald. “And before you know it, I’m being lent out to politicians and academics and royalty.’’ Roberts, too, was ordered to find Epstein girls — the younger, the better — by trolling areas where teenagers congregated, such as shopping malls, to lure girls to whatever residence Epstein was staying in at the time, she told the Herald. She began to travel with Epstein and Maxwell to Epstein’s other homes, in New York, New Mexico and the U.S. Virgin Islands — and her trips are documented in flight logs that frequently list her name or her initials as a passenger, court records show. “His appetite was insatiable. He wanted new girls, fresh, young faces every single day — that was just the sickness that he had,’’ Roberts said. Neither Epstein nor his lead attorney, Goldberger, responded to requests for comment. Roberts alleges that Epstein had cameras throughout his homes and said he liked her to tell him about the sexual peccadilloes of various important men she had sex with. “Epstein and Maxwell also got girls for Epstein’s friends and acquaintances. Epstein specifically told me that the reason for him doing this was so that they would ‘owe him,’ they would ‘be in his pocket,’ and he would ‘have something on them,’ ” Roberts said in a court affidavit. “I understood him to https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 7 of 18 Page 6 of 17 mean that when someone was in his pocket, they owed him favors.’’ Roberts elaborated in her interview with the Herald, saying that Epstein had access to girls through a modeling agency that recruited them from overseas. Epstein, who was close to Les Wexner, the owner of Victoria’s Secret, often talked about his connections to people in the modeling, fashion and acting industries, Roberts told the Herald. “He [Epstein] would tell the girls, ‘Hey, I will give you a modeling contract if you go have sex with this man [whichever acquaintance Epstein designated],’ ’’ she said. Roberts’ story about the modeling agency is supported, to a degree, by the sworn statement of a Miami woman named Maritza Vasquez, who was later interviewed in New York by an FBI agent from Miami. Vasquez worked as a bookkeeper for Mc2, owned by Epstein associate Jean-Luc Brunel. He employed scouts in South America, Europe and the former Soviet Union to find him models to bring to the United States, Vasquez said in a 2010 sworn court deposition obtained by the Herald. Vasquez stated in the deposition that from 2003 to 2006 she handled all the finances and payroll for the agency, including a bank transaction involving Epstein. She said Epstein invested $1 million in Mc2. The models were often very young — 13, 14 and 15 — and some of them were housed in apartments at 301 E. 66th St. in New York, a building purportedly owned by Epstein, the deposition said. Epstein didn’t charge the girls rent, Vasquez said, but Brunel charged them $1,000 a month, with four of them at a time sharing one apartment. The girls who were the youngest and most beautiful stayed at the 66th Street apartments, which were more luxurious than the other apartments that were used to house models who were not as young and desirable, she said. Vasquez once let one of the models, who was 14, stay overnight with her after the girl ran into trouble with police for trying to get into a Manhattan nightclub. Vasquez also testified that she helped a lawyer obtain visas for the foreign models, and assisted with their transportation to and from modeling assignments and parties. Vasquez said that even though the agency employed 200 to 300 models, the company didn’t make any money and Brunel was always broke. Brunel would later sue Epstein, alleging that the financier’s sex scandal had caused his business to fail, but the suit was eventually dropped. Vasquez testified it wasn’t unusual for the agency to send girls to an assignment with a wealthy client for $100,000 or more, but the girl wouldn’t be paid the full amount — or anything at all — if she refused to be “molested.’’ Vasquez considered herself a mother figure and often coached the youngest girls to stick to the 9-to-5 modeling assignments because she didn’t think it was appropriate for them to be having sex. She said she met Epstein only once, but she often helped arrange for girls — many of them underage — to be sent to his homes in New York, Palm Beach and his island in the Caribbean for parties. She heard salacious rumors about Epstein’s parties, but testified she had no firsthand knowledge about whether they involved sex. Vasquez said that she was questioned by the FBI and she tried to tell agents where to look for evidence. Vasquez was eventually let go from the agency after she was accused of stealing money — money she claims was given to her by Brunel. Vasquez said she was placed on probation for the theft. She never heard from the FBI about Epstein again. The Herald was unsuccessful in reaching Brunel through his former attorney. In a written statement released in 2015, Brunel denied any involvement in trafficking underage models. “I strongly deny having participated, neither directly nor indirectly, in the actions Mr. Jeffrey Epstein is being accused of,” he said. “I strongly deny having committed any illicit act or any wrongdoing in the course of my work as a scouter or model agencies manager.” Too old at 19 In 2003, when Roberts turned 19, it was clear that Epstein had lost interest because she was too old for him, she said. She convinced him to pay for her to get training to become a real professional masseuse so that she could move on. In an interview, she explained that Epstein arranged for her to take a class in Thailand, but it came with a hitch: She said she was instructed to pick up a Thai girl he had arranged to come to the States. https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 8 of 18 Page 7 of 17 Roberts, who showed the Herald the written instructions for the rendezvous, never picked up the girl because Roberts met a man on the trip who would become her husband. The couple married and moved to Australia, where they currently live. In 2007 — at the same time the FBI was investigating Epstein — Roberts, pregnant with her second child, said she unexpectedly received phone calls from Maxwell and Epstein. She said they were worried that she had told police about them. She assured them she had not spoken to anyone, she said. Shortly afterward, Roberts said, she was contacted by someone who claimed to be with the FBI. But she was afraid to tell that person details, fearing it was really an Epstein associate posing as an FBI agent. That agent, identified in court papers as Timothy Slater, confirmed that he and the other agent on the case, Nesbitt Kuyrkendall, called Roberts in January or February 2007. In a sworn statement, Slater said he informed Roberts that they suspected she was a victim of Epstein’s. The agent said Roberts answered basic questions, but became uncomfortable and “asked that I not bother her again.’’ Roberts said the agent didn’t try too hard to convince her to talk, and she was surprised when he hung up after asking her a few graphic questions about her sex life. She said she was suspicious, but would have cooperated had the FBI talked to her in person and explained why they were asking about Epstein. “I was still scared to death,’’ Roberts said. “Jeffrey used to tell me that he owned the entire Palm Beach Police Department. I just didn’t want my family harmed.’’ She nevertheless was listed by federal prosecutors as one of Epstein’s Palm Beach victims. As the years went by and Roberts had a daughter, she would be haunted by a fear that Epstein was still taking advantage of young girls. In 2011, she went public in a paid interview with a British tabloid, the Daily Mail, asserting that she had had sex with Prince Andrew, one of Epstein’s friends, several times when she was a teen. In her 2015 affidavit, she discussed in detail some of her alleged sex encounters with the prince and Epstein’s other friends, including lawyer Alan Dershowitz. Edwards included the affidavit in the court file as part of the Jane Does’ Crime Victims’ Rights Act case, at which time it became public. [REDACTED] says she was loaned out by Jeffrey Epstein to his friend Prince Andrew, shown here. He denies they had sex. COURTESY OF [REDACTED] https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 9 of 18 Page 8 of 17 In the affidavit, Roberts claimed that Epstein and Maxwell directed her to have sex with Andrew and Dershowitz and others. She had sex with Andrew three times, she alleged — once in London, when she was 17, again in New York, when she was 17, and a third time, as part of an orgy on Epstein’s island, when she was 18. By law, at 17, she would have been above the age of consent in New York and England, but not in Florida, where the age of consent is 18. As part of the affidavit, Roberts furnished a photograph of her with the prince and Maxwell, which she said was taken in London. Dershowitz, who was part of Epstein’s criminal defense team, was often a guest at Epstein’s homes, she said. “I had sexual intercourse with Dershowitz at least six times,’’ Roberts wrote in the 2015 court affidavit. “The first time was when I was about 16, early on in my servitude to Epstein and it continued until I was 19.’’ She detailed some of those alleged trysts, which she said happened at Epstein’s homes in Palm Beach, New Mexico and on Epstein’s island. One of Epstein’s housemen, Juan Alessi, testified in a 2009 sworn deposition that Dershowitz visited Epstein’s Palm Beach home four or five times a year. He said that Roberts was a frequent visitor as well, but he never placed Dershowitz and Roberts at the house at the same time. Alessi, who testified he worked for Epstein from 1999 to 2002, said there were often young girls who gave massages at the house, even in the middle of the night. But he said he never checked their ages, and only knew one girl for certain who was underage, because he had picked her up from high school. That girl, who is now an actress, was not one of Epstein’s masseuses, Alessi said. He also said he was Maxwell’s driver, and he recalls waiting outside of Mar-a-Lago the day Maxwell met Roberts. He testified he saw Maxwell talking to Roberts and recalls Roberts coming to Epstein’s mansion later that day. One of Alessi’s jobs was to drive Maxwell to various spas in Palm Beach where she left business cards in order to “recruit’’ more masseuses, he said in the sworn deposition. Dershowitz, Prince Andrew and Maxwell have long denied Roberts’ allegations. In an interview with the Herald, Dershowitz reiterated that he had never met Roberts, and never saw Epstein with any underage girls. “The story was 100 percent flatly categorically made-up,’’ he said, adding that Roberts and her attorneys fabricated the assertion in order to get money from other powerful, wealthy people she alleges she had sex with. “The only possible reason to accuse me in public and [them] in private is so she could get money,’’ Dershowitz said. Edwards and his co-counsel in the Crime Victims’ lawsuit, University of Utah law professor Paul Cassell, sued Dershowitz for defamation and Dershowitz countersued in 2015. The case was settled out of court, with Dershowitz saying he had been vindicated. Dershowitz said he received a massage at Epstein’s Palm Beach home only once — but that it was just a regular, therapeutic massage by a masseuse — not by Roberts or anyone underage. Dershowitz’s wife was there at Epstein’s house at the time, Dershowitz said in the deposition taken for the case in 2015. “I never had any knowledge of Jeffrey Epstein having any contact with any underage women — ever,’’ Dershowitz told the Herald. Edwards and Cassell admitted making a “tactical mistake” in filing the accusations against Dershowitz as part of a lawsuit not involving him. But they emphasized that the settlement had no bearing on the veracity of Roberts’ allegations. The judge for the Crime Victims’ Rights Act lawsuit agreed that the affidavit was misplaced in that case, and it was dropped. Prince Andrew’s spokesman at Buckingham Palace did not respond to an email requesting comment. Roberts, now 35, said it has taken her a long time to stand up to Epstein. She and 20 other victims received settlements from Epstein, ranging from $50,000 to more than $1 million. The exact amounts have been kept confidential. “It takes so long until you are able to speak about it. It took me having a daughter and looking at this young, beautiful innocent baby to say I want to speak out about it now. I’m hoping that this will bring out more girls so that they say, Me Too.’’ The state court hearing The judge at Epstein’s sentencing hearing at the Palm Beach County Courthouse knew very little about Epstein’s crimes. The sentencing paperwork was restricted to Epstein’s specific charges: one count of solicitation of prostitution and one count of procuring a person under the age of 18 for prostitution. https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 10 of 18 Page 9 of 17 “Are there more than one victim?’’ Circuit Court Judge Deborah Dale Pucillo asked the prosecutor at Epstein’s sentencing on June 30, 2008. “There’s several,’’ replied assistant state prosecutor Lanna Belohlavek. “Are all the victims in both of these cases in agreement with the terms of this plea?’‘ Pucillo later asked. “Yes,’‘ Belohlavek replied, telling the judge that she had spoken to “several” of Epstein’s victims. Emails show that federal prosecutors didn’t want the judge to know how many victims and accomplices there were. Federal prosecutor A. Marie Villafaña — in a September 2007 email to Epstein lawyer Jay Lefkowitz — said: “I will mention co-conspirators but I would prefer not to highlight for the judge all the other crimes and all the other persons that we could charge.’’ Attorney Spencer Kuvin happened to be in court that day because he’d heard Epstein was to appear, but Kuvin didn’t know why. He figured he’d use it as an opportunity to serve Epstein with civil court papers involving one of several victims he represented. Instead, he listened to what was happening and couldn’t believe that no one had contacted him or his clients. “I was shocked to learn that the proceeding involved my client’s case and there was nothing I could do except watch as they disposed of her case without ever telling her,’’ Kuvin said. At the hearing, Belohlavek and Epstein’s attorney, Goldberger, were in sync, the court transcript shows. Epstein would be required to register as a sex offender, but his probation would not be served under the strict requirements of sex offender probation. Jeffrey Epstein is a registered sex offender in New York State and Florida. Emily Michot EMICHOT@MIAMIHERALD.COM The judge didn’t question those provisions, but she did ask why Epstein was going to serve his sentence in the Palm Beach County stockade instead of in a Florida state prison, like most sex offenders. https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Page 10 of 17 Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 11 of 18 After he pleaded guilty in state court, Jeffrey Epstein was assigned to a private section of the Palm Beach County stockade. Soon, however, he was allowed to leave the compound six days a week, 12 hours a day, for what was termed work release. Emily Michot EMICHOT@MIAMIHERALD.COM “We just decided that was the best way to accomplish what needed to be done here and the parties agreed that that sentence satisfied everyone’s requirements,’’ Goldberger replied. Said Judge Pucillo: “The taxpayers of Palm Beach County are going to pay 18 months to house this guy instead of DOC [the Department of Corrections]?” Belohlavek: “Right.’’ Pucillo did not respond to a request for comment on the case. Villafaña, the lead federal prosecutor in Epstein’s case, was in the courtroom, but there’s no indication she objected to Epstein’s cozier jail accommodations. When he entered jail in July 2008, Epstein was arguably the most well-known inmate there. Records also show that Epstein hired Palm Beach sheriff’s deputies for his security details, paying them for the hours they spent monitoring him on work release at his West Palm Beach office, where he often stayed until 10 p.m., jail logs show. The Herald reviewed their time sheets, showing that the deputies logged visitors coming and going to and from his office throughout the day. A record log of his visitors was kept in a safe, but the log no longer exists, according to a spokeswoman for the Palm Beach County Sheriff’s Office. One deputy who often worked Epstein’s detail said that his assignment was to stay in a front reception room of Epstein’s office. Epstein was in a separate office — with the door closed — most of the day as he accepted visitors, both male and female, the deputies’ logs show. “It was not our job to monitor what he was doing in that office,’’ the deputy, now retired, told the Herald. In their early reports in July 2008, the deputies referred to Epstein as “inmate’’ but within a few weeks the language had changed and he was called a “client.” He was occasionally allowed to take a break for lunch by sitting outside in a park, the records show, and they also gave him permission to scout for a new office. While on work release, he was required to wear an ankle bracelet to monitor his whereabouts. https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Page 11 of 17 Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 12 of 18 The work release was approved by the Palm Beach County Sheriff’s Office, said spokeswoman Therese Barbera. “Jeffrey Epstein, while in custody, met the criteria for the Work Release Program,’’ Barbera wrote in an email. “There was no factual basis to deny Mr. Epstein the same availability of this program that is offered to other inmates under similar circumstances. Mr. Epstein was closely monitored and there were no problems encountered during his time in the program.” But the sheriff’s own work release policy — a copy of which Barbera provided to the Herald — specifically notes that sex offenders aren’t eligible for work While officially confined to the Palm Beach County stockade, serving time for his sex release. offenses, Jeffrey Epstein was allowed to spend half his day at this West Palm Beach office building. It was called work release, although Palm Beach Sheriff’s Office rules At first, Barbera questioned whether Epstein was a sex offender at all, noting prohibit work-release status for sexual offenders. Emily Michot that he didn’t have to register officially until after his release from the jail in EMICHOT@MIAMIHERALD.COM 2009. But his court papers clearly listed him as a sex offender. In fact, the papers Epstein signed — obtained by the Herald — included all the laws governing registered sex offenders in Florida. Barbera refused to explain why Epstein was seemingly allowed to deviate from the agency’s policies. She also would not respond to requests for an accounting of the amount of money that Epstein paid the sheriff’s office for his private details. Palm Beach Sheriff Ric Bradshaw, who has been in office since 2004 — and is widely considered to be one of the most powerful people in the county — did not respond to requests for comment. A spokeswoman for Palm Beach County Sheriff Ric Bradshaw declined to say why Jeffrey Epstein was allowed work-release status despite rules prohibiting work release for sex offenders. Taylor Jones PALM BEACH POST Epstein’s registration requirements are somewhat confusing, even to those who are responsible for keeping his registration. The Florida Department of Law Enforcement, which keeps the online registry, and the Palm Beach County Sheriff’s Office, where Epstein has to register in person twice a year, gave https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Page 12 of 17 Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 13 of 18 conflicting explanations over the past six months about who is responsible for ensuring that he is complying with the law. On Nov. 14, the Herald asked the sheriff’s office for a full accounting of Epstein’s check-ins for 2018. The record the office supplied two days later showed he registered in January and in July — as required. But PBSO also inexplicably had him registering on Nov. 14 — the very same day that the Herald asked for the records from the sheriff’s office. When asked about this sudden registration, Barbera replied: “The information we provided you was a snapshot from the FDLE website. Perhaps, someone from FDLE can provide a reason for you.’’ Said FDLE spokeswoman Gretl Plessinger in an email: “The screenshot is not on the public registry. This is information inputted by the local agency when the offender comes into the local sheriff’s office to register.’’ Plessinger said Epstein is not covered by the state’s new three-day rule, which requires sex offenders to re-register when they come to stay in Florida for three days or more. His town of Palm Beach home is already on file, as a temporary residence, she said. So it’s not clear why he would have suddenly registered a third time on Nov. 14. State Sen. Lauren Book, a child sex abuse survivor and vocal advocate for tough sex offender monitoring, called the case an appalling example of how those in the justice system allow wealthy people to skirt the law and bend the rules. “These prosecutors, and judges and sheriffs who are making these decisions and allowing things to fly — we have to hold these people accountable. They are supposed to uphold the law — regardless of who a person is and how much money they have in the bank or who they had on their airplane.’’ Piece by piece Over the years, [REDACTED], [REDACTED] and more than a dozen other women who say they were victims of Epstein have been quietly challenging the traditional legal norms that have failed to punish Epstein and other men in positions of power for sexual abuse. Epstein has paid millions of dollars in civil compensation that, for the most part, has kept the details about his operation out of the public eye. As a result, much — but not all — of the testimony and evidence collected as part of the vast litigation has been sealed or redacted from public court records. https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Page 13 of 17 Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 14 of 18 The girls who were abused by Jeffrey Epstein and the cops who championed their cause remain angry over what they regard as a gross injustice, while Epstein's employees and those who engineered his non-prosecution agreement have prospered. By Taking a page from Epstein’s legal team, lawyers representing Epstein’s victims hired private investigators and former police detectives to dig into Epstein’s life. Over the past decade, they’ve tracked down hundreds of people, including dozens of other potential victims; they’ve interviewed Epstein’s recruiters, bookkeepers, housekeepers, butlers, pilots and drivers. They’ve traveled around the country and the world, taking statements and sworn depositions, coaxing people to talk who had previously been too reticent to come forward. In short, they did what criminal prosecutors didn’t do. Some of the information they’ve learned was given to federal authorities in New York. Edwards said those authorities have shown no interest in opening a new investigation focused on crimes he is alleged to have committed in that state, where he is listed as a level 3 sex offender, the most dangerous category, considered at risk to re-offend, records show. In New York, he has to register every 90 days. [REDACTED] holds a photo of herself at age 16, when she says Palm Beach multimillionaire Jeffrey Epstein began abusing her sexually. Emily Michot EMICHOT@MIAMIHERALD.COM Holding abusers accountable In 2015, Roberts sued Maxwell for defamation in New York after Maxwell called her a liar in a news interview. The civil lawsuit was an effort by Roberts not just to clear her name, but an attempt to prove that Epstein and Maxwell operated an international underage sex trafficking operation. The lawsuit was settled out of court in 2017 and nearly all the evidence presented in the case has been sealed. Roberts’ attorney, Sigrid McCawley, claims that Roberts received a sizable settlement, although the amount is confidential. “She wanted to hold her abusers accountable and we were able to do that by bringing this case … which we ultimately settled very successfully for her,’’ said McCawley, an associate of noted Bush-Gore recount lawyer David Boies, who has also pursued cases against Epstein in federal court in New York. https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Page 14 of 17 Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 15 of 18 Maxwell’s lawyer, Laura Menninger, declined to comment, referring the Herald to the court history. “[Roberts] fabricated a story of abuse at the hands of Ms. Maxwell in exchange for hundreds of thousands of dollars from British tabloids with a motive for selling papers and advertisements and without regard for truth, veracity or substantiation,’’ Menninger noted in a 2016 response filed in the case. In February, the Miami Herald filed a federal court motion in the Southern District of New York, seeking access to documents that were sealed in the Maxwell case. The motion, which was not opposed by Roberts, could have cast light on the full scope of Epstein’s possible sex trafficking operation, who was involved and whether it was covered up. Maxwell has opposed the Herald’s motion, which was denied in August. The Herald is appealing. Today, Epstein has a new private jet, which takes him around the world. Flight records show that he spends most of his time on his private island, Little St. James in the U.S. Virgin Islands, which he now lists as his permanent residence. He is registered in New York and the U.S. Virgin Islands as a sex offender. New Mexico, where he owns a sprawling ranch, does not list him as a convicted sex offender. As part of its investigation, the Herald learned that in 2013, the federal government conceded that it had given Epstein what it called “valuable consideration” for information he provided to the FBI as part of his plea deal. The documents do not elaborate, but Epstein — a hedge fund manager who once worked for the investment firm Bear Stearns — was listed as a key investor who lost money in the financial crash of 2008. Francey Hakes, a former federal child sex crimes prosecutor, said any consideration the government gave to Epstein should be made public. “The public has a right to know why he got a slap on the wrist, and what was the interest that was so great that allowed him to not get prosecuted?” https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Page 15 of 17 Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 16 of 18 Nadia Marcinkova, now a professional pilot, worked for Jeffrey Epstein when he was molesting young women. Victims told police Marcinkova would participate in sex acts, often as Epstein choreographed every move. Jerod Harris In recent years, Epstein has been traveling the world in his new Gulfstream V jet. He has been active in various charitable causes and scientific research projects. The Jeffrey Epstein VI Foundation, based in the U.S. Virgin Islands, has helped fund NeuroTV, an online network that features interviews with academics and scientists. Then and now Both Nadia Marcinkova and Sarah Kellen changed their names after the scandal. Marcinkova, 32, briefly became Marcinko. She visited Epstein more than 70 times when he was in Palm Beach custody. She went on to a career in real estate. And she is now an FAA-certified commercial pilot and flight instructor who goes by the name “Global Girl’’ on social media. (www.facebook.com/GlobalGirlAviation/) https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Page 16 of 17 Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 17 of 18 Sarah Kellen, who used the name Kensington for a while, is now married to NASCAR driver Brian Vickers. The couple divides their time between homes in North Carolina, New York and Miami Beach. NASCAR driver Brian Vickers and his wife, Sarah, take part in pre-race ceremonies in Sparta, Ky., on June 28, 2014. She was known as Sarah Kellen when she was an aide to Jeffrey Epstein. According to police, she scheduled visits