EXHIBIT A [1332-16]

EXHIBIT A\nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 1 of 16\n\nRICHARD D. EMERY\nANDREW G. CELLI, JR.\nMATTHEW D. BRINCKERHOFF\nJONATHAN S. ABADY\nEARL S. WARD\nILANN M. MAAZEL\nHAL R. LIEBERMAN\nDANIEL J. KORNSTEIN\nO. ANDREW F. WILSON\nELIZABETH S. SAYLOR\nDEBRA L. GREENBERGER\nZOE SALZMAN\nSAM SHAPIRO\nALISON FRICK\nDAVID LEBOWITZ\nHAYLEY HOROWITZ\nDOUGLAS E. LIEB\nALANNA KAUFMAN\nJESSICA CLARKE\nEMMA L. FREEMAN\nEMERY CELLI BRINCKERHOFF & ABADY LLP\n \nATTORNEYS AT LAW \n600 FIFTH AVENUE AT ROCKEFELLER CENTER \n10TH FLOOR \nNEW YORK, NEW YORK 10020 \nTELEPHONE\n(212) 763-5000\nFACSIMILE \n(212) 763-5001\nWEB ADDRESS\nwww.ecbalaw.com\nCHARLES J. OGLETREE, JR.\nDIANE L. HOUK\nFILED UNDER SEAL\nJune 21, 2017\nBy ECF\nHonorable Robert W. Sweet\nUnited States District Court\nSouthern District of New York\n500 Pearl Street\nNew York, NY 10007\nRe:\nGiuffre v. Maxwell, No. 15 Civ. 7433 (RWS)\nDear Judge Sweet:\nThis firm represents Intervenor Professor Alan M. Dershowitz, and we write in \nanticipation of the parties’ forthcoming motion practice concerning the confidentiality of the \n[REDACTED] deposition.1 Intervenor requests that, if the Court allows Plaintiff Virginia \nGiuffre to remove the confidentiality designation concerning the Ransome deposition—an action \nthat would require modification of the Protective Order in this case —it also simultaneously \nremove the confidentiality designation from several related emails and attachments that the\nparties previously designated confidential (RANSOME_000273-557) (“the Emails”). The \nEmails will demonstrate that Ms. Ransome’s inflammatory, salacious, and defamatory testimony \nconcerning the Intervenor and others is false and that the deponent is not credible. Absent this \nrelief, Ms. Ransome’s unrebutted testimony will gravely prejudice Intervenor by publishing \ndeliberate lies calculated to harm his reputation. Counsel for Ms. Giuffre has not indicated \nwhether she consents to removing the confidentiality designation from the Emails; and counsel \nhas indicated that Ms. Giuffre “is not sure” whether she will seek to remove the confidentiality \ndesignation from the Ransome deposition, notwithstanding her prior letter requesting that relief \n1 Intervenor Dershowitz respectfully submits that issues concerning the confidentiality of particular materials under \nthe protective order are not mooted by the settlement of the underlying action. See Gambale v. Deutsche Bank AG, \n377 F.3d 133, 140-41 (2d Cir. 2004).\nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 2 of 16\n\nEMERY CELLI BRINCKERHOFF & ABADY LLP\nPage 2 \nprivately. Nevertheless, we write in an abundance of caution and to avoid the risk of a de-\ncontextualized and one-sided disclosure.\n \nIn a letter from her counsel Boise Shiller Flexner LLP to Laura Menninger on May 5, \n2017, Ms. Giuffre purported to give notice of her “withdrawal of her confidentiality designation \nof Ms. Ransome’s deposition transcript in its entirety.” We understand Ms. Maxwell will move \nto oppose this de-designation.\n \nIf the Court allows Ms. Giuffre to remove the confidentiality designation from the \nRansome deposition, the Emails should be disclosed at the same time to allow the public to \nunderstand the full context of Ms. Ransome’s testimony, and to assess the credibility (or lack \nthereof) of Ms. Ransome. Ms. Giuffre should not be permitted to use this Court’s power to make \na false and heinous public accusation against Intervenor (like the publicly filed false affidavits in \nprior litigation concerning Intervenor) and then shield from disclosure all proof that the \naccusation is perjurious (as she has done previously in this case by designating her book \nmanuscript and emails to the press, which show her claims against Intervenor to be false, as \nconfidential).