Text extracted via OCR from the original document. May contain errors from the scanning process.
RECEIVED 09/30/2816 02:45'M
0 09/30/2016 11:48 NI
12026009520
4 12127591216
O 1
Affidavit of Alan Dershowitz Regarding Potential Extortion Conspiracy
Involving
and Various Members of Her Legal Team
From t e day I was falsely accused of having sexual contact with Ms.
(otherwise known as
I. I believed that these allegations
were leveled for improper financial reasons. Over the course of the past ear I have
been made aware of facts that substantiate my belief that several of Ms.
lawyers, including Mr..Mand
Ms.
engaged in a
conspiracy to extort money rom wealthy individuals. One of these individuals is Mr.
Lesley Wexner who runs Limited Too and Victoria's Secret.
Indeed, it is my belief that Ms. IM
lawyers worked together: A. to threaten Mr.
Wexner with salacious information B. to offer him an opportunity to keep his name
out of the media C. to obtain publicity for Ms.
allegations D. to share in the
proceeds of the extortion.
I first learned that Mr. Wexner was the prima
to et of this cons ira from a
woman named
In
who is a
of
reached out to me in ear y p
, an over le course of
about ten conversations during the next several months, she told me that Ms.
never intended to mention me in any public filing but she felt pressured to
do so by her lawyers. She also told me facts that showed that the reason my name
was mentioned was to extort a large financial settlement from Mr. Wexner. Although
she did not use the word extortion, the substance of her conversation led
inescapably to the conclusion that naming me publicly, while not naming Mr.
Wexner publicly, was an essential element of the extortion plot.
With her permission, I recorded some of the crucial elements of our conversations,
and later had them transcribed. As the trash .ts make clear, throughout this
period
was in contact with Ms.
and spent time with her on several
occasions. Indeed, the information she relayed to me was based in part on
contemporaneous conversations she had with Ms. M.
Here are the relevant
excerpts:
Tape A
Alan M. Dershowitz: Now turning on a tape recorder and I'm recording with uh your
permission. So please repeat what you told me previously.
Okay, um tha
ever wanted to go after you urn but she felt
pressure um by her lawyers an that she had never... I've never heard her mention
you as when we were kids or you know until very recently after everything has
happened in the media but I've never heard her mention you before.
EFTA01681842
RECEIVED
09/30/2016 02: 45PM
09/30/2016 11:48 AM
12026009520
4 12127591216
O 2
Alan M. Dershowitz; Okay thank you and I'm turning off the tape recorder. Thank
you so much.
Dail
Alan M. Dershowitz: [inaudible] record and where you repeat what you basically
said to me before about the uh man in Columbus and urn what he um and how they
intended to get the amount of money they intended to get from them. That's crucial.
So can you give me that for just like 30 seconds?
Okay, I mean she never told me his name. I know it from you saying It.
Alan M. Dershowitz: We know his name of course.
ME Okay...
Alan M. Dershowitz: Tell me how she described him to you.
She just said that he owned Victoria Secret and Limited Too, and that he
had ots and lots of money. You know, was a billionaire.
Alan M. Dershowitz: Great And what did they want to do?
a
They wanted to sue him for at least half his money and use it for the
charities that they're trying to start
Alan M. Dershowitz: And what would the lawsuit be based on?
Oh I guess the... she didn't say exactly, just being affiliated with Epstein the
alleged you know and partaking you know in the girls that he would provide them
or provide him.
Alan M. Dershowitz: Yeah. And did they think they would have to bring the lawsuit
or would they just be able to threaten the lawsuit and he would pay the money?
a
She made it sound like to me that they were already talking to him and
they were, they had already you know in the process of suing him.
Alan M. Dershowitz: Aha. And was he going to then you think settle it or was he
actually going to litigate it... what did it sound like?
li
She didn't really say but she made it sound like she as pretty positive about
en I didn't hear about it for like months and then you know the last time she
talked about the charity, it wasn't about him anymore, it was about just you know
raising money going to like you know celebrity charity events to get money or I
remember her you know showing she was going to do a bunch of television
EFTA01681843
RECEIVED
09/30/2816 02: 45PM
0 09/30/2016 11:48 AM
12026009520
4 12127591216
O 3
interview um to raise the... and use that money that they were paying her for the
interviews to help get it started.
Alan M. Dershowitz: Right but that would be...
And the lawyers contributed their own money into it probably like, I don't
know, like $80,000 or something like that
Alan 14. Dershowitz: They contributed $80,000 to what, to the fund?
The charity yeah, to get it started for her.
Alan M. Dershowitz: And were the lawyers charging her or how did that work... do
you know?
Nope, I mean, uh, she, to her, I think the result of her, or what do you call it,
pro bono, they weren't charging anything for their, ya know.