of underage girls to Epstein’s Palm Beach estate for massages that turned sexual. She was not charged with a crime. Will Schneekloth GETTY IMAGES Maxwell, 56, transformed herself into an internationally known environmentalist. In 2012, she founded the TerraMar Project, a nonprofit environmental group that works to protect the world’s oceans. In 2013, she gave a TED Talk on ocean conservation, discussing her diving expeditions around the world. Dershowitz, 80, continues to lecture around the country. A professor emeritus at Harvard Law School, Dershowitz has been a frequent commenter on cable TV programs, often defending President Trump. Prince Andrew, the Duke of York, 58, remained friends with Epstein, and in 2010, a photograph was taken of the two of them strolling in Manhattan. It was later revealed that Epstein had loaned the prince’s ex-wife, Sarah Ferguson, $24,000 to pay off some debts. Ferguson later called the loan a “gigantic error of judgment.” Plain human beings Crime victims’ rights advocates have used the Epstein case to strengthen the federal law in recent years, adding more precise language mandating that prosecutors notify victims about plea bargains and allow victims to be heard at sentencing. Because some statute-of-limitation laws set deadlines for filing civil and criminal sex crime cases, it’s difficult to bring them years later, said Marci Hamilton, a University of Pennsylvania professor who is working to ease https://www.miamiherald.com/news/local/article219494920.html 4/3/2019 Even from jail, Jeffrey Epstein manipulated the system | Miami Herald Page 17 of 17 Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 18 of 18 those restrictions across the country. Ghislaine Maxwell, daughter of a British press magnate and Jeffrey Epstein’s close associate when he was inviting underage girls into his bedroom, leads a TED Talk on environmental issues. But she points out that there has been no statute of limitations for federal sex crimes involving children since 2002. Children who are sexually abused often take decades to reveal what happened to them, in part because their brains aren’t wired at a young age to understand the trauma they’ve experienced, said Kenneth V. Lanning, a retired FBI agent who investigated and studied child sex crimes for 40 years. “We want to hold children to some superhuman standard because they behave this way. In reality, police, prosecutors and judges have to understand that children are not all angels from heaven. They are just plain human beings who are emotionally immature so we have to protect them from their own decisions.’’ Wild, who continues to fight her federal case on behalf of all of Epstein’s victims, said she hopes that the federal judge hearing the Crime Victims’ Rights case will make a ruling soon, one that will send a message to prosecutors who fail to consider the rights of crime victims. “Really if you think about this too hard, it’s scary because this is our government that is supposed to protect us but has done everything to protect a pedophile,’’ she said. Support investigative journalism The Miami Herald obtained thousands of FBI and court records, lawsuits, and witness depositions, and went to federal court in New York to access sealed documents in the reporting of "Perversion of Justice." The Herald also tracked down more than 60 women who said they were victims, some of whom had never spoken of the abuse before. Your digital subscription, starting at $0.99 for the first month, supports investigative journalism like this. Case 1:19-cv-03377 Document 1-2 Filed 04/16/19 Page 1 of 4 EXHIBIT 2 Case 1:19-cv-03377 Document 1-2 Filed 04/16/19 Page 2 of 4 https://www.rawstory.com/2018/12/letter-editor-alan-dershowitz-responds-raw-story-report/ Case 1:19-cv-03377 Document 1-2 Filed 04/16/19 Page 3 of 4 https://www.rawstory.com/2018/12/letter-editor-alan-dershowitz-responds-raw-story-report/ Case 1:19-cv-03377 Document 1-2 Filed 04/16/19 Page 4 of 4 https://www.rawstory.com/2018/12/letter-editor-alan-dershowitz-responds-raw-story-report/ Case 1:19-cv-03377 Document 1-3 Filed 04/16/19 Page 1 of 3 EXHIBIT 3 Case 1:19-cv-03377 Document 1-3 Filed 04/16/19 Page 2 of 3 Alan Dershowitz: ‘I never had sex with [REDACTED]’ | Miami Herald miamiherald.com/opinion/letters-to-the-editor/article222532470.html In its series on the Jeffrey Epstein case, “Perversion of Justice,” the Herald quotes an affidavit by [REDACTED] — a woman I never met — claiming she had sex with me on Epstein’s island, ranch, plane and mansion. It then simply says I “denied” it. In fact, I disproved it. I produced my travel, phone, credit card and TV appearance records, conclusively proving that I could not have been and was not in any of these places during the time Roberts knew Epstein. The former FBI director, assisted by a former assistant U.S. attorney and a chief federal marshal, reviewed these records and the other evidence and concluded that, “The totality of the evidence found during the investigation refutes the allegations.” There is other evidence, currently under seal, that directly establishes my innocence. I am seeking to unseal emails between Roberts and a journalist, a book manuscript by Roberts and a legal brief that are smoking guns showing that I was “deliberately framed for financial reasons.” ADVERTISING inRead invented by Teads There is also irrefutable evidence that Roberts lied about other people for money. She told a British tabloid that she met Al and Tipper Gore on Epstein’s island and swore that she had dinner with Bill Clinton on the island. But Secret Service records prove that none of these people were on the island. Indeed, the Gores didn’t even know Epstein. Get six months of free digital access to the Miami Herald I have a tape recording of a conversation with Roberts’ closest friend in which she says that Roberts told her she “felt pressure to go after [Dershowitz]” in order to obtain money from a wealthy businessman, and that Roberts had never previously included me among the people with whom she claimed to have had sex. Finally, one of Roberts’ own lawyers has acknowledged in front of witnesses that her claims against me are “wrong” “simply wrong.” The evidence of my innocence is indisputable: I never met Roberts; I never had sex with her; she simply made up the entire story for money. Roberts made her false claims against me in court documents that immunize her from being sued for defamation. I challenge her to repeat her false accusations out of court, so that I can sue her for defamation and let a jury decide — after seeing all the evidence, 1/2 Case 1:19-cv-03377 Document 1-3 Filed 04/16/19 Page 3 of 3 including the suppressed emails and book manuscript — who is telling the truth and who is lying. 2/2 Case 1:19-cv-03377 Document 1-4 Filed 04/16/19 Page 1 of 4 EXHIBIT 4 https://lawandcrime.com/high-profile/dershowitz-goes-off-on-woman-who-made-underage-... 4/3/2019 Dershowitz Goes Off on Woman Who Made Underage Sex Allegations: 'She Should Be ... Case 1:19-cv-03377 Document 1-4 Filed 04/16/19 Page 2 of 4 Page 1 of 3 Dershowitz Goes Off on Woman Who Made Underage Sex Allegations: ‘She Should Be Seriously Punished’ by Ronn Blitzer | 2:26 pm, December 4th, 2018 Tweet Share � � 00:34 10:57 � � � Just hours after convicted pedophile Jeffrey Epstein agreed to settle a civil case brought against him by attorney Bradley Edwards, Epstein’s lawyer from his past criminal case, Alan Dershowitz, discussed his former client on the Law&Crime Network. Epstein was accused of trafficking more than 40 underage girls for sex, and one such girl claimed Dershowitz himself had sex with her when she was underage. Dershowitz vehemently denies the claim, telling host Brian Ross that accuser [REDACTED] is a “certified, complete, total liar,” and that her allegations are a “complete and total fabrication.” He also added that she should be punished by the law for what she did. The Harvard Law Professor Emeritus noted that Roberts’ allegations were eventually withdrawn, and that the FBI recognized the evidence showed he was not where she said he was. He pointed to documented evidence that proves he is innocent. “I can prove conclusively that she made the whole thing up,” Dershowitz said, citing travel records that he says prove where he was at the time she claims she had sex with him. “It’s conclusive, conclusive evidence.” “More importantly, I can prove where I wasn’t,” he said, after stating outright, “Never met her, don’t know who she is, never heard of her.” Similarly, Dershowitz said that Roberts claimed that notable figures such as Bill Clinton, Al Gore, and Tipper Gore were present on an https://lawandcrime.com/high-profile/dershowitz-goes-off-on-woman-who-made-underage-... 4/3/2019 Dershowitz Goes Off on Woman Who Made Underage Sex Allegations: 'She Should Be ... Case 1:19-cv-03377 Document 1-4 Filed 04/16/19 Page 3 of 4 Page 2 of 3 island, when Secret Service records proved they were never even there. Dershowitz said Roberts’ allegations were part of an extortion plot, and that she “should be seriously punished for submitting false information and a false affidavit.” The attorney emphasized that Roberts has not been willing to repeat her allegations against him in public, and that she has only accused him in the context of litigation, which affords certain protections. Advertisement “She simply hides behind litigation privileges,” Dershowitz said, encouraging Ross to call Roberts and see if she would repeat her claims. “And if she does, I will be in court the next day suing her for defamation and I will win the case ’cause I can prove conclusively that she made up the whole story from top to bottom.” Ross then turned to the controversial deal that Epstein received from federal prosecutors who were investigating the trafficking case against him. Federal prosecutors agreed not to prosecute him, and let him plead guilty to state charges that resulted in a 13-month prison sentence that allowed Epstein to leave prison during the day for work. Federal prosecutors allegedly did not even inform victims before making the deal, which is now the subject of a request for an Inspector General investigation. Congressional Democrats said in a letter that they want to know more about the circumstances surrounding the deal, which was made by then-U.S. Attorney and current Secretary of Labor Alex Acosta. As Epstein’s defense attorney in that case, Dershowitz is not upset about it the deal at all. “I’m very proud of that deal, that’s what lawyers are supposed to do,” he said. “Lawyers are supposed to get the best deals they can.” If he could have gotten 10 months or no time at all, that would have been even better, he said. Acosta said in the past that Epstein’s lawyers, including Dershowitz, put pressure on his office by investigating his staff. Dershowitz has denied this. “Acosta was very tough,” Dershowitz said, contrary to concerns that he did anything improper. Dershowitz pointed out that the problem feds had was proving that girls were transported in interstate commerce. https://lawandcrime.com/high-profile/dershowitz-goes-off-on-woman-who-made-underage-... 4/3/2019 Dershowitz Goes Off on Woman Who Made Underage Sex Allegations: 'She Should Be ... Case 1:19-cv-03377 Document 1-4 Filed 04/16/19 Page 4 of 4 Page 3 of 3 “Unless you can prove that, you don’t have a federal case, only a state case.” [Image via Law & Crime Network screengrab] Follow Law & Crime filed under Alan Dershowitz, Jefrey Epstein Case 1:19-cv-03377 Document 1-5 Filed 04/16/19 Page 1 of 3 EXHIBIT 5 Case 1:19-cv-03377 Document 1-5 Filed 04/16/19 Page 2 of 3 Case 1:19-cv-03377 Document 1-5 Filed 04/16/19 Page 3 of 3 Case 1:19-cv-03377 Document 1-6 Filed 04/16/19 Page 1 of 2 EXHIBIT 6 Case 1:19-cv-03377 Document 1-6 Filed 04/16/19 Page 2 of 2 https://twitter.com/AlanDersh Case 1:19-cv-03377 Document 1-7 Filed 04/16/19 Page 1 of 2 EXHIBIT 7 Case 1:19-cv-03377 Document 1-7 Filed 04/16/19 Page 2 of 2 Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 1 of 16 EXHIBIT 8 Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 2 of 16 http://www.vanityfair.com/news/2003/03/jeffrey‐epstein‐200303 Society The Talented Mr. Epstein Lately, Jeffrey Epstein’s high-flying style has been drawing oohs and aahs: the bachelor financier lives in New York’s largest private residence, claims to take only billionaires as clients, and flies celebrities including Bill Clinton and Kevin Spacey on his Boeing 727. But pierce his air of mystery and the picture changes. Vicky Ward explores Epstein’s investment career, his ties to retail magnate Leslie Wexner, and his complicated past. by � Vicky Ward June 27, 2011 12:00 am On Manhattan’s Upper East Side, home to some of the most expensive real estate on earth, exists the crown jewel of the city’s residential town houses. With its 15-foot-high oak door, huge arched windows, and nine floors, it sits on—or, rather, commands—the block of 71st Street between Fifth and Madison Avenues. Almost ludicrously out of proportion with its four- and five-story neighbors, it seems more like an institution than a house. This is perhaps not surprising—until 1989 it was the Birch Wathen private school. Now it is said to be Manhattan’s largest private residence. Inside, amid the flurry of menservants attired in sober black suits and pristine white gloves, you feel you have stumbled into someone’s private Xanadu. This is no mere rich person’s home, but a high-walled, eclectic, imperious fantasy that seems to have no boundaries. The entrance hall is decorated not with paintings but with row upon row of individually framed eyeballs; these, the owner tells people with relish, were imported from England, where they were made for injured soldiers. Next comes a marble foyer, which does have a painting, in the manner of Jean Dubuffet … but the host coyly refuses to tell visitors who painted it. In any case, guests are like pygmies next to the nearby twice-life-size sculpture of a naked African warrior. Despite its eccentricity the house is curiously impersonal, the statement of someone who wants to be known for the scale of his possessions. Its occupant, financier Jeffrey Epstein, 