HOUSE_OVERSIGHT_015613


From:
To:
Subject:
Date:
Thomas E. Scott; Steven R. Safra; Simpson, Richard; Borja, Mary; Eiler, Ashley; Jack Scarola; Mary E. Pirrotta;
Edward & Cassell v. Dershowitz CACE 15-000072 (05)
Wednesday, November 04, 2015 11:22:42 AM
Good morning,
I am advising of Judge Lynch's rulings on the above referenced case. His rulings are
as follows:
von Party's motion to quasn
von party fam firmn Boies schiller:or pre sutive ena, as to the laws uim, is a uasieedo
As to the "Jane Doe #3" subpoena: The motion is granted as to request #9, 17,
18, 20 and 23.
The motion is denied as to the other requests, but a confidentiality order shall be
entered.
Regarding the deposition: The depo shall be limited to 4 hours without prejudice to
request additional time in the future.
The Defendant can be present at the depo.
The depo will be taken at the law firm representing the witness.
There shall be a special master, paid by the Defendant, present at the depo, to rule
on objections.
The depo will be limited to the issues of this case without prejudice for another
depo, if required, in the future.
The issues and said limitations will be determined by the special master.
Each attorney who had a motion heard, is to prepare the order on their motion for
the judges signature, along with sufficient copies, self addressed, self stamped
envelopes for all parties.
These orders cannot be submitted through the order portal.
Respectfully,
Susan Moss
Judicial Assistant to Judge Thomas M. Lynch, IV
201 S.E. 6th Street, Rm 920B
Fort Lauderdale, Florida 33301
954-831-7831
HOUSE_OVERSIGHT_015614


EXHIBIT C
HOUSE_OVERSIGHT_015615


IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIVIL DIVISION
CASE NO. CACE 15-000072
BRADLEY J. EDWARDS, and
PAUL G. CASSELL,
Plaintiffs,
V.
ALAN DERSHOWITZ,
Defendant.
ORDER ON BOIES, SCHILLER & FLEXNER LLP AND JANE DOE NO. 3's MOTIONS
TO QUASH SUBPOENAS OR FOR PROTECTIVE ORDER
This Cause comes before the Court on November 2, 2015 upon Boies, Schiller & Flexner
LLP's Motion to Quash Subpoena Or For Protective Order and Jane Doe No. 3's Motion to Quash
Subpoena Or For Protective Order.
Having reviewed the record and being otherwise fully advised, the Court hereby Orders:
1. Non-Party Law Firm Boies, Schiller & Flexner LLP's Motion to Quash Subpoena is
GRANTED. The subpoena to Boies, Schiller & Flexner LLP is quashed in its entirety.
2. Non-Party Jane Doe No. 3's Motion to Quash Subpoena or For Protective Order is
Denied in Part, Granted in part, as follows:
a. The Motion to Quash is Granted as to Requests Nos. 9, 17, 18, 20, and 23. The
Motion is denied as to the remaining Requests.
b. A Confidentiality Order shall be entered.
c. The deposition of Jane Doe No. 3 shall be limited to 4 hours without prejudice
to request for additional time in the future.
d. The deposition will be taken at the law firm representing the witness, Boies,
Schiller & Flexner LLP.
HOUSE_OVERSIGHT_015616


2015.
e. There shall be a special master, paid by the Defendant, present at the
deposition, to rule on objections.
f. The Defendant Alan Dershowitz can be present at the deposition.
g. The deposition will be limited to the issues of this case without prejudice for
another deposition, if required, in the future. The issues and said limitations
will be determined by the special master.
DONE AND ORDERED in Broward County, Florida on this _
day of November,
THON.AS M. LYNCH, IV
NOV 12 213
Honorable Judger thends wynch
Circuit Judge
cc: Counsel of Record
HOUSE_OVERSIGHT_015617


EXHIBIT D
HOUSE_OVERSIGHT_015618


IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIVIL DIVISION
CASE NO. CACE 15-000072
BRADLEY J. EDWARDS, and
PAUL G. CASSELL,
Plaintiffs,
V.
ALAN DERSHOWITZ,
Defendant.
PROPOSEDI CONFIDENTIALITY ORDER
THIS CAUSE COMES before the Court based on its Order dated November 12, 2015
granting, in part, Non-Party Jane Doe No. 3's Motion to Quash Subpoena or for a Protective
Order. This Court ordered that "A Confidentiality Order Shall Be Entered."
Accordingly, having reviewed the record and being otherwise duly advised, the Court
issues the following Confidentiality Order:
1. The deposition testimony of Non-Party Virginia Giuffre will be designated as
"Confidential" and not subject to public disclosure. It may only be filed under seal.
2. Documents produced by Non-Party Virginia Giuffre that are confidential may be
marked as "Confidential" and shall be treated in the same manner as confidential
testimony.
DONE AND ORDERED in Broward County, Florida on this day of January, 2016.
Honorable Judge Thomas Lynch
Circuit Court Judge
ce: Counsel of Record
HOUSE_OVERSIGHT_015619


EXHIBIT E
HOUSE_OVERSIGHT_015620


Filing # 34801581 E-Filed 11/23/2015 05:53:31 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT, IN
AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE 15-000072
BRADLEY J. EDWARDS and PAUL G.
CASSELL,
Plaintiffs,
VS.
ALAN M. DERSHOWITZ,
Defendant.
PLAINTIFFS/COUNTERCLAIM DEFENDANT EDWARDS AND
CASSELL'S RESPONSE TO DERSHOWITZ'S MOTION TO DETERMINE
CONFIDENTIALITY OF COURT RECORDS
Plaintiffs/Counterclaim Defendants Bradley J. Edwards and Paul G. Cassell, by and
through their undersigned
attorneys, hereby file this response to Dershowitz's Motion to
Determine Confidentiality of Court Records. The records at issue are not confidential, and so the
Court should deny Dershowitz's motion in its entirety.
The court records at issue are three court filings by attorneys Edwards and Cassell
in which they recite their client's (Mr. Virginia Giuffre's) allegations that she was sexually
abused by Dershowitz. These records are hardly "confidential" in this defamation case,
where the parties
have claims and counterclaims about these sexual abuse
Allegations. Rather, these records are an important part of this case, since they not only
support the conclusion that Dershowitz abused Ms. Giuffre, but also indisputably establish
Edwards and Cassell's strong basis for filing the allegations on her behalf. Moreover,
contrary to assertions made in Dershowitz's motion, these documents have never been
found to be "confidential" by any other court. And Dershowitz has repeatedly referred to
HOUSE_OVERSIGHT_015621