\n \nIntervenor seeks the de-designation of the Emails to challenge Ms. Ransome’s false and \ndefamatory accusations that, among other things, she had sexual intercourse with Intervenor \nwhen she was twenty-three. Ms. Ransome’s allegations concerning Intervenor are categorically \nfalse. Prof. Dershowitz has never met or had contact with Ms. Ransome, was not her lawyer, and \ncertainly never had a sexual encounter with her. Prior to this action, Intervenor had never heard \nof Ms. Ransome. Her testimony was fabricated from whole cloth. Ms. Ransome’s testimony \nalso contains a slew of other incendiary claims concerning the sexual proclivities of Donald \nTrump, Bill Clinton, and other prominent individuals. \n \nThe Emails are a necessary antidote to Ms. Ransome’s deposition misstatements because \nthey demonstrate she manifestly lacks credibility. For example, she writes: \nx\n“My emails have been hacked. I have reached out to the Russians for help and they are \ncoming to my aid. Thank goodness for Anonymous!!!! I will make sure that they all go \nbehind bars. I have already sent everything I need to so, the CIA, hacking my emails etc \nwere too late. I also have numerous devices, with systems that are unhackable and I have \nfilm footage all over Europe itching to be released.” Ex. 1 (RANSOME_000521);\nx\nHer friend was “approached, by Special Agents Forces Men sent directly by Hilary [sic] \nClinton herself, in order to protect her presidential campaign.” Ex. 2 \n(RANSOME_000295);\nx\n“I will make sure that neither that evil bitch Hillary or that Paedophile Trump gets \nelected. I will also make sure that everyone on the God damn planet see’s [sic] that \nfootage and photo’s [sic] and will release them to Wiki leaks by Sunday. I will take \ndown Epstein and his bunch of fuck wit cronies myself!!!!!!!!!! I have also gone to a \nRussian news paper.” Ex. 3 (RANSOME_000368); \nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 3 of 16\n\nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 4 of 16\nEMERY CELLI BRINCKERHOFF & ABADY LLP \nPage 3 \n• \n"Clinton[ ] and Trump must pay for what they did to us as must the rest of the men that \nwere involved in their seedy inner circle." Ex. 4 (RANSOME_000284); \n• \n"[M]y friend had sexual intercourse with Clinton, Prince Andrew and Richard Branson, \nsex tapes were in fact filmed on each separate occasion ... I eventually managed to \npersuade her to send me some of the video footage which she kept, implicating all three \nall men ... I have backed up the footage on several USB sticks and have securely sent \nthem to various different locations throughout Europe." Ex. 5 (RANSOME_000295); \n• \n"[A]nother friend ... was one of the many girls that had sexual relations with Donald \nTrump ... She confided in me about her casual 'friendship' with Donald. Mr. Trump \ndefinitely seemed to have a thing for her and she told me how he kept going on about \nhow he liked her 'pert nipples'. Donald Trump liked flicking and sucking her nipples \nuntil they were raw. One evening when we were showering together she showed me her \nnipples. They looked incredibly painful as they were red and swollen and I remember \nwincing when I looked at them. I also know she had sexual relations with Trump at \nJeffery's NY mansion on regular occasions as I once met Jen for coffee, just before she \nwas going to meet Trump and Epstein together at his mansion." Ex. 6 \n(RANSOME_ 000296); \nImportantly, the Emails, which fatally undermine Ms. Ransome's credibility, were not \navailable to Ms. Maxwell's counsel when she examined Ms. Ransome in the deposition in this \ncase. For this reason, the deposition transcript standing alone leaves an incomplete and, thus, \nfalse impression of Ms. Ransome and her outrageous claims. \nThis Court should not allow its power to enter and modify a protective order to be \nmanipulated so as to authorize selective disclosure of de-contextualized materials. If the \nRansome deposition is made public, the Emails must also be as well. \nRespectfully submitted, \nc: \nCounsel for Plaintiff and Defendant (by Email) \n\nExhibit 1\nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 5 of 16\n\nFrom:\n[REDACTED]\nTo:\nSubject:\nRe: Our talk -\nDate:\nSunday, October 23, 2016 3:52:09 AM\nDear Maureen,\nI have spoken to my family at some length this morning and I would like to retract everything\nI have said to you and walk away from this.