Alan M. Dershowitz: But did they expect to get something out of it if they sued this
rich guy in Columbus from Victoria Secret.
II=
Really, it's, she didn't say it exactly but that's just kind of like, you know,
looking at it in retrospect, that's how it seemed, you know, it just seemed like it was,
they saw an opportunity to make a lot of money.
Alan M. Dershowltz: And did she mention, she didn't mention who the lawyers are
or where they were form did she?
IIME No.1 just have that paperwork that was sent to me by... from them.
Alan M. Dershowitz: right. Sure. But do you know who sent it to you?
Um, she sent, I mean, no, I don't know exactly, she sent it to me... it was
forwarded from her email to my email.
Alan M. Dershowitz: Right And my understanding Is that she was going to try to get
the uh ABC to uh give her some credibility so that that would increase the leverage
on being able to get a settlement or a lawsuit?
a
Yeah, I mean...
Alan M. Dershowitz: Yeah, alright, well I appreciate that and again just repeat you
gave me permission to record this and um would you just say yes so?
Ma
Okay, yes.
EFTA01681844
RECEIVED 09/30/2016 02:45PM
0 09/30/2016 11:48 AM
12026009520
i 12127591216
O 4
Alan M. Dershowitz: I appreciate that Thank you. If you can think of anything else,
just please, please let me know because um this is very, very important
Tape Q
Alan M. Dershowitz: I'm recording now with your permission so just tell me the
story as as simply as you can.
IMIN Okay about the interaction that I had with her where she told me about
what was going to happen when it came to starting this charity?
Alan M. Dershowitz: Right
IME ... is what you're asking?
Alan M. Dershowitz: Yeah, yeah.
IME Okay. Um you want me to talk now.
Alan M. Dershowitz: Yeah, sure.
Ok alright, earlier we were together on Clemantis we had dinner at
Dempsey's and she just kind of told me about how she was going to sue the man
who owned Limited Too and Victoria Secret for lots of money and that they were
going to be able to take that money and start this charity to help you know women
that had been trafficked and that you know there were other big names that she was
going to be able to um also urn refer to what happened or what she said had
happened when she was younger. Uh I don't know exactly what else. She didn't
really mention names Just one, just the one that I don't remember his, the guy who
owns, you know, Victoria Secret and all that and uh she also said to me that when it
came to Alan Dershowitz that she did feel pressure to go after you, after him... urn
her, you know to, she felt pressure to do it, she didn't want to go after you
specifically, that she felt pressured by her lawyers to do that
Alan M. Dershowitz: Alright, well thank you very much I really appreciate it You
know, we were recording this with your permission. I'm going to turn off the
recording now.
Upon learning of the extortion plot from MB
I immediately called Lesley
Wexner and spoke to his wife, Abigail. I told he
'
r. Wexner was
being extorted, and she confirmed the fact that
lawyers had
reached out to Mr. Wexner's lawyers. She said she would have Mr. Wexner's lawyers
call me, which they then did.
EFTA01681845
RECEIVED 09/30/2016 02: 45PM
09130/2016 11:48 AM
12026009520
12127591216
D 5
ohn Zie er, Mr. Wexner's lawyer, confirmed that and
his partneri.
hada.' meeting to resolve a situation involving Mr. Wexner and
eir c ien , Ms
In subsequent phone
tions, Mr. Zieger confirmed that Mr.aind Ms.
tated that
had a claim against Mr. Wexner. This claim included
allegations that Mr. Wexner had engaged in sexual contact with her when she was a
minor on numerous occasions, including on Epstein's island, his ranch in New
Mexico, his house in Palm Beach, and his home
York. Ms. McCawley also
specifically alleged that Mr. Wexner had made
dress up in baby doll lingerie
of the type made by Victoria's Secret.
Mr. Zieger informed me that the allegations in Mr.
regard were completely
fabricated, and that Mr. Wexner would not pay Ms.
her representatives
any amount whatsoever.
g this information was clearly intended to induce Mr. Wexner to pay for Ms.
' silence, since an accusation that the head of Victoria's Secret had sex with
an underage female, who he had dressed up in Victoria's Secret lingerie would be
extremely destructive to the company and to Wexner's stewardship of the company.
It is also clear that the statute of
expir
ions for
vit against Wexner has long
and Ms.
are aware of this is that
to sue Ghislaine Maxwell on behalf of Ms.
they i not sue or e actual events that took place years earlier but for an
alleged defamation that occurred during 2015.
The only realistic threat that the lawyers have over Wexner Is public exposure
rather than a credible lawsuit. Therefore, the only possible purpose of Ms. IS=
• g this information to Mr. Wexner would be to induce Mr. Wexner to pay Ms.
for her silence. Indeed, on information and belief, Mend
Ms.
ere planning to threaten and or bring a lawsuit against Mr. Wexner if he
failed to resolve the matter to their satisfaction.