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 2 of 20
these documents, not only in defamatory statements broadcast worldwide, but also in his
pleadings before this Court and in recent depositions. Indeed, Dershowitz said in his
media interviews that he wants "everything to be made public" and implied that Edwards
and Cassell had something to hide. Accordingly, Dershowitz has failed to carry his heavy
burden to justify sealing these presumptively-public documents.
DERSHOWITZ HAS NOT JUSTIFIED SEALING ALLEGED
DEFAMATORY RECORDS THAT ARE INTEGRAL TO THIS
DEFAMATION CASE.
In his motion, Dershowitz never recounts the heavy burden that he must carry to seal the
records at issue. To be sure, Florida Rule of Judicial Administration 2.420 allows for the sealing
of "confidential" materials. But the Rule begins by recounting the overarching principle that
"[t]he public shall have access to all records of the judicial branch of government, except as
provided below." Fla. R. Jud. Admin. 2.420(a). This rule is a codification of the Florida
Supreme Court's admonition that a "a strong presumption of openness exists for all court
proceedings. A trial is a public event, and the filed records of court proceedings are public
records available for public examination." Barron v. Florida Freedom Newspapers, Inc., 531
So.2d 113, 118 (Fla. 1988) (emphasis added). In light of this presumption of openness, "[the
burden of proof in [closure] proceedings shall always be on the party seeking closure." Id. To
obtain a sealing order, the party seeking sealing must carry a "heavy burden." Id.
Remarkably, Dershowitz fails to acknowledge these well-settled principles. More
important, he even fails to cite (much less discuss) the limited substantive exceptions to this
general
principle of access - and which specific exception he believes
applies to this
HOUSE_OVERSIGHT_015622


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 3 of 20
case. Accordingly, it is impossible for Edwards and Cassell to respond with precision to his
motion.
The exceptions that might arguably be in play in this case permit records to be maintained
as confidential in order to:
(i)
(ii)
(iii)
(iv)
(v)
(vi)
(vii)
Prevent a serious and imminent threat to the fair, impartial, and orderly
administration of justice;
Protect trade secrets;
Protect a compelling governmental interest;
Obtain evidence to determine legal issues in a case;
Avoid substantial injury to innocent third parties;
Avoid substantial injury to a party by disclosure of matters protected by a
common law or privacy right not generally inherent in the specific type of
proceeding sought to be closed;
Comply with established public policy set forth in the Florida or United
States Constitution or statutes or Florida rules or case law ....
Fla. R. Jud. Admin. 2.420(c)(9) (codifying the holding in Barron v.
Florida Freedom
Newspapers, Inc., 531 So.2d 113 (Fla. 1988)). The only exception that seems to even arguably
apply here is exception vi, which itself specifically provides that confidentiality is appropriate
only where disclosure is "not generally inherent in the specific type of proceeding sought to be
closed' (emphasis added). Of course, this lawsuit is a defamation action - involving
a defamation claim
by Edwards
and Cassell
and
a defamation counterclaim
by
Dershowitz. Disclosure, discussion, and debate about the defamatory statements at issue lies at
the heart of the case. Accordingly, disclosure of these materials is "inherent" in the case itself.
The principle that defamatory material in a defamation case cannot be sealed is recognized
in Carnegie v. Tedder, 698 So.2d 1310 (2d DCA 1997). Carnegie involved a claim and
counterclaim between two parties (Carnegie and Tedder), one of whom alleged that disclosure of
HOUSE_OVERSIGHT_015623


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 4 of 20
the
materials
in
records
would
be
harmful
to
his professional
reputation. Carnegie recited subsection vi's restriction on release of materials involving a
privacy right, but noted that "statements Tedder alleged were defamatory and damaging were
allegations
Carnegie's
counterclaim
for
which
she seeks damages.
These matters were not peripheral to the lawsuit; they were inherent to it." Id. at 1312. Of
course,
exactly the same principle applies here: sexual abuse allegations filed by attorneys
Edwards and Cassell for their client Ms. Virginia Giuffre are not peripheral to this lawsuit - they
are inherent to it.
To see how "inherent" the sexual abuse allegations are to this lawsuit, the Court need
look no further than Dershowitz's counterclaim in this case. Count I of Dershowitz's
Counterclaim (styled as "False Allegations in the Joinder Motion") contends that Edwards and
Cassell should pay him damages because they "filed a pleading in the Federal Action titled 'Jane
Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in Action' ... " Dershowitz
Counterclaim at 1 14. Dershowitz's Counterclaim then goes on to quote at length from the
Joinder Motion.
His counterclaim contains, for example, this paragraph recounting the
allegations:
The Joinder Motion then goes on to allege - without any supporting evidence - as
follows:
One such powerful individual that Epstein forced then-minor Jane Doe #3 to
have sexual relations with
was former Harvard Law Professor Alan
Dershowitz, a close friend of Epstein's and well-known criminal defense
attorney. Epstein required Jane Doe #3 to have sexual relations with
Dershowitz on numerous occasions while she was a minor, not only in Florida
but also on private planes, in New York, New Mexico, and the U.S. Virgin
HOUSE_OVERSIGHT_015624


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 5 of 20
Islands. In addition to being a participant in the abuse of Jane Doe #3 and other
minors, Dershowitz was an eye-witness to the sexual abuse of many other
minors by Epstein and several of Epstein's coconspirators. Dershowitz would
later play a significant role in negotiating the [Non-Prosecution Agreement] on
Epstein's behalf. Indeed, Dershowitz helped negotiate an agreement that
provided immunity from federal prosecution in the Southern District of Florida
not only to Epstein, but also to "any potential coconspirators of Epstein." Thus,
Dershowitz helped negotiate an agreement with a provision that provided
protection for himself against criminal prosecution in Florida for sexually
abusing Jane Doe #3. Because this broad immunity wouldhave been
controversial if disclosed, Dershowitz (along with other members of Epstein's
defense team) and the Government tried to keep the immunity provision secret
from all of Epstein's victims and the general public, even though such secrecy
violated the Crime Victims' Rights Act.
Dershowitz Counterclaim at I 15 (quoting Joinder Motion at 4).
Remarkably, having quoted at length from the Joinder Motion in his Counterclaim in this
case, Dershowitz now seeks to have that very same language from the Joinder Motion deemed
"confidential" and sealed. Compare Counterclaim at 915 (block quotation above) with Motion to
Determine Confidentiality, Exhibit A at 4 (composite exhibit with proposed "confidential"
document that includes paragraph beginning "[o]ne such powerful individual that Epstein forced
then-minor Jane Doe #3 to have sexual relations with was former Harvard Law Professor Alan
Dershowitz, a close friend of Epstein's . ..."). Dershowitz cannot come before this Court and
file a counterclaim seeking damages from Edwards and Cassell for alleged defamatory
statements
and then
ask to
have those
very
same statements placed under
seal as
"confidential." See Barron v. Florida Freedom Newspapers, 531 So.2d at 119 ("although
generally protected by one's privacy right, medical reports and history are no longer protected
HOUSE_OVERSIGHT_015625


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 6 of 20
when the medical condition becomes an integral part of the civil proceeding, particularly when
the condition is asserted as an issue by the party seeking closure" (emphasis added)).
II.
JUDGE MARRA'S ORDER IN HIS CASE DOES NOT REQUIRE THAT
THE RECORDS BE SEALED IN THIS CASE.
Dershowitz also appears to contend that Judge Marra's order striking some of the
materials from the records at issue somehow requires that these stricken materials be kept
confidential in this case. Dershowitz's argument misunderstands both the scope of Judge
Marra's order and its effect in this case. His argument rests on a truncated - and misleading --
description of the events surrounding Judge Marra's ruling striking certain documents.
A more
complete description makes clear that Judge Marra has not determined the documents are
somehow "confidential" even in the federal Crime Victims' Rights Act case - much less in this
separate state defamation action.
Edwards and Cassell filed the federal case pro bono on behalf of two young women who
were sexually abused as underage girls by Dershowitz's close personal friend - Jeffrey
Epstein. In 2008, Edwards and Casell filed a petition to enforce the rights of "Jane Doe No. 1"
and "Jane Doe No. 2" under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, alleging
that the Government had failed to provide them rights with regard to a plea arrangement it was
pursuing with Epstein. Jane Doe No. 1 and Jane Doe No. 2 v. United States, No. 9:08-cv-80736
(S.D. Fla.). In the course of that case, on October 11, 2011, the victims filed discovery requests
with the Government, including requests specifically seeking information about Dershowitz,
Prince Andrew, and others.
Further efforts from the Government to avoid any discovery
HOUSE_OVERSIGHT_015626