\nI shouldn't have contacted you and I'm sorry I wasted your time. It's not worth coming forward\nand I will never be heard anyhow and only bad things will happen as a consequence of me\ngoing public and I know this to be true. This will just create pain for my family and I and they\nhave already helped me pick up the pieces once before and I can't ask them to do that again. \nI'm disappointed that you have made little contact or didn't do anything to help me this week\nas it been a little terrifying for Peter and myself but I understand your stance and we managed\nto get through it. Prehaps if I was in your position I would have done the same?\nI guess one person can't make a difference. \nI wish you the best of luck on catching Epstein and company.\nRegards\nSarah\nFrom: [REDACTED] <\n \nTo: [REDACTED] <r\n \nSubject: Re: Our talk - \nSent: Sat, Oct 22, 2016 4:52:41 PM \nMaureen,\nMy emails been hacked. I have reached out to the Russians for help and they are coming to my\naid. Thank goodness for Anonymous!!!!\nI will make sure that they all go behind bars. I have already sent everything I need to so, the\nCIA, hacking my emails etc were too late. \nI also have numerous devices, with systems that are unhackable and I have film footage all\nover Europe itching to be released. \nThanks again for your help. You really took one for the team. Nice! I hope you go to sleep at\nnight wondering just quite where you will end up after this life is finished. Don't believe me? I\ncan prove that too. You don't know who I am and I am not going to go away until I have\nachieved my goals on getting the bad guys where they belong.\nCONFIDENTIAL\nRANSOME_000521\nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 6 of 16\n\nExhibit 2\nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 7 of 16\n\nwhilst he spanked his penis on her bottom.\nShe also had to have sexual intercourse with Clinton in Epstein’s New York Mansion just off 5th\nAvenue on numerous occasions. It’s the NY Mansion we spoke about yesterday. I too was forced\nby Epstein to visit regularly and if I didn’t turn up he would personally come and find me where ever\nI was hiding. It still bewilders me how Epstein always seemed to know where I was if I didn’t turn up\nat his NY residence. \nWhen my friend had sexual intercourse with Clinton, Prince Andrew and Richard Branson, sex\ntapes were in fact filmed on each separate occasion by Jeffery. Thank God she managed to get a\nhold of some footage of the filmed sex tapes, which clearly identify the faces of Clinton, Prince\nAndrew and Branson having sexual intercourse with her. Frustratingly enough Epstein was not\nseen in any of the footage but he was clever like that!\nAfter two hours of trying to convince my friend to come forward with me, I eventually managed to\npersuade her to send me some of the video footage which she kept, implicating all three all men\nmentioned above. I personally can confirm that I have, with my own two eyes, seen the evidence of\nthese sexual acts, which clearly identifies Bill Clinton, Prince Andrew, Richard Branson having\nsexual intercourse with my friend. I will be more then willing to swear under oath and testify in court\nover these sex tapes. It will break your heart into a million tiny pieces Maureen when you watch this\nfootage, and I know that what I watched yesterday, will haunt me for the rest of my life!\nUnfortunately, I cannot send you the footage without her consent due to massive consequences to\nher safety but I can confirm that I do have footage in my possession. I have backed up the footage\non several USB sticks and have securely sent them to various different locations throughout\nEurope with only one other person close to me, knowing where their locations are, just in case\nanything happens to me before the footage is released.\nWhen my friend eventually had the courage to speak out and went to the police in 2008 to report\nwhat had happened, nothing was done and she was utterly humiliated by the police department\nwhere she went to report what had happened with Epstein, Clinton, Branson and Prince Andrew.\nShe was made to feel like a dirty whore and a liar and wasn’t taken seriously. When she then tried\nto sue Epstein for damages, she was severely bullied and threatened by his lawyer Alan\nDershowitz whom she also had sexual relations with and who was also heavily involved in\nEpstein's paedophile Ring.