This extortion scheme is substantiated by the fact that when representatives of Ms.
made contact with ABC in January 2015, they studiously avoided any
mention of Mr. Wexner. Again, the only possible purpose for these lawyers not to
name Mr. Wexner would be so that they could hold allegations over his head as a
threat Similarly, Mr. Wexner's was describecLaitagiential witness to Wats
alleged abuses on several occasions both Ms.
lawyers, and by Ms.
herself, most notably in a teleconference call from 2011. However, following the
meetings between Mr. Wexner's lawyers
r. Wexner's
name was excluded from the witness list in the lawsuit against Ms. Ghislaine
Maxwell in New York
EFTA01681846
RECEIVED
09/30/2016 02: 45PM
0 09/30/2016 11:48 AM
12026009520
312127591216
f", 6
On information and belief,
has also accused other prominent
businessmen and political leaders. We are aware of their names but this information
has been sealed. It is necessary to investigate whether meetings similar to those
with Mr. Wexner's lawyers were held with other wealthy or prominent individuals,
or their representatives.
EFTA01681847
RECEIVED
09/30/2016 02: 45PM
0 09/30/2016 11:48 AM
12026009520
-> 12127591216
C 7
***************** The Following Paragraphs are Sealed ***************""
documents produced durin
'
ry in
Is
hat will confirm the fact that
never made any allegations against me until after she met with her lawyers,
from whom she felt pressurelise me as one of her abusers. This further
corroborates the role of Ms.
lawyers in the extortion plot described above.
Among hese documents
the reporter fo
Ms.
allegations regarding Prince
also wrote several stories concerning Ms.
apparently is a close friend of Ms.
and Ms
ho original)
of England in 2011. Ms.
allegations in my regard, and
M name appears on two se arate occasions in the correspon n
tween Ms.
and Ms.
particular, on 11 May 2011 Ms.
wrote to Ms.
•
"Don't forget Alan Dershowitz... JE' s buddy and lawyer -good name for your pitch as he
repped Claus von Bulow and a movie was made about that case ._ title was Reversal of
Fortune. We all suspect Alan is a pedo and tho no proof of that, you probably met him when
he was hanging put w JE"
Attached to another email is an early draft of the book Ms.
was writing
regarding her experiences with Mr. Epstein. My name appears there as well:
'Jeffrey' s business was running well from the looks of his attentiveness the office he owned
in the Upper East Side of Manhattan. Alan Dershowite, his colleague in finances and personal
solicitor, a bird of the same feather, I had seen hanging around the island and Jeffrey' s
Manhattan mansion, more and more these days. Alan' s taste for the young and beautiful was
a bias for a blooming business relationship between him and Jeffrey. After an explicit session
of Jeffrey s vulgar pilgrimage into my body, we were interrupted by a knock at the door by
Jeffrey's good friend, Alan. I wrapped myself up in Jeffrey's pink bed sheets, which is the
color preference he chose to sleep in because it reminded him of the same color of his own
words " Pussy', and covered my face from the unexpected intrusion. Jeffrey got up and
wrapped a towel around his loins and answered the door completely calm. Opening the
bedroom door and letting Alan inside they began to converse about business Immediately,
right in front of me. Jeffrey started to tell Alan what needed to be done while he jostled some
notes down quickly. I peeked my head from underneath the covers thinking they were too
wrapped up in their work to notice me get up and dressed, and Jeffrey turned back to me and
told me to just stay there this would only take a second. Going back to Alan he turned his
focus back Into work and hustled out a few more orders before letting Alan out of the door
and returning his attention to me."
Beyond the fact that Ms.=
story described above is wholly fabricated, more
c
importantly, this is the only Instance in which 1 featur '
count of her
experiences with Mr. Epstein. In short even after Ms.
urged Ms.
to
include me in her memoir, Ms.
did not name me as someone with whom she
EFTA01681848
RECEIVED 09/30/2016 02:45PM
0 09/30/2016 11:48 AM
12026009520
-> 12127591216
D 8
had sex. In fact, according to Ms. Mttorneys,
she had no reason to suspect
me:
akes no suggestion that [Ms
had sexual contact with Dershowltz. To the
contrary, she states that there was 'no proof' that he was a'
Dm—which directly
contradicts such a suggestion in itself—but only that
robably met him when
he was hanging out with [Jeffrey Epstein):
This corroborates the accounts o
Ms:
who stated that she did not name me as one of the individua s tow om s e
was allegedly pimped out by Mr. Epstein. It was not until after she had met with her
lawyers that she suddenly "remembered" her alleged sexual relations with me—
relations that in fact never occurred.
EFTA01681849