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 7 of 20
followed (see generally Docket Entry or "DE" 225-1 at 4-5), ultimately leading to a further
Court ruling in June 2013 that the Government should produce documents. DE 189. The
Government then produced about 1,500 pages of largely irrelevant materials to the victims (DE
225-1 at 5), while simultaneously submitting 14,825 pages of relevant materials under seal to the
Court. The Government claimed that these pages were "privileged" for various reasons,
attaching an abbreviated privilege log.
While these discovery issues were pending, in the summer of 2014, Edwards and Cassell,
contacted Government counsel to request their agreement to add two additional victims to the
case, including Ms. Virginia Giuffre (who was identified in court pleadings as "Jane Doe No.
3"). Edwards and Cassell sought to have her added to the case via stipulation, which would have
avoided the need to include any detailed facts about her abuse. Weeks went by and the
Government - as it had done on a similar request for a stipulation to add another victim - did not
respond to counsel's request for a stipulation. Finally, on December 10, 2014, despite having
had four months to provide a position, the Government responded by email to counsel that it was
seeking more time, indicating that the Government understood that victims' counsel might need
to file a motion with the court on the matter immediately. DE 291 at 3-5. Rather than file a
motion immediately, victims' counsel waited and continued to press the Government for a
stipulation. See id. at 5. Finally, on December 23, 2014 - more than four months after the initial
request for a stipulated joinder into the case - the Government tersely indicated its objection,
without indicating any reason: "Our position is that we oppose adding new petitioners at this
stage of the litigation." See DE 291 at 5.
HOUSE_OVERSIGHT_015627


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 8 of 20
Because the Government
now contested the joinder motion, Edwards and
Cassell prepared a more detailed pleading explaining the justification for granting the
motion. One week after receiving the Government's objection, on December 30, 2014, Ms.
Giuffre (i.e., Jane Doe No. 3) and Jane Doe No. 4 filed a motion (and later a corrected motion)
seeking to join the case. DE 279 and DE 280. (Note: DE 280 is the first of the three documents
Dershowitz seeks to have declared "confidential" in this case.) Uncertain as to the basis for the
Government's objection, the motion briefly proffered the circumstances that would qualify
the two women as "victims" eligible to assert rights under the CVRA. See 18 U.S.C. 3771(e)
(defining "crime victim" protected under the Act). With regard to Ms. Giuffre, the motion
indicated that when she was a minor, Jeffrey Epstein had trafficked her to Dershowitz and Prince
Andrew (among others) for sexual purposes. Jane Doe No. 3 stated that she was prepared to
prove her proffer. See DE 280 at 3 ("If allowed to join this action, Jane Doe No. 3 would prove
the following...
"). The motion also provided specific reasons why Jane Doe No. 3's
participation was relevant to the case, including the pending discovery issues regarding
Dershowitz and Prince Andrew. DE 280 at 9-10 (explaining several reasons participation of new
victims was relevant to existing issues).
After the motion was
filed, various news organizations published articles about
it. Dershowitz also made numerous media statements about the filing, including calling Jane
Doe No. 3 "a
serial
liar" who
"has
lied through her
teeth
about many world
leaders."
http://www.cnn.com/2015/01/06/us/dershowitz-sex-allegation/. Dershowitz
also
repeatedly called Edwards and Cassell "two sleazy, unprofessional, disbarable lawyers." Id. On
HOUSE_OVERSIGHT_015628


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 9 of 20
January 5, 2015, Dershowitz filed a motion to intervene to argue to have the allegations
stricken. DE 282. Dershowitz also argued that Ms. Giuffre had not provided a sworn affidavit
attesting to the truth of her allegations. On January 21, 2015, Edwards and Cassell filed a
response for Ms. Giuffre and Jane Doe No. 4. DE 291. (Note: This is the second of the three
documents Dershowitz seeks to have kept under seal here.) The response enumerated nine
specific reasons why Ms. Giuffre's specific allegations against Dershowitz were relevant to the
case, including the fact that Ms. Giuffre needed to establish that she was a "victim" in the case,
that pending discovery requests concerning Dershowitz-specific documents were pending, and
that Dershowitz's role as a defense attorney in the case was highly relevant to the motive for the
Government and defense counsel to conceal the plea deal from the victims. DE 291 at 17-26 &
n.17. The response included a detailed affidavit from Ms. Giuffre about the sexual abuse she had
suffered from Epstein, Dershowitz, and other powerful persons. DE 291-1. On February 6,
2015, Edwards and Cassell filed a further pleading (and affidavit from Ms. Giuffre, see DE 291-
1) in support of her motion to intervene. (Note: this affidavit is the third of the three documents
Dershowitz seeks to have declared confidential.)
On April 7, 2015, Judge Marra denied Ms. Giuffre's motion to join the case. Judge
Marra concluded that "at this juncture in the proceedings" details about the sexual abuse she had
suffered was unnecessary to making a determination "of whether Jane Doe 3 and Jane Doe 4
should be permitted to join [the other victims'] claim that the Government violated their rights
under the CVRA. The factual details regarding with whom and where the Jane Does engaged in
sexual activities are impertinent to this central claim (i.e., that they were known victims of Mr.
HOUSE_OVERSIGHT_015629


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 10 of 20
Epstein and the Government owed them CVRA duties), especially considering that the details
involve non-parties who are not related to the respondent Government." DE 324 at 5 (emphasis
in original). While Judge Marra struck those allegations, he emphasized that "Jane Doe 3 is free
reassert these factual details through proper evidentiary proof, should [the victims]
demonstrate a good faith basis for believing that such details are pertinent to a matter presented
for the Court's consideration. Judge Marra then denied Ms. Giuffre's motion to join the case,
but allowed her to participate as trial witness: "The necessary "participation' of [Ms. Giuffre] ..
in this case can be satisfied by offering ... properly supported - and relevant, admissible, and
non-cumulative - testimony as needed, whether through testimony at trial ... or affidavits
supported in support [of] the relevancy of discovery requests." DE 324 at 8 (emphasis
deleted). In a supplemental order, Judge Marra stated that the victims "may re-refile these
documents omitting the stricken portions." DE 325. The victims have recently refiled the
documents.
In light of this history, Dershowitz is flatly incorrect when he asserts that "Judge Marra's
Order appropriately precludes the unredacted documents from being re-filed in this case on the
public docket." Confidentiality Motion at 3. To the contrary, the Order specifically permits
factual details about Dershowitz's sexual abuse of Ms. Giuffre to be presented in regard to
pertinent matters in the federal CVRA case. And certainly nothing in Judge Marra's Order could
render those documents confidential in this state defamation case, where the central issues swirl
around Edwards and Cassell's good faith basis for filing the allegations. Indeed, the order is not
binding in any way in this case, because it is res judicata only as to Ms. Giuffre (the moving
HOUSE_OVERSIGHT_015630