\nA couple months later, she was then approached, by Special Agents Forces Men sent directly by\nHilary Clinton herself, in order to protect her presidential campaign in 2008. They heavily\nintimidated her, ruffled her up (luckily she took photos as evidence) and was then forced to sign a\nconfidentiality agreement which ensures that she can never come forward publicly implicating her\nhusband.\nShe was then given a substantial payout, directly from the Clinton Foundation to keep her quiet.\nShe is 1000% certain that the FBI did a cover up and she has the individual names of Hilary’s\nSpecial Agent Officers involved in intimidating her. She was then forced against her will to sign a\nlegally binding confidentially agreement on Hilary’s behalf for her eternal silence. If she breaks this\nagreement, she is dead.\nShe told me how it was a complete conspiracy as Alan Dershowitz, whom was one of the lawyers\nthat represented Jeffery when he went to trail, made huge endorsements to the Clinton Foundation\nto help fund her 2008 presidential campaign.\nI personally met Alan numerous times as Jeffery had sent him to my legal aid, to deal with a case I\nwas going to open against \n whom I met through the website SugarDaddie.com (he went under the name \n on the site). \n also tried to rape me with his friend when we were at anchor on\nhis boat in Miami.\nCONFIDENTIAL\nRANSOME_000295\nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 8 of 16\n-\n\nExhibit 3\nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 9 of 16\n\nI'm stronger then that and mark my words I will take them and you down with me if you do\nnot publish my story!!!!!!!!!!!!\n* I have already corresponded with the Moscow police and aid them in stopping Hillary or\nTrump getting through.\n*I will film my own interview on this subject and post it on every single one of my social\nmedia apps and ask everybody to share it!!! (I have lived all over the world some I have quite\na big little black book of my own! \nI have also emailed Wiki Leaks and Anonymous, because my voice will be heard if it's the last\nthing I do!!!\nI will not stand by and let anyone else be hurt and I want those bastards to see my face when I\nwas in my coma. That was a result of the trauma they put me through. No one else will suffer,\ndo you understand me!!!!!!! I thought you were on our side!\nYou have really annoyed the wrong person and I am done being nice to anyone anymore.\nSo there you have your God damn headline, I'm taking the world to Ransom and taking down\nall the evil people with or without your help!\nSarah\nFrom: [REDACTED] <\n>; \nTo: Maureen Callahan <\n>; \nSubject: Re: Our talk - \nSent: Fri, Oct 21, 2016 11:23:08 AM \nMaureen,\nSeeming as MY and my fiancé's life is in danger and nothing has been done!!!! Even though I\nhave every bit of evidence to implicate all parties mentioned. \nMark my words, I will make sure that neither that evil bitch Hillary or that Paedophile Trump\ngets elected. I will also make sure that everyone on the God damn planet see's that footage and\nphoto's and will release them to Wiki leaks by Sunday. I will take down Epstein and his bunch\nof fuck wit cronies myself!!!!!!!!!!\nI have also gone to a Russian news paper. \nSeeming as the US Goverment won't help me surprise surprise, I will help myself...... just like\nI alsways have!!!!! \nYou've just lost your exclusive and I AM SUPER FUCKED OFF NOW!!!!\nI feel so strongly about taking down these evil cunts, that even if you offered me enough\nmoney to buy the biggest Super Yacht in the world, which would give me the ability to hire\nand then fire all the people that where dicks to me, when I worked in the industry, I will still\nnot diaviate from my goal. \nCONFIDENTIAL\nRANSOME_000368\nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 10 of 16\n\nExhibit 4\nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 11 of 16\n\nThu, Oct 13, 2016 5:43:06 PM \nHi Sarah,\nNo need to apologize at all. I'm with you -- the more girls who can\ncome forward the better. We're in a new climate now -- it's the\nvictimizers who should be scared, not the victims.\nSend me the best number to call you at, and we'll talk next week.