50, admits to friends that he likes it when people think of him this way. A good-looking man, resembling Ralph Lauren, with thick gray-white hair and a weathered face, he usually dresses in jeans, knit shirts, and loafers. He tells people he bought the house because he knew he “could never live anywhere bigger.” He thinks 51,000 square feet is an appropriately large space for someone like himself, who deals mostly in large concepts—especially large sums of money. Guests are invited to lunch or dinner at the town house—Epstein usually refers to the former as “tea,” since he likes to eat bite-size morsels and drink copious quantities of Earl Grey. (He does not touch alcohol or tobacco.) Tea is served in the “leather room,” so called because of the cordovan-colored fabric on the walls. The chairs are covered in a leopard print, and on the wall Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 3 of 16 http://www.vanityfair.com/news/2003/03/jeffrey‐epstein‐200303 hangs a huge, Oriental fantasy of a woman holding an opium pipe and caressing a snarling lionskin. Under her gaze, plates of finger sandwiches are delivered to Epstein and guests by the menservants in white gloves. Upstairs, to the right of a spiral staircase, is the “office,” an enormous gallery spanning the width of the house. Strangely, it holds no computer. Computers belong in the “computer room” (a smaller room at the back of the house), Epstein has been known to say. The office features a gilded desk (which Epstein tells people belonged to banker J. P. Morgan), 18th-century black lacquered Portuguese cabinets, and a nine-foot ebony Steinway “D” grand. On the desk, a paperback copy of the Marquis de Sade’s The Misfortunes of Virtue was recently spotted. Covering the floor, Epstein has explained, “is the largest Persian rug you’ll ever see in a private home—so big, it must have come from a mosque.” Amid such splendor, much of which reflects the work of the French decorator Alberto Pinto, who has worked for Jacques Chirac and the royal families of Jordan and Saudi Arabia, there is one particularly startling oddity: a stuffed black poodle, standing atop the grand piano. “No decorator would ever tell you to do that,” Epstein brags to visitors. “But I want people to think what it means to stuff a dog.” People can’t help but feel it’s Epstein’s way of saying that he always has the last word. ADVERTISEMENT In addition to the town house, Epstein lives in what is reputed to be the largest private dwelling in New Mexico, on an $18 million, 7,500-acre ranch which he named “Zorro.” “It makes the town house look like a shack,” Epstein has said. He also owns Little St. James, a 70-acre island in the U.S. Virgin Islands, where the main house is currently being renovated by Edward Tuttle, a designer of the Amanresorts. There is also a $6.8 million house in Palm Beach, Florida, and a fleet of aircraft: a Gulfstream IV, a helicopter, and a Boeing 727, replete with trading room, on which Epstein recently flew President Clinton, actors Chris Tucker and Kevin Spacey, supermarket magnate Ron Burkle, Lew Wasserman’s grandson, Casey Wasserman, and a few others, on a mission to explore the problems of AIDS and economic development in Africa. Epstein is charming, but he doesn’t let the charm slip into his eyes. They are steely and calculating, giving some hint at the steady whir of machinery running behind them. “Let’s play chess,” he said to me, after refusing to give an interview for this article. “You be white. You get the first move.” It was an appropriate metaphor for a man who seems to feel he can win no matter what the advantage of the other side. His advantage is that no one really seems to know him or his history completely or what his arsenal actually consists of. He has carefully engineered it so that he remains one of the few truly baffling mysteries among New York’s moneyed world. People know snippets, but few know the whole. “He’s very enigmatic,” says Rosa Monckton, the former C.E.O. of Tiffany & Co. in the U.K. and a close friend since the early 1980s. “You think you know him and then you peel off another ring of the onion skin and there’s something else extraordinary underneath. He never reveals his hand…. He’s a classic iceberg. What you see is not what you get.” Even acquaintances sense a curious dichotomy: Yes, he lives like a “modern maharaja,” as Leah Kleman, one of his art dealers, puts it. Yet he is fastidiously, almost obsessively private—he lists Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 4 of 16 http://www.vanityfair.com/news/2003/03/jeffrey‐epstein‐200303 himself in the phone book under a pseudonym. He rarely attends society gatherings or weddings or funerals; he considers eating in restaurants like “eating on the subway”—i.e., something he’d never do. There are many women in his life, mostly young, but there is no one of them to whom he has been able to commit. He describes his most public companion of the last decade, Ghislaine Maxwell, 41, the daughter of the late, disgraced media baron Robert Maxwell, as simply his “best friend.” He says she is not on his payroll, but she seems to organize much of his life—recently she was making telephone inquiries to find a California-based yoga instructor for him. (Epstein is still close to his two other long-term girlfriends, Paula Heil Fisher, a former associate of his at the brokerage firm Bear Stearns and now an opera producer, and Eva Andersson Dubin, a doctor and onetime model. He tells people that when a relationship is over the girlfriend “moves up, not down,” to friendship status.) Some of the businessmen who dine with him at his home—they include newspaper publisher Mort Zuckerman, banker Louis Ranieri, Revlon chairman Ronald Perelman, real-estate tycoon Leon Black, former Microsoft executive Nathan Myhrvold, Tom Pritzker (of Hyatt Hotels), and real-estate personality Donald Trump—sometimes seem not all that clear as to what he actually does to earn his millions. Certainly, you won’t find Epstein’s transactions written about on Bloomberg or talked about in the trading rooms. “The trading desks don’t seem to know him. It’s unusual for animals that big not to leave any footprints in the snow,” says a high-level investment manager. ADVERTISEMENT Unlike such fund managers as George Soros and Stanley Druckenmiller, whose client lists and stock maneuverings act as their calling cards, Epstein keeps all his deals and clients secret, bar one client: billionaire Leslie Wexner, the respected chairman of Limited Brands. Epstein insists that ever since he left Bear Stearns in 1981 he has managed money only for billionaires—who depend on him for discretion. “I was the only person crazy enough, or arrogant enough, or misplaced enough, to make my limit a billion dollars or more,” he tells people freely. According to him, the flat fees he receives from his clients, combined with his skill at playing the currency markets “with very large sums of money,” have afforded him the lifestyle he enjoys today. Why do billionaires choose him as their trustee? Because the problems of the mega-rich, he tells people, are different from yours and mine, and his unique philosophy is central to understanding those problems: “Very few people need any more money when they have a billion dollars. The key is not to have it do harm more than anything else…. You don’t want to lose your money.” He has likened his job to that of an architect—more specifically, one who specializes in remodeling: “I always describe [a billionaire] as someone who started out in a small home and as he became wealthier had add-ons. He added on another addition, he built a room over the garage … until you have a house that is usually a mess…. It’s a large house that has been put together over time where no one could foretell the financial future and their accompanying needs.” He makes it sound as though his job combines the roles of real-estate agent, accountant, lawyer, money manager, trustee, and confidant. But, as with Jay Gatsby, myths and rumor swirl around Epstein. Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 5 of 16 http://www.vanityfair.com/news/2003/03/jeffrey‐epstein‐200303 Here are some of the hard facts about Epstein—ones that he doesn’t mind people knowing: He grew up middle-class in Brooklyn. His father worked for the city’s parks department. His parents viewed education as “the way out” for him and his younger brother, Mark, now working in real estate. Jeffrey started to play the piano—for which he maintains a passion—at five, and he went to Brooklyn’s Lafayette High School. He was good at mathematics, and in his early 20s he got a job teaching physics and math at Dalton, the elite Manhattan private school. While there he began tutoring the son of Bear Stearns chairman Ace Greenberg and was friendly with a daughter of Greenberg’s. Soon he went to Bear Stearns, where, under the mentorship of both Greenberg and current Bear Stearns C.E.O. James Cayne, he did well enough to become a limited partner—a rung beneath full partner. He abruptly departed in 1981 because, he has said, he wanted to run his own business. Thereafter the details recede into shadow. A few of the handful of current friends who have known him since the early 1980s recall that he used to tell them he was a “bounty hunter,” recovering lost or stolen money for the government or for very rich people. He has a license to carry a firearm. For the last 15 years, he’s been running his business, J. Epstein & Co. Since Leslie Wexner appeared in his life—Epstein has said this was in 1986; others say it was in 1989, at the earliest—he has gradually, in a way that has not generally made headlines, come to be accepted by the Establishment. He’s a member of various commissions and councils: he is on the Trilateral Commission, the Council on Foreign Relations, the New York Academy of Sciences, and the Institute of International Education. His current fan club extends to Cayne, Henry Rosovsky, the former dean of Harvard’s Faculty of Arts and Sciences, and Larry Summers, Harvard’s current president. Harvard law professor Alan Dershowitz says, “I’m on my 20th book…. The only person outside of my immediate family that I send drafts to is Jeffrey.” Real-estate developer and philanthropist Marshall Rose, who has worked with Epstein on projects in New Albany, Ohio, for Wexner, says, “He digests and decodes the information very rapidly, which is to me terrific because we have shorter meetings.” Also on the list of admirers are former senator George Mitchell and a gaggle of distinguished scientists, most of whom Epstein has helped fund in recent years. They include Nobel Prize winners Gerald Edelman and Murray Gell-Mann, and mathematical biologist Martin Nowak. When these men describe Epstein, they talk about “energy” and “curiosity,” as well as a love for theoretical physics that they don’t ordinarily find in laymen. Gell-Mann rather sweetly mentions that “there are always pretty ladies around” when he goes to dinner chez Epstein, and he’s under the impression that Epstein’s clients include the Queen of England. Both Nowak and Dershowitz were thrilled to find themselves shaking the hand of a man named “Andrew” in Epstein’s house. “Andrew” turned out to be Prince Andrew, who subsequently arranged to sit in the back of Dershowitz’s law class. Epstein gets annoyed when anyone suggests that Wexner “made him.” “I had really rich clients before,” he has said. Yet he does not deny that he and Wexner have a special relationship. Epstein sees it as a partnership of equals. “People have said it’s like we have one brain between two of us: each has a side.” Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 6 of 16 http://www.vanityfair.com/news/2003/03/jeffrey‐epstein‐200303 “I think we both possess the skill of seeing patterns,” says Wexner. “But Jeffrey sees patterns in politics and financial markets, and I see patterns in lifestyle and fashion trends. My skills are not in investment strategy, and, as everyone who knows Jeffrey knows, his are not in fashion and design. We frequently discuss world trends as each of us sees them.” By the time Epstein met Wexner, the latter was a retail legend who had built a $3 billion empire—one that now includes Victoria’s Secret, Express, and Bath & Body Works—from $5,000 lent him by his aunt. “Wexner saw in Jeffrey the type of person who had the potential to realize his [Jeffrey’s] dreams,” says someone who has worked closely with both men. “He gave Jeffrey the ball, and Jeffrey hit it out of the park.” Wexner, through a trust, bought the town house in which Epstein now lives for a reported $13.2 million in 1989. In 1993, Wexner married Abigail Koppel, a 31-year-old lawyer, and the newlyweds relocated to Ohio; in 1996, Epstein moved into the town house. Public documents suggest that the house is still owned by the trust that bought it, but Epstein has said that he now owns the house. Wexner trusts Epstein so completely that he has assigned him the power of fiduciary over all of his private trusts and foundations, says a source close to Wexner. In 1992, Epstein even persuaded Wexner to put him on the board of the Wexner Foundation in place of Wexner’s ailing mother. Bella Wexner recovered and demanded to be reinstated. Epstein has said they settled by splitting the foundation in two. Epstein does not care that he comes between family members. In fact, he sees it as his job. He tells people, “I am there to represent my client, and if my client needs protecting—sometimes even from his own family—then it’s often better that people hate me, not the client.” “You’ve probably heard I’m vicious in my representation of my clients,” he tells people proudly; Leah Kleman describes his haggling over art prices as something like a scene out of the movie Mad Max: Beyond Thunderdome. Even a former mentor says he’s seen “the dark side” of Epstein, and a Bear Stearns source recalls a meeting in which Epstein chewed out a team making a presentation for Wexner as being so brutal as to be “irresponsible.” One reporter, in fact, received three threats from Epstein while preparing a piece. They were delivered in a jocular tone, but the message was clear: There will be trouble for your family if I don’t like the article. On the other hand, Epstein is clearly very generous with friends. Joe Pagano, an Aspen-based venture capitalist, who has known Epstein since before his Bear Stearns days, can’t say enough nice things: “I have a boy who’s dyslexic, and Jeffrey’s gotten close to him over the years…. Jeffrey got him into music. He bought him his first piano. And then as he got to school he had difficulty … in studying … so Jeffrey got him interested in taking flying lessons.” Rosa Monckton recalls Epstein telling her that her daughter, Domenica, who suffers from Down syndrome, needed the sun, and that Rosa should feel free to bring her to his house in Palm Beach anytime. Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 7 of 16 http://www.vanityfair.com/news/2003/03/jeffrey‐epstein‐200303 Some friends remember that in the late 80s Epstein would offer to upgrade the airline tickets of good friends by affixing first-class stickers; the only problem was that the stickers turned out to be unofficial. Sometimes the technique worked, but other times it didn’t, and the unwitting recipients found themselves exiled to coach. (Epstein has claimed that he paid for the upgrades, and had no knowledge of the stickers.) Many of those who benefited from Epstein’s largesse claim that his generosity comes with no strings attached. “I never felt he wanted anything from me in return,” says one old friend, who received a first-class upgrade. Epstein is known about town as a man who loves women—lots of them, mostly young. Model types have been heard saying they are full of gratitude to Epstein for flying them around, and he is a familiar face to many of the Victoria’s Secret girls. One young woman recalls being summoned by Ghislaine Maxwell to a concert at Epstein’s town house, where the women seemed to outnumber the men by far. “These were not women you’d see at Upper East Side dinners,” the woman recalls. “Many seemed foreign and dressed a little bizarrely.” This same guest also attended a cocktail party thrown by Maxwell that Prince Andrew attended, which was filled, she says, with young Russian models. “Some of the guests were horrified,” the woman says. “He’s reckless,” says a former business associate, “and he’s gotten more so. Money does that to you. He’s breaking the oath he made to himself—that he would never do anything that would expose him in the media. Right now, in the wake of the publicity following his trip with Clinton, he must be in a very difficult place.” According to S.E.C. and other legal documents unearthed by VANITY FAIR, Epstein may have good reason to keep his past cloaked in secrecy: his real mentor, it might seem, was not Leslie Wexner but Steven Jude Hoffenberg, 57, who, for a few months before the S.E.C. sued to freeze his assets in 1993, was trying to buy the New York Post. He is currently incarcerated in the Federal Medical Center in Devens, Massachusetts, serving a 20-year sentence for bilking investors out of more than $450 million in one of the largest Ponzi schemes in American history. When Epstein met Hoffenberg in London in the 1980s, the latter was the charismatic, audacious head of the Towers Financial Corporation, a collection agency that was supposed to buy debts that people owed to hospitals, banks, and phone companies. But Hoffenberg began using company funds to pay off earlier investors and service a lavish lifestyle that included a mansion on Long Island, homes on Manhattan’s Sutton Place and in Florida, and a fleet of cars and planes. Hoffenberg and Epstein had much in common. Both were smart and obsessed with making money. Both were from Brooklyn. According to Hoffenberg, the two men were introduced by Douglas Leese, a defense contractor. Epstein has said they were introduced by John Mitchell, the late attorney general. Epstein had been running International Assets Group Inc. (I.A.G.), a consulting company, out of his apartment in the Solo building on East 66th Street in New York. Though he has claimed that he managed money for billionaires only, in a 1989 deposition he testified that he spent 80 percent of his time assisting people recover stolen money from fraudulent brokers and lawyers. Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 8 of 16 http://www.vanityfair.com/news/2003/03/jeffrey‐epstein‐200303 He was also not above entering into risky, tax-sheltered oil and gas deals with much smaller investors. A lawsuit that Michael Stroll, the former head of Williams Electronics Inc., filed against Epstein shows that in 1982 I.A.G. received an investment from Stroll of $450,000, which Epstein put into oil. In 1984 Stroll asked for his money back; four years later he had received only $10,000. Stroll lost the suit, after Epstein claimed in court, among other things, that the check for $10,000 was for a horse he’d bought from Stroll. “My net worth never exceeded four and a half million dollars,” Stroll has said. Hoffenberg, says a close friend, “really liked Jeffrey…. Jeffrey has a way of getting under your skin, and he was under Hoffenberg’s.” Also appealing to Hoffenberg were Epstein’s social connections; they included oil mogul Cece Wang (father of the designer Vera) and Mohan Murjani, whose clothing company grew into Gloria Vanderbilt Jeans. Epstein lived large even then. One friend recalls that when he took Canadian heiress Wendy Belzberg on a date he hired a Rolls-Royce especially for the occasion. (Epstein has claimed he owned it.) In 1987, Hoffenberg, according to sources, set Epstein up in the offices he still occupies in the Villard House, on Madison Avenue, across a courtyard from the restaurant Le Cirque. Hoffenberg hired his new protégé as a consultant at $25,000 a month, and the relationship flourished. “They traveled everywhere together—on Hoffenberg’s plane, all around the world, they were always together,” says a source. Hoffenberg has claimed that Epstein confided in him, saying, for example, that he had left Bear Stearns in 1981 after he was discovered executing “illegal operations.” Several of Epstein’s Bear Stearns contemporaries recall that Epstein left the company very suddenly. Within the company there were rumors also that he was involved in a technical infringement, and it was thought that the executive committee asked that he resign after his two supporters, Ace Greenberg and Jimmy Cayne, were outnumbered. Greenberg says he can’t recall this; Cayne denies it happened, and Epstein has denied it as well. “Jeffrey Epstein left Bear Stearns of his own volition,” says Cayne. “It was never suggested that he leave by any member of management, and management never looked into any improprieties by him. Jeffrey said specifically, ‘I don’t want to work for anybody else. I want to work for myself.’” Yet, this is not the story that Epstein told to the S.E.C. in 1981 and to lawyers in a 1989 deposition involving a civil business case in Philadelphia. In 1981 the S.E.C.’s Jonathan Harris and Robert Blackburn took Epstein’s testimony and that of other Bear Stearns employees in part of what became a protracted case about insider trading around a tender offer placed on March 11, 1981, by the Seagram Company Ltd. for St. Joe Minerals Corp. Ultimately several Italian and Swiss investors were found guilty, including Italian financier Giuseppe Tome, who had used his relationship with Seagram owner Edgar Bronfman Sr. to obtain information about the tender offer. After the tender offer was announced, the S.E.C. began investigating trades involving St. Joe at Bear Stearns and other firms. Epstein resigned from Bear Stearns on March 12. The S.E.C. was tipped off that Epstein had information on insider trading at Bear Stearns, and it was therefore obliged to question him. In his S.E.C. testimony, given on April 1, 1981, Epstein claimed that he had found “offensive” the way Bear Stearns management had handled a disciplinary action Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 9 of 16 http://www.vanityfair.com/news/2003/03/jeffrey‐epstein‐200303 following its discovery that he had committed a possible “Reg D” violation—evidently he had lent money to his closest friend. (In the 1989 deposition he said that he’d lent approximately $20,000 to Warren Eisenstein, to buy stock.) Such an action could have been considered improper, although Epstein claimed he had not realized this until afterward. According to Epstein, Bear Stearns management had questioned him about the loan around March 4. The questioners, Epstein said, were Michael (Mickey) Tarnopol and Alvin Einbender. In his 1989 deposition Epstein recalled that the partner who had made an “issue” of the matter was Marvin Davidson. On March 9, Epstein said, he had met with Tarnopol and Einbender again, and the two partners told him that the executive committee had weighed the offense, together with previous “carelessness” over expenses, and he would be fined $2,500. “There was discussion whether, in fact, I had ever put in an airline ticket for someone else and not myself and I said that it was possible, … since my secretary handles my expenses,” Epstein told the S.E.C. In his 1989 testimony he stated that the “Reg D” incident had cost him a shot at partnership that year. What the S.E.C. seemed to be especially interested in was whether there was a connection between Epstein’s leaving and the alleged insider trading in St. Joe Minerals by other people at Bear Stearns: Q: Sir, are you aware that certain rumors may have been circulating around your firm in connection with your reasons for leaving the firm? A: I’m aware that there were many rumors. Q: What were the rumors you heard? A: Nothing to do with St. Joe. Q: Can you relate what you heard? A: It was having to do with an illicit affair with a secretary. Q: Have you heard any other rumors suggesting that you had made a presentation or communication to the Executive Committee concerning alleged improprieties by other members or employees of Bear Stearns? A: I, in fact, have heard that rumor, but it’s been from Mr. Harris in our conversation last week. Q: Have you heard it from anyone else? A: No. A little later the interview focuses on James Cayne: Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 10 of 16 http://www.vanityfair.com/news/2003/03/jeffrey‐epstein‐200303 Q: Did you ever hear while you were at Bear Stearns that Mr. Cayne may have trader or insider information in connection with St. Joe Minerals Corporation? Q: Did Mr. Cayne ever have any conversation with you about St. Joe Minerals? Q: Did you happen to overhear any conversations between Mr. Cayne and anyone else regarding St. Joe Minerals? And still later in the questioning comes this exchange: Q: Have you had any type of business dealings with Mr. Cayne? A: There’s no relationship with Bear Stearns. Q: Pardon? A: Other than Bear Stearns, no. Q: Have you been a participant in any type of business venture with Mr. Cayne? Q: Do you have any expectation of participating in any business venture with Mr. Cayne? Q: Have you had any business participations with Mr. Theram? A: No; nor do I anticipate any. Q: Mr. Epstein, did anyone at Bear Stearns tell you in words or substance that you should not divulge anything about St. Joe Minerals to the staff of the Securities and Exchange Commission? Q: Has anyone indicated to you in any way, either directly or indirectly, in words or substance, that your compensation for this past year or any future monies coming to you from Bear Stearns will be contingent upon your not divulging information to the Securities and Exchange Commission? A: No. Despite the circumstances of Epstein’s leaving, Bear Stearns agreed to pay him his annual bonus—which he anticipated as being approximately $100,000. The S.E.C. never brought any charges against anyone at Bear Stearns for insider trading in St. Joe, but its questioning seems to indicate that it was skeptical of Epstein’s answers. Some sources have wondered why, if he was such a big producer at Bear Stearns, he would have given it up over a mere $2,500 fine. Certainly the years after Epstein left the firm were not obviously prosperous ones. His luck didn’t seem to change until he met Hoffenberg. Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 11 of 16 http://www.vanityfair.com/news/2003/03/jeffrey‐epstein‐200303 One of Epstein’s first assignments for Hoffenberg was to mastermind doomed bids to take over Pan American World Airways in 1987 and Emery Air Freight Corp. in 1988. Hoffenberg claimed in a 1993 hearing before a grand jury in Illinois that Epstein came up with the idea of financing these bids through Towers’s acquisition of two ailing Illinois insurance companies, Associated Life and United Fire. “He was hired by us to work on the securities side of the insurance companies and Towers Financial, supposedly to make a profit for us and for the companies,” Hoffenberg reportedly told the grand jury. He also alleged that Epstein was the “technician,” executing the schemes, although, having no broker’s license, he had to rely on others to make the trades. Much of Hoffenberg’s subsequent testimony in his criminal case has proven to be false, and Epstein has claimed he was merely asked how the bids could be accomplished and has said he had nothing to do with the financing of them. Yet Richard Allen, the former treasurer of United Fire, recalls seeing Epstein two or three times at the company. He and another executive say they had direct dealing with Epstein over the finances. And in his deposition of 1989, Epstein stated that he was the one who executed “all” Hoffenberg’s instructions to buy and sell the stock. He called it “making the orders.” He could not recall whether he had chosen the brokers used. To win approval from the Illinois insurance regulators for Towers’s acquisition of the companies, Hoffenberg promised to inject $3 million of new capital into them. In fact, in his grand-jury testimony Hoffenberg claimed that he, his chief operating officer, Mitchell Brater, and Epstein came up with a scheme to steal $3 million of the insurance companies’ bonds to buy Pan Am and Emery stock. “Jeffrey Epstein and Mitch Brater arranged the various brokerage accounts for the bonds to be placed with in New York, and I think one in Chicago, Rodman & Renshaw,” Hoffenberg reportedly said. Then, said Hoffenberg, while making it appear as though they were investing the bonds in much safer financial instruments, they used them as collateral to buy the stock. “Epstein was the person in charge of the transactions, and Mitchell Brater was assisting him with it in coordination on behalf of the insurance companies’ money,” Hoffenberg claimed at the time. At one point, according to Hoffenberg, a broker forged the documents necessary for a $1.8 million check to be written on insurance-company funds. The check was used to buy more stock in the takeover targets. Meanwhile, in order to throw the insurance regulators off, the $1.8 million was reported as being safely invested in a money-market account. United Fire’s former chief financial officer Daniel Payton confirms part of Hoffenberg’s account. He says he recalls making one or two telephone calls to Epstein (at Hoffenberg’s direction) about the missing bonds. “He said, ‘Oh, yeah, they still exist.’ But we found out later that he had sold those assets … leveraged them … [and] used some margin account to take some positions in … Emery and Pan Am,” says Payton. Epstein’s extraordinary creativity was, according to Hoffenberg, responsible for the purchase by the insurance companies of a $500,000 bond, with no money down. “Epstein created a great scheme to purchase a $500,000 treasury bond that would not be shown … [as] margined or collateralized,” he reportedly told the grand jury. “It looked like it was free and clear but it actually wasn’t,” he said. Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 12 of 16 http://www.vanityfair.com/news/2003/03/jeffrey‐epstein‐200303 Epstein has denied he ever had any dealings with anyone from the insurance companies. But Richard Allen says he recalls talking to Epstein at Hoffenberg’s direction and telling him it was urgent they retrieve the missing bonds for a state examination. According to Allen, Epstein said, “We’ll get them back.” He had “kind of a flippant attitude,” says Allen. “They never came back.” Epstein, according to Hoffenberg, also came up with a scheme to manipulate the price of Emery Freight stock in an attempt to minimize the losses that occurred when Hoffenberg’s bid went wrong and the share price began to fall. This was alleged to have involved multiple clients’ accounts controlled by Epstein. Eventually, in 1991, insurance regulators in Illinois sued Hoffenberg. He settled the case, and Epstein, who was only a paid consultant, was never deposed or accused of any wrongdoing. Barry Gross, the attorney who was handling the suit for the regulators, says of Epstein, “He was very elusive…. It was hard to really track him down. There were a substantial number of checks for significant dollars that were paid to him, I remember…. He was this character we never got a handle on. Again we presumed that he was involved with the Pan Am and Emery run that Hoffenberg made, but we never got a chance to depose him.” “From the government’s discovery in the main sentencing against Hoffenberg it would seem the government was perhaps a bit lazy,” says David Lewis, who represented Mitchell Brater. “They went for what they knew they could get … and that was the fraudulent promissory notes [i.e., the much larger and unrelated part of Hoffenberg’s fraud, based in New York State]…. What they couldn’t get, they didn’t bother with.” Another lawyer involved in the criminal prosecution of Hoffenberg says, “In a criminal investigation like that, when there is a guilty plea, to be quick and dirty about it, discovery is always incomplete…. They don’t have to line up witnesses; they don’t have to learn every fact that might come out on cross-examination.” Epstein was involved with Hoffenberg in other questionable transactions. Financial records show that in 1988 Epstein invested $1.6 million in Riddell Sports Inc., a company that manufactures football helmets. Among his co-investors were the theater mogul Robert Nederlander and attorney Leonard Toboroff. A source close to this transaction claims that Epstein told Nederlander and Toboroff that he had raised his share of the money from a Swiss banker, whose identity they could not be allowed to know. But Hoffenberg has claimed the money came from him, and Towers’s financial statements for that year show a loan to Epstein of $400,000. (Epstein has said he can’t remember the details and has disputed the accuracy of the Towers financial reports.) Around the same time, Nederlander and Toboroff let Epstein come in with them on a scheme to make money out of Pennwalt, a Pennsylvania chemical company. The plan was to group together with two other parties to take a substantial declared position in the stock. According to a source, Epstein was supposed to help Nederlander and Toboroff raise $15 million. He seemed to fail to find other investors, say those familiar with the deal. (Epstein has said he was merely an investor.) He invested $1 million, which he told his co-investors was his own money. But in his Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 13 of 16 http://www.vanityfair.com/news/2003/03/jeffrey‐epstein‐200303 1989 deposition he said that he put in only $300,000 of his own money. Where did the rest come from? Hoffenberg has said it came from him, in a loan that Nederlander and Toboroff didn’t know about. Two things happened that alarmed Nederlander and Toboroff. After the group signaled a possible takeover, the Pennwalt management threatened to sue the would-be raiders. Epstein was reluctant initially to give a deposition about his share of the money, telling Toboroff there were “reasons” he didn’t want to. Then, after the opportunity for new investors was closed, coinvestors recall Epstein announcing that he’d found one at last: Dick Snyder, then C.E.O. of the publisher Simon & Schuster, who wanted to put up approximately $500,000. (Neither Epstein nor Snyder can now recall the investment. Yet in the 1989 deposition Epstein said that he had recruited Snyder, whom he had met socially, into the deal.) According to a source, Toboroff and Nederlander told Epstein that Snyder was too late, but, without their realizing it, Hoffenberg has claimed, Snyder wrote a check to Hoffenberg and bought out some of his investment. But then Snyder wanted out. “Nederlander started to get these irate calls from [Snyder,] who wasn’t part of the deal, saying he was owed all this money,” says someone close to the deal. Toboroff and Nederlander were baffled. Eventually, a source close to Hoffenberg says, Hoffenberg paid Snyder off. Just as Nederlander and Toboroff were growing wary of Epstein, he became increasingly involved with Leslie Wexner, whom he had met through insurance executive Robert Meister and his late wife. Epstein has told people that he met Wexner in 1986 in Palm Beach, and that he won his confidence by persuading him not to invest in the stock market, just as the 1987 crash was approaching. His story has subsequently changed. When asked if Wexner knew about his connection to Hoffenberg, Epstein said that he began working for Wexner in 1989, and that “it was certainly not the same time.” Wherever and whenever it was that Epstein and Wexner actually met, there was an immediate and strong personal chemistry. Wexner says he thinks Epstein is “very smart with a combination of excellent judgment and unusually high standards. Also, he is always a most loyal friend.” Sources say Epstein proved that he could be useful to Wexner as well, with “fresh” ideas about investments. “Wexner had a couple of bad investments, and Jeffrey cleaned those up right away,” says a former associate of Epstein’s. Before he signed on with Wexner, Epstein had several meetings with Harold Levin, then head of Wexner Investments, in which he enunciated ideas about currencies that Levin found incomprehensible. “In fact,” says someone who used to work very closely with Wexner, “almost everyone at the Limited wondered who Epstein was; he literally came out of nowhere.” “Everyone was mystified as to what his appeal was,” says Robert Morosky, a former vicechairman of the Limited. Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 14 of 16 http://www.vanityfair.com/news/2003/03/jeffrey‐epstein‐200303 Much of Epstein’s work is related to cleaning up, tightening budgets, and efficiencies. One person who worked for Wexner and who saw a contract drawn up between the two men says Epstein is involved in “everything, not just a little here, a little there. Everything!” In addition, he says, “Wexner likes having a hatchet man…. Whenever there is dirty work to be done he’d stick Jeffrey on it…. He has a reputation for being ruthless but he gets the job done.” Epstein has evidently been asked to fire personal-staff members when needed. “He was that mysterious person that everyone was scared to death of,” says a former employee. Meanwhile, he is also less than popular with some people outside Wexner’s company with whom he now deals. “He ‘inserted’ himself into the construction process of Leslie Wexner’s yacht…. That resulted in litigation down the road between Mr. Wexner and the shipyard that eventually built the vessel,” says Lars Forsberg, a lawyer whose firm at the time, Dickerson and Reily, was hired to deal with litigation stemming from the construction of Wexner’s Limitless— at 315 feet, one of the largest private yachts in the world. Evidently, Epstein stalled on paying Dickerson and Reily for its work. “It’s probably once or twice in my legal career that I’ve had to sue a client for payment of services that he’d requested and we’d performed … without issue on the performance,” says Forsberg. In the end the matter was settled, but Epstein claims he now has no recollection of it. The incident is one of a number of disputes Epstein has become embroiled in. Some are for sums so tiny as to be baffling; for instance, Epstein sued investment adviser Herbert Glass, who sold him the Palm Beach house in 1990, for $13,444—Epstein claimed this was owed him for furnishings removed by Glass. In 1998 the U.S. Attorney’s Office sued Epstein for illegally subletting the former home of the deputy consul general of Iran to attorney Ivan Fisher and others. Epstein paid $15,000 a month in rent to the State Department, but he charged Fisher and his colleagues $20,000. Though the exact terms of the agreement are sealed, the court ruled against Epstein. Wexner offers some insight into his friend’s combative style. “Many times people confuse winning and losing,” Wexner says. “Jeffrey has the unusual quality of knowing when he is winning. Whether in conversations or negotiations, he always stands back and lets the other person determine the style and manner of the conversation or negotiation. And then he responds in their style. Jeffrey sees it in chivalrous terms. He does not pick a fight, but if there is a fight, he will let you choose your weapon.” One case is rather more serious. Currently, Citibank is suing Epstein for defaulting on loans from its private-banking arm for $20 million. Epstein claims that Citibank “fraudulently induced” him into borrowing the money for investments. Citibank disputes this charge. The legal papers for another case offer a rare window into Epstein’s finances. In 1995, Epstein stopped paying rent to his landlord, the nonprofit Municipal Arts Society, for his office in the Villard House. He claimed that they were breaking the terms of the lease by not letting his staff in at night. The case was eventually settled. However, one of the papers filed in this dispute is Epstein’s financial statement for 1988, in which he claimed to be worth $20 million. He listed Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 15 of 16 http://www.vanityfair.com/news/2003/03/jeffrey‐epstein‐200303 that he owned $7 million in securities, $1 million in cash, zero in residential property (although he told sources that he had already bought the home in Palm Beach), and $11 million in other assets, including his investment in Riddell. A co-investor in Riddell says: “The company had been bought with a huge amount of debt, and it wasn’t public, so it was meaningless to attach a figure like that to it … the price it cost was about $1.2 million.” The co-investors bought out Epstein’s share in Riddell in 1995 for approximately $3 million. At that time, when Epstein was asked, as a routine matter, to sign a paper guaranteeing he had access to a few million dollars in case of any subsequent disputes over the sale price, Wexner signed for him. Epstein has explained that this was because the co-investors wanted an indemnity against being sued by Wexner. One of the investors calls this “bullshit.” Epstein’s appointment to the board of New York’s Rockefeller University in 2000 brought him into greater social prominence. Boasting such social names as Nancy Kissinger, Brooke Astor, and Robert Bass, the board also includes such pre-eminent scientists as Nobel laureate Joseph Goldstein. “Epstein was thrilled to be elected,” says someone who knows him. After one term Epstein resigned. According to New York magazine, this was because he didn’t like to wear a suit to meetings. A spokesperson for the Rockefeller board says Epstein left because he had insufficient time to commit; a board member recalls that he was “arrogant” and “not a good fit.” The spokesperson admits that it is “infrequent” for board members not to be renominated after only one term. Still, the recent spate of publicity Epstein has inspired does not seem to have fazed him. In November he was spotted in the front row of the Victoria’s Secret fashion show at New York’s Lexington Avenue Armory; around the same time the usual coterie of friends and beautiful women were whisked off to Little St. James (which he tells people has been renamed Little St. Jeff) for a long weekend. Thanks to Epstein’s introductions, says Martin Nowak, the biologist finds himself moving from Princeton to Harvard, where he is assuming the joint position of professor of mathematics and professor of biology. Epstein has pledged at least $25 million to Harvard to create the Epstein Program for Mathematical Biology and Evolutionary Dynamics, and Epstein will have an office at the university. The program will be dedicated to searching for nature’s algorithms, a pursuit that is a specialty of Nowak’s. For Epstein this must be the summit of everything he has worked toward: he has been seen proudly displaying Harvard president Larry Summers’s letter of commitment as if he can’t quite believe it is real. He says he was reluctant to have his name attached to the program, but Summers persuaded him. He rang his mentor Wexner about it, and Wexner told him it was all right. An insatiable, restless soul, always on the move, Epstein builds a tremendous amount of downtime into his hectic work schedule. Yet there is something almost programmed about his relaxation: it’s as if even pleasure has to be measured in terms of self-improvement. Nowak says that, when he goes to stay with Epstein in the Caribbean, they’ll get up at six and, as the sun rises, have three-hour conversations about theoretical physics. “Then he’ll go off and do some work, re-appear, and we’ll talk some more.” Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 16 of 16 http://www.vanityfair.com/news/2003/03/jeffrey‐epstein‐200303 Another person who went to the island with Epstein, Maxwell, and several beautiful women remembers that the women “sat around one night teasing him about the kinds of grasping women who might want to date him. He was amused by the idea…. He’s like a king in his own world.” Many people comment there is something innocent, almost childlike about Jeffrey Epstein. They see this as refreshing, given the sophistication of his surroundings. Alan Dershowitz says that, as he was getting to know Epstein, his wife asked him if he would still be close to him if Epstein suddenly filed for bankruptcy. Dershowitz says he replied, “Absolutely. I would be as interested in him as a friend if we had hamburgers on the boardwalk in Coney Island and talked about his ideas.” Case 1:19-cv-03377 Document 1-9 Filed 04/16/19 Page 1 of 4 EXHIBIT 9 Case 1:19-cv-03377 Document 1-9 Filed 04/16/19 Page 2 of 4 4/15/2019 Alan Dershowitz says he's still advising Jeffrey Epstein - Axios Alan Dershowitz says he's still advising Jeffrey Epstein Alan Dershowitz still provides legal advice to serial pedophile Jeffrey Epstein, he confirmed to Axios. What he's saying: "He has called me a couple of times about legal issues, because I'm still technically his lawyer," Dershowitz told me in a phone interview on Saturday. "But I haven't had any social, or any other kind of contact. ... You never stop being a person's lawyer." Background: Dershowitz helped Epstein get a sweetheart plea deal from then-U.S. Attorney Alexander Acosta (now Donald Trump's labor secretary and a rumored long-shot contender for attorney general). A bombshell Miami Herald investigative series last week highlighted for the first time the extent of Epstein's alleged crimes and the soft treatment he received from federal prosecutors. The Palm Beach multimillionaire would "serve just 13 months in the county jail, but the deal — called a non-prosecution agreement — essentially shut down an ongoing FBI probe into whether there were more victims and other powerful people who took part in Epstein’s sex crimes," according to a Miami Herald examination of thousands of emails, court documents and FBI records. https://www.axios.com/alan-dershowitz-jeffrey-epstein-legal-advice-1a13ad59-a718-46c9-9813-11231604a387.html 1/3 Case 1:19-cv-03377 Document 1-9 Filed 04/16/19 Page 3 of 4 4/15/2019 Alan Dershowitz says he's still advising Jeffrey Epstein - Axios Dozens of women alleged that Epstein molested and raped them when they were underaged using a sophisticated human trafficking network. A civil trial is scheduled to begin on Tuesday in Palm Beach County that may finally let these women tell their stories in court. Behind the scenes: While he was allegedly raping teenage girls, Epstein cultivated cozy relationships with America's elites. Bill Clinton flew on Epstein's plane, nicknamed the "Lolita Express," numerous times, according to flight logs. And Donald Trump, in a profile with New York magazine written several years before the police caught up with Epstein, praised his friend as a "terrific guy." "It is even said that he likes beautiful women as much as I do," Trump said of Epstein, "and many of them are on the younger side." Dershowitz was also friendly with Epstein before the broader public knew he was a pedophile. Dershowitz confirmed to me that he received a massage at Epstein's Palm Beach home, adding that the woman who provided it was of legal age. "What happened was I, um, he lent us, this was well before any of this thing came out, he lent us his house once. And I was there, my grandchildren were there, my daughter was there, and we all got massages." "And, um, it was therapeutic. I had a therapeutic massage with an old old Russian, but I never never ... and that was part of when we had his house for about a week during I think it was Christmas vacation." "Believe me, if I had known that anything improper had ever taken place in that house, I never would have allowed my children, my grandchildren, my wife, my daughter-in-law, my son, to have spent time there. I can tell you categorically there were no inappropriate pictures, no inappropriate anythings. It was like any other house." One of Epstein's accusers, [REDACTED], has claimed Dershowitz had sex with her when she was underage. Dershowitz has denied the allegation and told the Miami Herald "the story was 100 percent flatly categorically made-up" so "she could get money." Go deeper: Trump defender Dershowitz shunned by Martha's Vineyard https://www.axios.com/alan-dershowitz-jeffrey-epstein-legal-advice-1a13ad59-a718-46c9-9813-11231604a387.html 2/3 Case 1:19-cv-03377 Document 1-9 Filed 04/16/19 Page 4 of 4 4/15/2019 Alan Dershowitz says he's still advising Jeffrey Epstein - Axios SEXUAL ASSAULT Show less https://www.axios.com/alan-dershowitz-jeffrey-epstein-legal-advice-1a13ad59-a718-46c9-9813-11231604a387.html 3/3 Case 1:19-cv-03377 Document 1-10 Filed 04/16/19 Page 1 of 3 EXHIBIT 10 Case 1:19-cv-03377 Document 1-10 Filed 04/16/19 Page 2 of 3 4/9/2019 Opinion | Jeffrey Epstein’s Attorneys: A Fair Plea Deal - The New York Times LETTER Jeffrey Epstein’s Attorneys: A Fair Plea Deal The attorneys for a man accused of sexual abuse of young women defend the prosecutors’ decision to drop federal charges against him. March 4, 2019 To the Editor: Re “The Cowardly Labor Secretary” (editorial, March 3): Your editorial’s conclusions are in profound conflict with the reality as we, Jeffrey Epstein’s current and former lawyers, knew it. When he was United States attorney for the Southern District of Florida in 2007, Alexander Acosta, the current labor secretary, oversaw a plea deal for Mr. Epstein involving charges of solicitation of prostitution involving young women. Your underlying premise is that Mr. Acosta had capitulated and not filed federal charges because Mr. Epstein had a “high-priced defense team.” This was categorically denied by the Southern District’s then first assistant, Jeffrey H. Sloman, in an Op-Ed article in The Miami Herald on Feb. 15. Mr. Sloman correctly represented the existence of “significant legal impediments to [federally] prosecuting” what was a quintessentially state case. He also correctly represented that the government had achieved its principal objectives — a felony plea, incarceration, millions of dollars in restitution and monetary settlements, and lifetime sex offender registration — through its agreement with Mr. Epstein. That agreement was reviewed at multiple levels of the Justice Department. An agreement rather than a trial is how over 97 percent of federal cases get resolved, through negotiations by two teams of experienced professionals. The case lacked the credible and compelling proof that is required by federal criminal statutes. That the guilty plea was required in a state, not federal, court reflected the absence of evidence that Mr. Epstein used the internet, traveled to a location away from his home for the purpose of having illegal sex, commercially trafficked women to others, engaged in force, fraud or coercion, used drugs or alcohol to entice young women who came to his house to exchange sexual massages for money, possessed child pornography or in other ways violated federal law. https://www.nytimes.com/2019/03/04/opinion/letters/jeffrey-epstein.html 1/2 Case 1:19-cv-03377 Document 1-10 Filed 04/16/19 Page 3 of 3 The number of young women involved in the investigation has been vastly exaggerated, there was no “international sex-trafficking operation” and there was never evidence that Mr. Epstein “hosted sex parties” at his home. 4/9/2019 Opinion | Jeffrey Epstein’s Attorneys: A Fair Plea Deal - The New York Times You have 3 free articles remaining. Subscribe to The Times Finally, Mr. Epstein has gone to prison and made enormous monetary settlements relying on his negotiated agreement. He is entitled to finality like every other defendant. Kenneth W. Starr Martin G. Weinberg Jack Goldberger Lilly Ann Sanchez A version of this article appears in print on March 5, 2019, on Page A26 of the New York edition with the headline: Jeffrey Epstein’s Attorneys: A Fair Plea Deal https://www.nytimes.com/2019/03/04/opinion/letters/jeffrey-epstein.html 2/2 Case 1:19-cv-03377 Document 1-11 Filed 04/16/19 Page 1 of 4 EXHIBIT 11 Case 1:19-cv-03377 Document 1-11 Filed 04/16/19 Page 2 of 4 4/8/2019 Prof. Dershowitz, Tell Me How You Really Feel | Law.com Prof. Dershowitz, Tell Me How You Really Feel Harvard's legendary law professor chats with the Careerist about the recent sex allegations, his enemies and the "cesspool." By Vivia Chen | January 15, 2015 at 06:19 PM | Originally published on The American Lawyer (Alan Dershowitz) Alan Dershowitz, arguably the most famous—and maybe infamous—law professor in the land, wants to set the record straight. When he heard that I was writing about his relationship with billionaire Jeffrey Epstein and the related allegation that Dershowitz engaged in sex with a minor, he tracked me down to tell his side of the story. The backdrop: Dershowitz was part of a legal team that had negotiated a plea deal in 2008 in which Epstein pleaded guilty to felony charges in Florida for soliciting prostitution from a minor. Epstein served 13 months in prison but was spared federal charges under the deal. Last December, lawyers Bradley Edwards and Paul Cassellfiled suit against the U.S. government, arguing that the plea deal violated the rights of Epstein’s alleged sex victims; the suit also alleges that Dershowitz had sex with one of the victims when she was under age. Dershowitz has denied all the allegations, and Edwards and Cassell have filed a defamation suit against Dershowitz for calling them liars. The following are excerpts from my two phone conversations with Dershowitz: From what I’ve read, your relationship with Epstein seemed chummy. You socialized with him and you and your family stayed at his various homes. Isn’t it a bad idea for a lawyer to be so close to a notorious client? Let me tell you how I met him. I was introduced to him by Lady de Rothschild as an academic colleague. He was friendly with Larry Summers . . . He was in the process of contributing $50 million to Harvard for evolutionary biology. So Epstein was friendly with all sorts of Harvard muckety-mucks. https://www.law.com/almID/1202715316005/Prof-Dershowitz-Tell-Me-How-You-Really-Feel/?slreturn=20190308174659 1/3 Case 1:19-cv-03377 Document 1-11 Filed 04/16/19 Page 3 of 4 4/8/2019 Prof. Dershowitz, Tell Me How You Really Feel | Law.com The fact that he was giving money didn’t hurt. We went to events that he was involved in but none of us suspected that he had another side until later. Jeffrey loved academics. My conversations with him were only about academic subjects. We never discussed females or our social life. Did your relationship change with Epstein when you took him on as a client? Virtually all my social contact with him was of an academic nature, and it was prior to the time he was indicted. My relationship with him was entirely professional. It is a total bum rap to say that I “cavorted” with him or was “chummy” with him. I teach my students never, never get too close to clients—and certainly don’t do anything improper with them. The suit says that Jane Doe No. 3 was forced to have sex with you, Prince Andrew and “many other powerful men,” including unnamed politicians, foreign presidents and world leaders. Why were you and the Prince singled out by name? They want to void the plea agreement and needed to find a lawyer who knew Epstein before [the indictment], and had been on his island, his home in New Mexico, Palm Beach. I fit the bill. It was lawyer profiling. And the Prince? They claimed that Prince Andrew was using his influence to get Epstein a better deal with the government. What’s more laughable than suggesting that the U.S. Attorney would listen to the Prince to go easy on Epstein! Why bother responding if you think the allegations are so outrageous? Why not just let the facts come out during the legal process? I have to respond to everything. That’s the way I am. Imagine having an unblemished personal life then reading graffiti scrawled on the bathroom door that gets picked up in every paper based on the assertions of a woman who’s a serial liar. Brad Edwards, one of the lawyers bringing this suit, has a history of legal entanglement with Epstein, as does his former partner Scott Rothstein, who’s now in prison for his role in a Ponzi scheme. But the other lawyer in this case, Paul Cassell, is a former federal judge and a law professor. Why is he getting involved? Everyone is shocked that he would be part of this. I think he’s always hated me because I’m his opposite. I’m the conventional liberal he hates: I’m against the death penalty, I’m pro abortion rights, pro gun control. Seems risky to bring a lawsuit for just ideological differences. No one can understand Cassell’s motive. Either he will be disbarred or I