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 11 of 20
party in that case), not as to her attorneys Edwards and Cassell. See Palm AFC Holdings, Inc. v.
Palm Beach County, 807 So.2d 703 (4th DCA 2002) ("In order for res judicata to apply four
identities must be present: (1) identity of the thing sued for; (2) identity of the cause of action;
(3) identity of persons and parties; and (4) identity of the quality or capacity of the persons for or
against whom the claim is made.").
III.
EDWARDS AND CASSELL WILL BE PREJUDICED IF THEY ARE
BARRED FROM QUOTING FROM THE RECORD WHILE
DERSHOWITZ IS PERMITTED TO FREELY REFER TO THEM
WHENEVER HE FINDS IT CONVENIENT.
Dershowitz is also incorrect when he asserts that no prejudice will befall Edwards and
Cassell if the records are placed under seal. To the contrary, placing the documents under seal
would permit Dershowitz to continue to misrepresent and distort what is contained in those
records while preventing Edwards and Cassell from correcting those misrepresentations.
Dershowitz has repeatedly referred to details in the records when he has found it convenient to
do so - treating the records as not confidential in any away. One clear example comes from
Dershowitz's recent deposition, where he gratuitously injected into the record a reference to a
portion of Ms.
Giuffre's affidavit about him watching Ms. Giuffre perform oral sex on
Epstein. And then, having injected that gratuitous reference into the record, he proceeded to try
to rebut the reference with confidential settlement discussions - but did so by mispresenting what
another attorney (David Boies) had said during the settlement discussions. So that the Court may
have the full flavor of the exchange, the narrow question to Dershowitz (by attorney Jack
HOUSE_OVERSIGHT_015631


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 12 of 20
Scarola) and Dershowitz's extended answer are quoted in full- including
Dershowitz's
reference to the oral sex allegation that he now argues this Court should treat as "confidential":
Q.
[You [are] aware that years before December of 2014, when the
CVRA pleading was filed, that your name had come up repeatedly in
connection with Jeffrey Epstein's abuse of minors, correct? ...
A.
Let me answer that question. I am aware that never before 2014,
end of December, was it ever, ever alleged that I had acted in any
way inappropriately with regard to Virginia [Giuffre], that I ever
touched her, that I ever met her, that Ihad ever been with her. I was
completely
aware of that.
There had
never
been
any
allegation. She claims under oath that she told you that secretly in
2011, but you have produced no notes of any such conversation.
You, of course, are a witness to this allegation and will be deposed
as a witness to this allegation. I believe it is an entirely false
allegation that she told you in 2011 that she had had any sexual
contact with me. I think she's lying through her teeth when she
says that. And I doubt that your notes will reveal any such
information.
But if she did tell you that, she would be absolutely, categorically
lying. So I am completely aware that never, until the lies were put
in a legal pleading at the end of December 2014, it was
never alleged that I had any sexual contact with Virginia Roberts.
I know that it was alleged that I was a witness to Jeffrey Epstein's
alleged abuse and that was false. I was never a witness to any of
Jeffrey Epstein's sexual abuse. And I wrote that to you, something
that you have falsely denied. And I stand on the record. The record
is clear that I have categorically denied I was ever a witness to
any abuse, that I ever saw Jeffrey Epstein abusing anybody.
And -- and the very idea that I would stand and talk to Jeffrey
Epstein while he was receiving oral sex from Virginia Roberts,
which she swore to under oath, is so outrageous, so preposterous,
that even David Boies said he couldn't believe it was true.
MS. McCAWLEY: I object. I object. I'm not going to allow you to reveal
any conversations that happened in the context of a settlement discussion.
THE WITNESS: Does she have standing?
HOUSE
_OVERSIGHT_015632


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 13 of 20
MS. McCAWLEY: I have a standing objection and, I'm objecting again. I'm
not going to
THE WITNESS: No, no, no. Does she have standing in this deposition?
MR. SCOTT: Let's take a break for a minute, okay?
THE WITNESS: I'm not sure she has standing.
MR. SCAROLA: Are we finished with the speech?
MR. SCOTT: No. If he --
MR. SCAROLA: I'd like him to finish the speech so that we can get to my
question
and then we can take a break.
A. So the question -- the answer to your question is --
MR. SIMPSON: Wait a minute. Wait a minute. Wait a minute. Please don't
disclose something that she has a right to raise that objection if she wants to.
MR. SCOTT: Exactly.
Deposition of Alan Dershowitz (Oct. 15, 2015) at 93-95 (attached as Exhibit 1); see
also Deposition of Alan Dershowitz (Oct. 16, 2016) (attached as Exhibit 2) (also containing
discussion of Ms. Giuffre's affidavit).
The Court should be aware that within approximately two hours of this exchange, Ms.
McCawley (David Boies' law partner) released a
statement on his behalf, which stated that
Dershowitz was misrepresenting what happened: "Because the discussions that Mr. Boies had
with Mr. Dershowitz were expressly privileged settlement discussions, Mr. Boies will not, at
least at this time, describe what was actually said. However, Mr. Boies does state that Mr.
HOUSE_OVERSIGHT_015633


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 14 of 20
Dershowitz description of what was said is not true." Statement of Ms. McCawley on Behalf of
David Boies (Oct. 15, 2015).
More broadly, the Court can readily see from this passage how Dershowitz is willing to
inject into the record a part of Ms. Giuffre's affidavit whenever it serves his purpose - and,
indeed, to characterize the part of the affidavit as "preposterous." But then he asks this Court to
place the underlying affidavit under seal, so that the Edwards and Cassell stand accused having
filed a "preposterous" affidavit without anyone being able to assess the validity of Dershowitz's
attack.
Dershowitz has referred to the court records that he now wishes to have the Court declare
confidential not only in his deposition, but also in his widely-broadcast media attacks on
Edwards and Cassell. For example, Dershowitz appeared on the British Broadcasting
Corporation (the BBC) and was asked about the allegations:
Well, first of all they were made in court papers that they don't even ask for a hearing
Tom any consequen. Theo ma deanin cons a tre story is to my maze themselves
up, completely out of whole cloth.
I don't know this woman. I was not at the places at the times. It is part of a pattern of
made up stories against prominent people and world leaders. And the lawyers in
recent statement challenged me to deny the allegations under oath. I am doing that. I
am denying them under oath, thus subjecting me to a perjury prosecution were I not
telling the truth. I am now challenging them to have their client put these charges
under oath and for them to put them under oath. I am also challenging them to repeat
them outside of the context of court papers so that I can sue them for defamation. ...
And I will prove beyond any doubt not only that the story is totally false, but it was
knowingly false: that the lawyers and the client conspired together to create a false
story. That is why I am moving for their disbarment in challenges to be provided to
the disciplinary committee.
BBC Radio 4 - Sarah Montague (Jan. 3, 2015) (http://www.bbc.co.uk/programmes/p02g7qbc).
HOUSE_OVERSIGHT_015634