\nThanks to you for reaching out.\nSincerely,\nM\nOn Thu, Oct 13, 2016 at 1:27 PM, [REDACTED]\n<\n> wrote:\nThat's great. We need to get the other girls to come forward\nMaureen as they are all be afraid. I however am not intimated and\nneed your help. These men distroyed my life. \nI apologize for my heated first email to you however when I came\nacross your acticle in the NYC Post, how that happened I don't\nknow and everything came flooding back. I would never dream of\ncontacting anyone about this but something made me reach out to\nyou.\nWhat they did was wrong and I have spent the last 10 years trying\nto forget what happened on that Island. There are more girls\nMaureen. More then you can ever imagine. They're scared and so\nam I but Jeffery, Clinton, and Trump must\npay for what they did to us as must the rest of the men that were\ninvolved in their seedy inner circle. We have to get the rest of the\ngirls to come forward somehow?\nI look forward to you your\ncall and thank you for taking the time to listen to me. \nKind Regards\nSarah\nCONFIDENTIAL\nRANSOME_000284\nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 12 of 16\n\nExhibit 5\nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 13 of 16\n\nwhilst he spanked his penis on her bottom.\nShe also had to have sexual intercourse with Clinton in Epstein’s New York Mansion just off 5th\nAvenue on numerous occasions. It’s the NY Mansion we spoke about yesterday. I too was forced\nby Epstein to visit regularly and if I didn’t turn up he would personally come and find me where ever\nI was hiding. It still bewilders me how Epstein always seemed to know where I was if I didn’t turn up\nat his NY residence. \nWhen my friend had sexual intercourse with Clinton, Prince Andrew and Richard Branson, sex\ntapes were in fact filmed on each separate occasion by Jeffery. Thank God she managed to get a\nhold of some footage of the filmed sex tapes, which clearly identify the faces of Clinton, Prince\nAndrew and Branson having sexual intercourse with her. Frustratingly enough Epstein was not\nseen in any of the footage but he was clever like that!\nAfter two hours of trying to convince my friend to come forward with me, I eventually managed to\npersuade her to send me some of the video footage which she kept, implicating all three all men\nmentioned above. I personally can confirm that I have, with my own two eyes, seen the evidence of\nthese sexual acts, which clearly identifies Bill Clinton, Prince Andrew, Richard Branson having\nsexual intercourse with my friend. I will be more then willing to swear under oath and testify in court\nover these sex tapes. It will break your heart into a million tiny pieces Maureen when you watch this\nfootage, and I know that what I watched yesterday, will haunt me for the rest of my life!\nUnfortunately, I cannot send you the footage without her consent due to massive consequences to\nher safety but I can confirm that I do have footage in my possession. I have backed up the footage\non several USB sticks and have securely sent them to various different locations throughout\nEurope with only one other person close to me, knowing where their locations are, just in case\nanything happens to me before the footage is released.\nWhen my friend eventually had the courage to speak out and went to the police in 2008 to report\nwhat had happened, nothing was done and she was utterly humiliated by the police department\nwhere she went to report what had happened with Epstein, Clinton, Branson and Prince Andrew.\nShe was made to feel like a dirty whore and a liar and wasn’t taken seriously. When she then tried\nto sue Epstein for damages, she was severely bullied and threatened by his lawyer Alan\nDershowitz whom she also had sexual relations with and who was also heavily involved in\nEpstein's paedophile Ring.\nA couple months later, she was then approached, by Special Agents Forces Men sent directly by\nHilary Clinton herself, in order to protect her presidential campaign in 2008. They heavily\nintimidated her, ruffled her up (luckily she took photos as evidence) and was then forced to sign a\nconfidentiality agreement which ensures that she can never come forward publicly implicating her\nhusband.