will be. And if I knowingly had sex with a sex slave then I would deserve disbarment. What about the reaction? Do you feel you’ve been treated fairly by the press and the public? I’ve been treated particularly harshly by lawyers and law professors. They are so quick to say that I might be guilty. They’re getting too much pleasure out of this. There’s a dose of schadenfreude. Why do you think people like getting you upset? I’m controversial and more famous than they are. There’s a lot of jealousy. https://www.law.com/almID/1202715316005/Prof-Dershowitz-Tell-Me-How-You-Really-Feel/?slreturn=20190308174659 2/3 Case 1:19-cv-03377 Document 1-11 Filed 04/16/19 Page 4 of 4 4/8/2019 Prof. Dershowitz, Tell Me How You Really Feel | Law.com I gather you’re talking about legal academia. Yes, it’s a cesspool of jealousy. People in it lack courage. But you’re no stranger to harsh criticism. People weren’t exactly nominating you for a justice award for getting O.J. Simpson and Claus von Bulow off the hook. Some of the criticisms against me have been just. I’m a tough lawyer. But charging me with one of the most heinous crimes is on a different level. I’ve never been attacked like this. I don’t know any lawyer or professor who’s had these accusations waged against them. It’s worse than what Clarence Darrow had to face. You retired from Harvard Law School a year ago. Did you expect so much excitement at this stage of your career? This is an absolute shock. I’m living my little life here [in Florida, New York and Martha's Vineyard]. I lead a boring life. I’ve been married to the same woman for 28 years. She goes with me everywhere. People know that I won’t argue a case or give a speech unless my wife travels with me. This is not the profile of someone who screws around. You take all this very, very personally, don’t you? Wouldn’t you? I’ve got two grandchildren in college and they are reading this about me. This is the fight of my life. Note: We have been in contact with Edwards and Cassell and hope to get their sides of the story soon. https://www.law.com/almID/1202715316005/Prof-Dershowitz-Tell-Me-How-You-Really-Feel/?slreturn=20190308174659 3/3 Case 1:19-cv-03377 Document 1-12 Filed 04/16/19 Page 1 of 4 EXHIBIT 12 Case 1:19-cv-03377 Document 1-12 Filed 04/16/19 Page 2 of 4 Case 1:19-cv-03377 Document 1-12 Filed 04/16/19 Page 3 of 4 Case 1:19-cv-03377 Document 1-12 Filed 04/16/19 Page 4 of 4 Case 1:19-cv-03377 Document 1-13 Filed 04/16/19 Page 1 of 4 EXHIBIT 13 Case 1:19-cv-03377 Document 1-13 Filed 04/16/19 Page 2 of 4 Case 1:19-cv-03377 Document 1-13 Filed 04/16/19 Page 3 of 4 Case 1:19-cv-03377 Document 1-13 Filed 04/16/19 Page 4 of 4 Case 1:19-cv-03377 Document 1-14 Filed 04/16/19 Page 1 of 3 EXHIBIT 14 Case 1:19-cv-03377 Document 1-14 Filed 04/16/19 Page 2 of 3 Case 1:19-cv-03377 Document 1-14 Filed 04/16/19 Page 3 of 3 Case 1:19-cv-03377 Document 1-15 Filed 04/16/19 Page 1 of 2 EXHIBIT 15 Case 1:19-cv-03377 Document 1-15 Filed 04/16/19 Page 2 of 2 Case 1:19-cv-03377 Document 1-16 Filed 04/16/19 Page 1 of 6 EXHIBIT 16 Case 1:19-cv-03377 Document 1-16 Filed 04/16/19 Page 2 of 6 An Epstein sex case is settled; Dershowitz denies latest allegation BY JULIE K. BROWN DECEMBER 19, 2018 8:30 PM, UPDATED DECEMBER 27, 2018 7:55 AM Accused sex traffickers Jeffrey Epstein and Ghislaine Maxwell have settled a federal civil lawsuit filed by a woman who says she was ordered under threat of violence to have sex with them and other influential individuals when she was in her early 20s, sources confirmed Wednesday. [REDACTED], who now lives in Barcelona, claimed that she was recruited and trafficked for sex by the pair in 2006 and 2007 — at the same time that Epstein, a wealthy New York hedge fund manager, was under federal investigation for molesting dozens of underage girls at his Palm Beach mansion. Women who say they were victims of sexual abuse at the hands of Palm Beach multimillionaire Jeffrey Epstein want a judge to throw out his lenient plea deal. AP According to a recent court transcript, among those people Ransome claims she was directed to have sex with was Epstein’s lawyer, Alan Dershowitz, who helped negotiate a controversial plea https://www.miamiherald.com/latest-news/article223315075.html Case 1:19-cv-03377 Document 1-16 Filed 04/16/19 Page 3 of 6 deal that gave the eccentric multimillionaire — and co-conspirators employed by Epstein — federal immunity in 2008. Dershowitz, 80, told the Miami Herald that he has never met Ransome nor has he ever had sex with her. He accused Ransome’s attorney, powerhouse lawyer David Boies, of inventing the story and using her and another woman, [REDACTED], to frame him. Roberts asserted in a federal court affidavit in 2015 that Epstein forced her to have sex with Dershowitz when she was 16 years old. “I am the victim. David Boies and these women are the perpetrators,’’ Dershowitz said. “They have willfully and deliberately concocted stories in order to make money — millions and millions of dollars. And I will not rest until the entire story comes out,’’ said Dershowitz, a professor at Harvard Law School and frequent Fox news guest commentator. Nowhere in the court case or the transcript does Ransome or anyone else allege that Ransome had sex with Dershowitz — only that she was directed to. The Ransome settlement, which is confidential, comes two weeks after Epstein settled another lawsuit in Palm Beach, filed by an attorney who represented several women who said they were coerced into sex acts with Epstein when they were underage. As part of the settlement, Epstein, 65, issued an apology to Fort Lauderdale attorney Bradley Edwards, admitting that he leveled false claims in a lawsuit as part of an effort to intimidate Edwards into abandoning his aggressive advocacy for the women, who are now in their late 20s and early 30s. The developments follow a series of stories published by the Miami Herald in late November that detailed how state and federal prosecutors worked with Epstein’s lawyers to conceal the extent of Epstein’s crimes, and secretly negotiated an unusual plea agreement that allowed him to escape federal sex trafficking charges that could have sent him to prison for life. The agreement, by design, was kept from his victims so that they could not appear at his sentencing. Last week, more than two dozen lawmakers in Washington demanded a federal investigation into that plea deal, which was negotiated, signed and sealed by former Miami U.S. Attorney Alexander Acosta, now President Donald Trump’s secretary of labor. Acosta has not commented on the Herald story or on the calls for a probe into how he handled the Epstein case. This week, a decade after defending Epstein, Dershowitz once again found himself in the spotlight amid the new allegations, mentioned briefly in a court filing on Nov. 28, and first reported on Tuesday by the New York Daily News. During a Nov. 7 hearing, Maxwell’s lawyer, Laura Menninger, mentioned Dershowitz’s name as among those “third parties’’ that Ransome claims she was instructed to have sex with, according to a transcript of the hearing obtained by the Herald. On Tuesday, after the Daily News published its story, Dershowitz lashed out in dozens of posts on Twitter, denouncing Ransome as “delusional’’ and claiming that her lawyer, Boies, was retaliating against him because Dershowitz had filed a bar complaint against him. Alan Dershowitz says he has never met the woman who alleges in a lawsuit she was ordered to have sex with influential men, including the famous lawyer. John Lamparski GETTY IMAGES/TNS “Attorney David Boies threatened that unless I withdrew a bar complaint I had filed against him for falsely accusing me of sexual misconduct, he would find another woman to accuse me of similar misconduct. He has https://www.miamiherald.com/latest-news/article223315075.html Case 1:19-cv-03377 Document 1-16 Filed 04/16/19 Page 4 of 6 now found an unbalanced woman who has delusions of having sex tapes of Donald Trump, Hillary Clinton, Bill Clinton and other prominent figures,’’ Dershowitz said in a tweet. Boies, best known for arguing on behalf of Vice President Al Gore in the 2000 Florida election recount, responded in an interview with the Herald: “[Dershowitz’s] charges are absurd. Either he has become totally unhinged or he thinks that if he says things that are loud enough and crazy enough it will distract attention from what he has done. There is no support — none — for what he says.’’ Ransome claimed that, in her early 20s, she was recruited to work as a masseuse for Epstein who, in exchange, promised he would help her get into fashion design in New York, according to her civil lawsuit, filed in January 2017. Epstein and Maxwell then kept her passport and threatened to ruin her life and physically harm her if she didn’t have sex with them and others in 2006 and 2007, Ransome said in the complaint. The complaint alleges that this all occurred at the same time as Epstein’s lawyers were negotiating with Acosta and other federal prosecutors for a deal to avoid federal sex trafficking charges in connection with a scheme in which he lured underprivileged girls, mostly 13 to 16, to his home in Palm Beach under the pretense that he would pay them $200 to $300 for massages. Instead, police in Palm Beach found that he had been molesting and sexually abusing dozens of girls between 2001 and 2007. In this photograph, [REDACTED] socializes with Prince Andrew as Jeffrey Epstein associate Guislaine Maxwell stands in the background. Roberts claims she was effectively used as a sex slave by Epstein. In that capacity she had sex with the prince, Roberts says. The prince denied that. COURTESY OF [REDACTED] Under the plea deal, known as a non-prosecution agreement, Epstein was allowed to plead guilty in state court to two prostitution charges. He served 13 months in a private wing of the Palm Beach County jail, where he was given liberal work release privileges. The deal also quashed an FBI investigation into whether Epstein was operating an international sex trafficking organization, the Herald found as part of its yearlong investigation. “Even as [Epstein, Maxwell and other defendants] and their attorneys were busy arguing Epstein’s innocence and publicly defaming his victims as liars...defendants merely changed their location’’ from Palm Beach to “other places in the U.S. [including the Southern District of New York] and abroad and brought them to Epstein’s mansion in New York City and his private island in the Virgin Islands,’’ Ransome’s complaint alleged. https://www.miamiherald.com/latest-news/article223315075.html Case 1:19-cv-03377 Document 1-16 Filed 04/16/19 Page 5 of 6 Dershowitz, in interviews with the Herald, and in recent public statements, said he has never met Ransome. He also said she initially tried to interest the New York Post in her story, but a reporter whom he said he spoke with told him Ransome was not credible. He said he has a trove of emails between Ransome and the reporter that prove she is a “lunatic.’’ “There are hundreds of emails in which she claimed to have sex with everybody in the world and also claimed she has video of Hillary Clinton, Bill Clinton, Donald Trump and others having sex with underage girls — but she never ever accused me in these emails,’’ Dershowitz said. The emails are under seal, he said, and therefore cannot be made public. Dershowitz said he has asked the court to unseal them but his efforts thus far have been unsuccessful. In the recent court transcript, however, it is Maxwell’s attorney, Laura Menninger — not Ransome or her attorneys — who named Dershowitz. “[Ransome] has alleged not only that my client [Maxwell] ran a sex trafficking organization but she claims also that she was directed by my client and the Epstein defendants to have sex with third parties, including Alan Dershowitz, for example,’’ Menninger said. “And so to the extent my client or Mr. Dershowitz or anyone else is going to be asked about their private sexual activity, I believe that would implicate their privacy rights...’’ Roberts, who now lives in Australia, said that Epstein ordered her to have sex with Dershowitz six times, according to a 2015 affidavit, which was filed in connection with an unrelated Epstein federal lawsuit. At that time, Dershowitz launched a media blitz on TV asserting that Roberts made up the story. He also called for Roberts’ lawyers — Edwards and University of Utah law professor Paul Cassell — to be disbarred. The lawyers sued Dershowitz for defamation, and the case was settled last year. Dershowitz publicly declared he was vindicated after a federal judge ordered Roberts’ affidavit stricken from the court record. But the judge did not address the veracity of her sexual misconduct claims; he instead ruled that the affidavit was misplaced in a case not involving Dershowitz. Boies, whose firm represented Roberts pro bono, addressed Dershowitz’s longstanding contention that he had been exonerated. “Anytime in a lawsuit where you were the defendant and you paid the plaintiff $900,000 to settle it — that’s a strange kind of vindication,’’ Boies said, asserting that Dershowitz paid that amount as part of the defamation settlement with Edwards and Cassell. In 2016, Dershowitz released a statement following what he said was “an independent investigation’’ that had been conducted by former FBI Director Louis Freeh, who is now a private consultant. “Our investigation found no evidence to support the accusations of sexual misconduct against Professor Dershowitz. In fact, in several instances, the evidence directly contradicted the accusations made against him,’’ Freeh wrote. Most of the court records in the Roberts case are sealed. In February, the Miami Herald filed a motion in the Southern District of New York, seeking access to documents. The motion, which was not opposed by Roberts, could shed more light on the full scope of Epstein’s crimes and who was involved. https://www.miamiherald.com/latest-news/article223315075.html Case 1:19-cv-03377 Document 1-16 Filed 04/16/19 Page 6 of 6 The motion was denied. The Herald is appealing. https://www.miamiherald.com/latest-news/article223315075.html