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 15 of 20
Similarly, Dershowitz appeared on NBC's Today Show the morning after Edwards and
Cassell made a filing for Ms. Giuffre, to say that the Edwards and Cassell - and Ms. Giuffre -
were all "lying" in the court documents:
Question from Savannah Guthrie: In legal papers from the lawyers, they say you've
had, in fact, the opportunity to be deposed.
Answer from Alan Dershowitz: They're lying.
They're lying.
Question: They show letters in which they offered to depose you.
Answer: And they didn't show my letters in response saying, (a), if you ask me about
my legal relationship with Epstein and I'll be happy to answer. ... And I responded
that I would be happy to be deposed if you could give me any indication that I would
be a relevant witness. ... They will be proved - all of them [i.e., Cassell, Edwards,
and Ms. Giuffre] - to be categorically lying and making up this story. And it will be a
terrible thing for rape victims. ... We [Epstein and Dershowitz] had an academic
relationship. I was never in the presence of a single, young, underaged
woman. When I was with him, it was with prominent scientists, prominent
academics. And they're just - again - lying about this. I never saw him doing
anything improper. I was not a participant. I was not a witness.
Today Show, Jan. 22, 2015 (emphases added).
As another example, in Miami Herald, Dershowitz called the Joinder Motion that he
seeks
to have sealed "the sleaziest legal documentI have ever seen. They [Edwards and
Cassell] manipulated a young, suggestible woman who was interested in money. This is a
disbarrable offense, and they will be disbarred. They will rue the day they ever made this false
charge against me" - i.e., Edwards and Cassell will "rue the day" they ever filed the Joinder
Motion. Miami Herald (Jan. 3, 2015).
HOUSE_OVERSIGHT_015635


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 16 of 20
Most remarkably, Dershowitz took the public airwaves to represent that he wanted all of
the information surrounding the allegations to "be made public," while implying that Edwards
and Cassell had something
hide. For example, on the BBC he claimed that he
wanted" everything to be made public":
Q: Would you encourage that it now be made public?
A: Of course, of course. I want everything to be made public. I want
every bit of evidence in this case to be made public. I want every
allegation to be made public. I want to know who else she's accused of
these horrible crimes.
We know that she accused Bill Clinton of being on
Jeffrey Epstein's island and participating in sex orgy with underage
girls. The records of the Secret Service will prove that President Clinton
never set foot on that island. So that she lied. Now it's possible to have a
case of mistaken identification with somebody like me. It's impossible to
have a case of mistaken identification with Bill Clinton.
My only feeling is that if she has lied about me, which I know to an
absolute certainty she has, she should not be believed about anyone
else. She's lied clearly about me, she's lied clearly about Bill
Clinton. We know that. We know that she's lied about other public
figures, including a former prime minister and others who she claims to
have participated in sexual activities with. So I think it must be presumed
that all of her allegations against Prince Andrew are false as well.
I think he [Prince Andrew] should clear the air as well.
If you're squeaky clean and if you have never done anything like this, you
must fight back with all the resources available to you. And that's what I
will do. I will not rest or stop until the world understands no only that I
had nothing to do with any of this, but that she deliberately, with the
connivance of her lawyer, lawyers, made up this story willfully and
knowingly.
BBC Radio 4 - Sarah Montague (Jan. 3, 2015) (http://www.bbc.co.uk/programmes/p02g7qbc).
In another widely-broadcast interview on CNN, Dershowitz implied that there is no
evidence supporting the allegations against him:
HOUSE_OVERSIGHT_015636


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 17 of 20
Ask them [Edwards and Cassell] if they have any evidence . ... They're doing it for
money. She's getting money for having sold her story. She wants to sell the book.
They're trying to get into this lawsuit. They see a pot of gold at the end of the
rainbow. They're [Edwards and Cassell] prepared to lie, cheat, and steal. These are
unethical lawyers. This is Professor Cassell who shouldn't be allowed near a
student. This is Professor Cassell, who is a former federal judge, thank God he no
longer wears a robe. He is essentially a crook. He is essentially somebody who's
distorted the legal profession. . . .
Why would he charge a person with a
sterling reputation for 50 years on the basis of the word alone of a woman who is
serial liar, who has lied about former Prime Ministers, former Presidents, has lied
demonstrably.
CNN Live (with Hala Gorani) (January 5, 2015). Of course, by placing "the evidence" in this
case under seal, Dershowitz will be free to continue to try and insinuate that Edward and Cassell
- and their client, Ms. Giuffre - had no evidence supporting the allegations against him, even
though a mountain evidence strongly support Ms. Giuffre's allegations. See Deposition of Paul
Cassell (Oct. 16, 2015) at 61-117 (Exhibit 3); see also Depo of Pual Cassell (Oct. 17, 2015)
(Exhibit 4).
CONCLUSION
The Court should deny Defendant/Counterclaim Plaintiff Alan Dershowitz's motion to
place documents regarding Ms. Giuffre's allegations against him under seal.
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
to all Counsel on the attached list, this
23r0
day of November, 2015.
/s/ Jack Scarola
Jack Scarola
Florida Bar No.: 169440
Attorney E-Mails): jsx@searcylaw.com and
mep@searcylaw.com
Primary E-Mail: _scarolateam@searcylaw.com
Searcy Denney Scarola Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone: (561) 686-6300
Fax: (561) 383-9451
HOUSE_OVERSIGHT_015637


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 18 of 20
SEAN D. REYES
Utah Attorney General
By: JONI J. JONES
JOEL A. FERRE
Assistant Utah Attorneys General
Bradley J. Edwards
FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Telephone (954) 524-2820
Facsimile (954) 524-2822
E-mail: brad@pathtojustice.com
And
Paul G. Cassell
Pro Hac Vice Motion Pending
S.J. Quinney College of Law at the
University of Utah
383 S. University St.
Salt Lake City, UT 84112
Telephone:801-585-5202
Facsimile: 801-585-6833
E-Mail:cassellp@law.utah.edu
Attorneys for Plaintiffs Bradley J. Edwards and Paul G. Cassell
COUNSEL LIST
Thomas Emerson Scott, Jr., Esquire
Thomas.scott@csklegal.com; Steven.safra@csklegal.com
Cole Scott & Kissane P.A.
9150 S Dadeland Boulevard, Suite 1400
Miami, FL 33156
HOUSE_OVERSIGHT_015638


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 19 of 20
Phone: (305)-350-5329
Fax: (305)-373-2294
Attorneys for Defendant
Richard A. Simpson (pro hac vice)
rsimpson@wileyrein.com
Mary E. Borja (pro hac vice)
mborja@wileyrein.com
Ashley E. Eiler (pro hac vice)
aeiler@wileyrein.com
WILEY REIN LLP
1776 K St. NW
Washington, DC 20006
Phone: (202) 719-7000
Fax: (202) 719-7049
HOUSE_OVERSIGHT_015639


Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 20 of 20
COUNSEL LIST
Sigrid Stone McCawley, Esquire
smccawley@bsfllp.com;
sperkins@bsfllp.com; ftleserve@bsfllp.com
Boies Schiller & Flexner, LLP
401 E Las Olas Boulevard., Suite 1200
Fort Lauderdale, FL 33301
Phone: (954)-356-0011
Attorneys for Alan M.Dershowitz, Esquire
Thomas Emerson Scott, Jr., Esquire
Thomas.scott@csklegal.com;
Steven.safra@csklegal.com;
Renee.nail@csklegal.com;
shelly.zambo@csklegal.com
Cole Scott & Kissane P.A.
9150 S Dadeland Boulevard, Suite 1400
Miami, FL 33156
Phone: (305)-350-5329/Fax: (305)-373-2294
Attorneys for Alan M.Dershowitz, Esquire
Bradley J. Edwards, Esquire
staff.efile@pathtojustice.com;
brad@pathtojustice.com;
maria@pathtojustice.com
Farmer Jaffe Weissing Edwards Fistos &
Lehrman, P.L.
425 N Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301
Phone: (954)-524-2820/Fax: (954)-524-2822
Attorneys for Alan M.Dershowitz, Esquire
Kenneth A. Sweder, Esquire
ksweder@sweder-ross.com
Sweder & Ross, LLP
131 Oliver Street
Boston, MA 02110
Phone: (617)-646-4466/Fax: (617)-646-4470
Attorneys for Alan M.Dershowitz, Esquire
Ashley Eiler, Esquire
AEller@wileyrein.com
Mary E. Borja, Esquire
MBorja@wileyrein.com
Richard A. Simpson, Esquire
RSimpson@wileyrein.com
Wiley Rein, LLP
1776 K Street NW
Washington, DC 20006
Phone: (202)-719-4252/Fax: (202)-719-7049
Attorneys for Alan M.Dershowitz, Esquire
Joni J. Jones, Esquire
jonijones@utah.gov
Assistant Utah Attorney General
160 E 300 S
Salt Lake City, UT 84114
Phone: (801)-366-0100/Fax: (801)-366-0101
Attorneys for Paul Cassell
HOUSE_OVERSIGHT_015640


EXHIBIT F
UNDER SEAL
HOUSE_OVERSIGHT_015641


EXHIBIT G
HOUSE_OVERSIGHT_015642


12/8/2015
Prince Andrew and girl, 17, who sex offender friend flew to Britain to meet him | Daily Mail Online
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CUTS OFF Donald
Vacuous
sloganeering,
Prince Andrew and the 17-year-old girl his
sex offender friend flew to Britain to meet
him
By SHARON CHURCHER
UPDATED: 08:02 EST, 2 March 2011
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•101
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• Virginia Roberts reveals she is 'Jane Doe 102' in Jeffrey Epstein case
• Mother-of-three spent four years as millionaire's personal masseuse
• She describes being flown across world to meet Prince Andrew
• Epstein trained her 'as a prostitute for him and his friends'
As the UK's special representative for international trade, the Duke of York holds an important
position, requiring sound judgement and widespread respect.
But those qualities have been thrown into question since photographs of Prince Andrew with his
billionaire financier friend Jeffrey Epstein, a convicted child-sex offender who was jailed for 18
months for soliciting underage prostitutes, appeared last weekend.
Today, however, even more serious doubts are cast on his suitability after a woman at the centre of
the Epstein case revealed to The Mail on Sunday that she had, as a 17-year-old employed by
Epstein, been flown across the world to be introduced to the Prince.
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HOUSE_OVERSIGHT_015643


12/8/2015
Prince Andrew and girl, 17, who sex offender friend flew to Britain to meet him | Daily Mail Online
• announce they are
expecting a baby boy -
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baby Maxima as he
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Famed for Sister, Sister
First meeting: Prince Andrew puts his arms around 17-year-old Virginia, centre
On one of those occasions Virginia Roberts was subsequently paid $15,000 (£9,400). Her shocking
account of her four years as Epstein's personal masseuse is supported by court documents, an
eyewitness, photographs and flight details of Epstein's private jets.
One picture, said to have been taken by Epstein during Andrew's first encounter with the girl in
March 2001 and published today by The Mail on Sunday, shows the Prince with his arm around her
waist.
This is not the first time the Duke of York's judgment and choice of associates have been
questioned. He appears to relish the company of super-rich oil billionaires from the Middle East,
North Africa and the former Soviet Union.
The peculiar sale of his former marital home to a Kazakh businessman for £15 million after it had
languished unsold for five years at £12 million has never been satisfactorily explained.
In the recent leak of American diplomatic cables it was revealed that he had criticised an official
corruption investigation into the huge Al-Yamamah arms deal between Britain and Saudi Arabia,
while he is also said to be close to Saif Al-Islam Gaddafi, son of the beleaguered Libyan president,
and may have had a role in the early release of Lockerbie bomber Abdelbaset Al Megrahi.
But it is Andrew's friendship with Epstein, whom
he has known since at least 2000, and with
While on the streets, I
Epstein's confidante Ghislaine Maxwell, daughter slept with men for
of the late disgraced newspaper baron Robert
Maxwell, that gives most concern.
He was first seen with the pair on holiday in
money. I was a
Thailand, and was pictured cavorting with
paedophile's dream
Ghislaine at a Halloween fetishthemed party in
Manhattan.
The photograph that appeared last weekend shows the prince strolling through Central Park with
58-year-old Epstein. Andrew was said to have spent four days at his New York mansion in
December, when he was joined by other distinguished guests, including Woody Allen, at a dinner.
It is by no means the first New York soiree Andrew has attended as Epstein's guest.
A lengthy profile of the financier in Vanity Fair magazine some years ago reported that Andrew was
a guest at a cocktail party thrown by Epstein and Maxwell packed with young Russian models.
Some guests were horrified,' said the article's author, Vicky Ward.
It should not be forgotten that Epstein is a registered sex offender after recently completing his
sentence for offences relating to child prostitution.
http://www.dailymail.co.uk/news/article-1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him.html
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HOUSE_OVERSIGHT_015644