\nShe was then given a substantial payout, directly from the Clinton Foundation to keep her quiet.\nShe is 1000% certain that the FBI did a cover up and she has the individual names of Hilary’s\nSpecial Agent Officers involved in intimidating her. She was then forced against her will to sign a\nlegally binding confidentially agreement on Hilary’s behalf for her eternal silence. If she breaks this\nagreement, she is dead.\nShe told me how it was a complete conspiracy as Alan Dershowitz, whom was one of the lawyers\nthat represented Jeffery when he went to trail, made huge endorsements to the Clinton Foundation\nto help fund her 2008 presidential campaign.\nI personally met Alan numerous times as Jeffery had sent him to my legal aid, to deal with a case I\nwas going to open against \n whom I met through the website SugarDaddie.com (he went under the name \n the site). \n also tried to rape me with his friend when we were at anchor on\nhis boat in Miami.\nCONFIDENTIAL\nRANSOME_000295\nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 14 of 16\n-\n\nExhibit 6\nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 15 of 16\n\nseveral girls at any one time. She confided in me about her casual “friendship" with Donald. Mr\nTrump definitely seemed to have a thing for her and she told me how he kept going on about how\nhe liked her "pert nipples”.\nDonald Trump liked flicking and sucking her nipples until they were raw. One evening when we\nwere showering together she showed me her nipples. They looked incredibly painful as they were\nred and swollen and I remember wincing when I looked at them. I also know she had sexual\nrelations with Trump at Jeffery’s NY mansion on regular occasions as I once met Jen for coffee,\njust before she was going to meet Trump and Epstein together at his mansion.\nI will shortly start forwarding you, all the emails which I have managed to save. They include the\nfollowing:\n I moved from Edinburgh to\nNew York in September 2006, where shortly after I was introduced to Jeffery Epstein by Natalie.\n. A couple months later, after he constantly stalked me around\nEdinburgh, I moved to New York to get as far away from him as possible and to start a new life.\nI will send you that photo, amongst others as soon as I am able to fly back to the UK next week as I\ndefinitely, 100% have it all in my little storage box. I also have other photo’s of the Epstein girls and\nI, whilst on the Island including a couple of pictures of me with Sergey Brin and his then finance\nAnne Wojcicki. I met the pair when they visited the Island for the day as Sergey wanted try out his\nnew kite surfing equipment as he had only just started kite surfing and was very eager to try out his\nnew equipment with us girls.\nIn my secret box, I also have old sim cards which still contain old text messages and telephone\nnumbers which I will have to send you next week once I have them. Hopefully Jens number will be\nthere and I can trace her somehow, surely?\n* Email exchanges with Sarah Kellen which includes flight tickets booked for me to St Thomas.\n*Email exchanges with Lesley Groff ,which proves that I was asked to source girls from modelling\nagencies when I went home to see my family in Cape Town. How Jeffery used education as a way\nfor me to trade my soul to the Devil and become a sex slave to pay for my studies at FIT in New\nYork.\nI was desperate to get qualified and get a proper career. The email also show's evidence that I had\nto become almost anorexic for Jeffery to even entertain the idea of him paying for my tuition. As\nyou will see, Lesley Groff asked me to send her a picture for Jeffery.\nI would like to point out that I had to regularly send nude photo's to Lesley so that Jeffery could\ncheck how my body looked and if I was putting on any weight.\n* An email which was exchanged between \n using his code name \nvia Sugar Daddie.com. I have other correspondence which I had with him in my storage box in\nEngland.\n* Email exchanges between the girl Natalie Malyshev whom received funds from Jeffery for\nintroducing me to him.\nCONFIDENTIAL\nRANSOME_000297\nCase 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 16 of 16