12/8/2015
Prince Andrew and girl, 17, who sex offender friend flew to Britain to meet him | Daily Mail Online
However, he avoided trial on more serious charges that carried a potential life sentence. And no one
• singing Christmas
reading The Mail on Sunday's interview with the woman who was prepared to testify against him can
song... as she reveals
be in any doubt of the seriousness of the charges.
remarkably slim post-
baby body
Epstein, a Wall Street money manager who once counted Bill Clinton and Donald Trump among his
friends, became the subject of an undercover investigation in 2005 after the stepmother of a 14-year
old girl claimed she was paid $200 (£125) to give him an 'erotic massage'.
The subsequent FBI probe uncovered at least 20 girls levelling sexual allegations against him.
Eventually, Epstein struck a 'plea bargain' with prosecutors - a practice not permitted under British
law - under which he was allowed to plead guilty to two relatively minor charges.
Police claim that his donations to politicians and his 'dream team' of influential lawyers deterred
prosecutors from bringing more serious charges of sex-trafficking. The deal certainly kept the names
of a lot of Epstein's famous friends out of an embarrassing court case.
However, an unusual part of the agreement was that Epstein's alleged victims were allowed to bring
civil proceedings against him.
He has so far made 17 out-of-court settlements, and some cases are ongoing. One of these girls
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was to have been a key witness for the prosecution had the case gone to trial. She was just 15
years old when she was drawn into Epstein's exploitative world in 1998.
In her civil writ against him, under the pseudonym Jane Doe 102' she alleged that her duties
included being 'sexually exploited by Epstein's adult male peers including royalty'.
Now, horrified by the evidence of Epstein and
Andrew enjoying each other's company in New
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After 19 years together
York, Jane Doe 102 has agreed to waive her
anonymity and tell for the first time her deeply
disturbing story.
Her real name is Virginia Roberts and she now
lives in Australia, where she is a happily married
mother of three.
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Over the course of a week during which she
spoke at length to The Mail on Sunday, she
appeared sometimes vulnerable, and
sometimes steely, but always quietly resolute
and consistent.
Revisiting events from a past that she had
hoped she had left behind, Virginia occasionally
buried her face in her hands.
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Some recollections - and, for reasons of taste,
not all the details can be included here - caused
her to flush with shame. I'm telling you things
that even my husband didn't know,' she said.
Virginia, who has undergone counselling to try
to come to terms with her past, is honest about
'I wouldn't have put me
on the show either': Gigi
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'shaking' during
unsuccessful first
Victoria's Secret
audition
her initiation into Epstein's depraved world.
She was a troubled teenager, whose slender
figure, delicate complexion, hesitant voice and
soulful blue eyes made her look young for her
years.
Born in Sacramento, California, in August 1983,
• Who's that boy? Kate
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The 36-year-old has
been playing the field
Virginia spent her early years on a small ranch
on the West Coast of America.
This seemingly idyllic childhood ended when she
was sexually molested by a man close to her
family.
The fallout from that led to her parents
temporarily splitting up. Blaming herself, Virginia
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began to get into trouble Aged 11, she was sent
to live with an aunt but repeatedly ran away.
Living on the streets, she was beaten up and
slept with at least two older men in return for
food. 'I was a paedophile's dream, she says.
Three years later, she was reunited with her
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she jets out of London
'on her way to visit baby
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Off to meet her nephew
family and started a new life with her father who
had moved to Palm Beach,
Florida, where he was maintenance manager at
Donald Trump's country club, Mar-a-Lago.
Virginia got a part-time job as a changing room
assistant -which is where, soon after her 15th
birthday, she met Ghislaine Maxwell, who invited
A new life: Virgina, now a mother-of-three, in
Australia
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her to work as Epstein's personal masseuse.
I was wearing my uniform - a white miniskirt
and a skin-tight white polo top - when I was approached by Ghislaine, Virginia says.
'I told her I wanted to become a masseuse and she said she worked for a very wealthy gentleman
who was looking for a travelling masseuse.
I'd get training and be paid well. 'Virginia's father gave his blessing, believing his daughter was being
handed the opportunity to learn a skill and to work for a wealthy and respectable employer.
He drove her to Epstein's pink mansion on the Palm Beach waterfront - he also owns a nine-storey
home in New York, the city's biggest private residence; a 7,500-acre ranch called 'Zorro' in New
Mexico and Little Saint James, a private 70- acre atoll in the US Virgin Islands.
Virginia says: 'Ghislaine said I was to start immediately and that someone would drive me home.
http://www.dailymail.co.uk/news/article-1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him.html
3/29
HOUSE_OVERSIGHT_015645


12/8/2015
Prince Andrew and girl, 17, who sex offender friend flew to Britain to meet him | Daily Mail Online
My father left and I was told to go upstairs.' She was led by another woman through Epstein's
bedroom into a massage room where he lay face down naked on a table.
He started to interviewed Virginia. This was unconventional, but Virginia had no suspicions.
Presumably, she thought, this was how the wealthy conducted their business.
Epstein elicited the information that Virginia had been a runaway, and was no longer a virgin.
Virginia was then told to start massaging Epstein, under the instructions of the woman who had
shown her in. The massage quickly developed into a sexual encounter.
Virginia was uncomfortable, but reluctant to deny such important people. 'My face was red with
embarrassment, she says. 'But I felt under immense pressure to please them.
The whole time it was going on, they were promising me the world, that I'd travel with Jeffrey on his
private jet and have a well-paid profession.' Afterwards, she was given two $100 bills and told to
return the next day.
That was the beginning of the four years she spent with Epstein.
For three of those years, she was under Florida's age of consent, which is 18.
Troubled teenager: Virginia on the billionaire's Zorro ranch in New Mexico in 2001
Virginia was fascinated by his life story: the son of a humble New York City parks worker, he was a
teacher before becoming a Wall Street broker and friends with the upper echelons of the political,
financial and academic establishment.
As a confused teenager, Virginia easily fell into the practice of sexually gratifying him for money.
He guaranteed her a minimum of $200 each time she gave him what he called an 'erotic massage.'
Virginia said: 'I would always receive the money immediately. He would give me the cash from a wad
he carried in a black duffel bag or an assistant paid me.
'And, because of the way Epstein had warped her sensibilities, every time she took the cash,
Virginia felt even more indebted to him. Secretly, he was also preparing her for an even more
disturbing role.
'Basically, I was training to be a prostitute for him
and his friends who shared his interest in young
Epstein had trained me
girls,' she says: 'After about two years, he started
to ask me to "entertain" his friends.'
to do whatever men
It started when Epstein called Virginia at the Palm Wanted. I told myself I
Beach apartment he had rented for her.
She recalls: 'He said, "I've got a good friend and I
was special
need you to fly to the island to
entertain him, massage him and make him feel how you make me feel."
He didn't spell out what I had to do. He didn't have to. 'He'd trained me to do whatever a man
wanted. I was shocked but I told myself he was sharing me around because he trusted me and I was
special.
I was worried, but I would do anything to keep Jeffrey happy and to keep my place as his number
one girl.
He would keep telling me how lucky I was with the life I was leading and the money I was making. It
was easy to fall into his grasp.
The way it usually worked was l'd be sent to meet a man on the private island Jeffrey owned in the
Caribbean, or at his ranch in New Mexico, which was really isolated.' She was 'given' to men ranging
in age from their 40s to their 60s.
They included a well-known businessman (whose pregnant wife was asleep in the next room), a
world-renowned scientist, a respected liberal politician and a foreign head of state.
None appeared to think the arrangement was unusual. Virginia says there were many other girls in
Epstein's circle and that she was paid extra money to help recruit them.
They would lounge around the Palm Beach house, the ranch or the island, nude or topless,' she
says. 'But I was one of the very few he trusted as "special" and chosen to "entertain" his friends.'
Virginia took the sedative Xanax to detach herself from sordid reality. 'It was an escape drug,' she
says. 'It made me calm and helped me forget about what I had to do. I was up to eight pills a day.'
Epstein had no objection to Virginia's use of prescription drugs, no doubt recognising that they made
her even more malleable. 'I didn't want to go back to the life l'd had before' she says.
That made me totally obedient.' Despite the fact that Epstein was, essentially, her pimp, this life now
seemed normal to Virginia. 'I felt that he and Ghislaine really cared for me,' she said.
http://www.dailymail.co.uk/news/article-1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him.html
> The Hunger Games
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Prince Andrew and girl, 17, who sex offender friend flew to Britain to meet him | Daily Mail Online
We'd do family things, like watch Sex And The
City and eat popcorn. 'A lot of it was very
glamorous. I met famous friends of his such as
Al Gore and Heidi Klum and Naomi Campbell.
He introduced me as his "travelling masseuse."
Some people mistook me for his daughter.
'When we were in New York or Palm Beach,
Ghislaine and I would shop all day.
Jeffrey bought me jewellery - diamonds were
his favourite - and wonderful furniture. He was
paying me very well because I'd give him sex
whenever he wanted it.'
She was, she says, delighted when Epstein
invited her to accompany him on a six-week trip
in 2001.
'He said we'd be going to Europe and North
Africa to meet architects and interior decorators
because he wanted to redo his New Mexico
house.
I threw my arms around him and gave him a
peck on the cheek.' They flew to Paris, then
Spain, then Tangier.
Finally, they went to London. 'After we landed,
we drove straight to Ghislaine's house,' says
Virginia. 'I was given a small upstairs bedroom.
The following morning, Ghislaine came in.
Counselling: Virginia at her mother's home at Palm
She was chirpy and jumped on the bed saying,
"Get up, sleepyhead. You've got a big day.
We've got to go shopping. You need a dress as you're going to dance with a Prince tonight."
'She said I needed to be "smiley" and bubbly because he was the Queen's son.
Ghislaine and I went to Burberry, where she bought me a £5,000 bag, and to a few other designer
stores where we bought a couple of dresses, a pair of embroidered jeans and a pink singlet,
perfume and make-up.
We got back to Ghislaine's house at around 4pm and I ran straight upstairs to shower and dress.
When I went downstairs, Ghislaine and Jeffrey were in the lounge. There was a knock at the door.
Ghislaine led Andrew in and we kissed each other on the cheek. 'Ghislaine served tea from a
porcelain pot and biscuits. She knew Sarah Ferguson and they talked fondly about Andrew's
Then Ghislaine asked Andrew how old he thought I was and he guessed 17 and they all laughed.
Ghislaine made a joke that I was getting too old for Jeffrey.
She said, "He'll soon have to trade her in." It was widely known that he liked young girls.' The four of
them went out to dinner and on to Tramp nightclub where, she says, Andrew danced with her.
'After about an hour-and-a-half, we drove back to Ghislaine's.
All of us went upstairs and I asked Jeffrey to snap a picture of me with the Prince. I wanted
something to show my Mom. Ghislaine and Jeffrey left us after that, and later Andrew left.
'In the morning, Ghislaine said, "You did well. He had fun". We flew straight back to the States.' The
Mail on Sunday has confirmed that the tycoon's jet flew to Paris on March 6, 2001, continuing to
Granada, Tangier and London, before returning to New York.
On the last leg of the trip, Virginia was paid about $15,000 (£9,400) by Epstein. 'It was amazing
money, more than I'd ever made on a trip with him before.
He didn't say there was any special reason, but I felt like l'd done everything he wanted. He was very
There is no suggestion that there was any sexual
contact between Virginia and Andrew, or that
I took eight pills a day to
Andrew knew that Epstein paid her to have sex
help me forget what I had to
with his friends.
do. It made me calm.
However, the Prince must have been aware of
Epstein's conviction when he stayed with him in New York in December.
Virginia says she met Andrew for a second time around Easter 2001 at Epstein's Manhattan
mansion.
When I got to the mansion, I was told, "Get ready. You are meeting someone in the office" - which
s what they called the library. Andrew was sitting there in a big leather armchair
hislaine had just given him a present, a big toy that was his Spitting Image puppet. 'He was smilin
ar-to-ear. He looked like a kid whose parents were taking him to Disney Worl
A beautiful girl called Johanna Sjoberg who worked for Jeffrey was sitting on Andrew's knee
Chisembe remed me over to Andrew and I think he recognised me, though I don't know if he
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Prince Andrew and girl, 17, who sex offender friend flew to Britain to meet him | Daily Mail Online
• comments on social
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modelling career started
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Organiser: Ghislaine Maxwell looks on as Andrew put his arm around Virginia. Robert Maxwell's daughter
invited her to work as Epstein's personal masseuse soon after her 15th birthday
We kissed on the cheek and Ghislaine placed me on his other knee.' Johanna spoke to The Mail on
Sunday three years ago about this incident, which took place when she was 21.
She said: 'Ghislaine put the puppet's hand on Virginia's breast, then Andrew put his hand on my
breast. It was a great joke. Everybody laughed.' After this, Virginia was paid, by Epstein, around
$400 (£250).'
She met Andrew for the third and final time on Epstein's Caribbean island, Little Saint James.
Virginia was never under the British legal age of consent when she met Andrew. She was 17 during
the first two encounters and 18 at the third.
By now, however, Epstein, had started to hint
that she was getting 'too old' for him.
But during one trip to the island, Epstein and
Ghislaine made their most astonishing
proposition, and one which repulsed her. 'They
said Jeffrey wanted me to have his child, she
'They said I was part of their family and I was
beautiful,young, loyal and nurturing and would
be a great mother.
They said I would have to sign a contract
relinquishing rights to the child and consenting
to Jeffrey having as many relationships as he
liked. In return I would have my own mansion in
Palm Beach and a large monthly payment, a
percentage of his income.'
This, finally, was a wake-up call to Virginia and
she began to see the way in which she had
'It was a smack in the face,' she says. 'I finally
realised this wasn't ever going to be a real
relationship but I knew if I refused, I'd be thrown
back on the streets. So I said, "I'm too young. I
want to get my massage credentials, then
maybe we'll do it"
The tycoon took her at her word and, for her
19th birthday in August 2002, flew her to
Thailand where he enrolled her in a massage
Shortly after arriving there, she met an
Australian martial arts expert called Robert.
They fell in love and, just ten days later, married
in a Buddhist ceremony.
Conviction: Jeffrey Epstein
I called Jeffrey and told him l'd fallen madly in
love,' Virginia says. 'I was hoping he'd be
delighted. But he said, "Have a nice life," and hung up on me. The couple now have two sons, aged
five and four, and a daughter who recently turned one.
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http://www.dailymail.co.uk/news/article-1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him.html
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Prince Andrew and girl, 17, who sex offender friend flew to Britain to meet him | Daily Mail Online
The first few months after I married Robert were the worst,' she says. 'I couldn't bring myself to tell
wall for shoot in
him much. No man wants to know his wife has been traded out.
picturesque Mykonos
Actress new photoshoot
I felt very alone. I was having panic attacks and seeing a psychiatrist and was on anti-depressants.
' Virginia was beginning to put her Epstein days behind her when, three years ago, she was phoned
by the FBI.
'They said they had found photos of me at Jeffrey's Palm Beach house,' she says. '[Epstein had]
hidden cameras watching me the entire time even when I was in the bathroom. I was so
embarrassed.
'I told the FBI that my true purpose was sexual. They told me everything he did was illegal because I
was under age. (The age of consent in Florida is 18).
'They said that if it had to go to trial, they'd need me because I'd lived with him and that made me a
key witness. I was very afraid, because he had so much power, but eventually I agreed to testify.
I was glad he'd finally been found out. He shouldn't be hurting other girls. Following Epstein's arrest,
investigators are believed to have found a list of men's names on his computer and asked him
whether they had been 'treated' to sexual encounters with his menage of minors.
'He took the Fifth Amendment, refusing to answer, indicating that if he were to answer the question,
it could be incriminating,' a source told The Mail on Sunday.
Epstein struck a deal resulting in what commentators characterised as a 'slap on the wrist' for him,
and ended up serving 13 months of his sentence, much of it in a liberal work-release programme
Lawyer Brad Edwards, who represented several of Epstein's victims, said: 'Rather than punish him
the way they would an average Joe, they sent a clear message that with enough money and power
and influence, the system can be bought.'
Virginia was spared her the humiliation of having to go before a jury, and has kept her feelings
bottled up until last weekend's photograph of Andrew with Epstein triggered distressing memories.
Virginia says: 'I am appalled. To me, it's saying, "We are above the law." But Jeffrey is a monster.'
Last night, neither Epstein, Ghislaine Maxwell nor Prince Andrew would comment on Virginia's story.
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