Filing # 27349731 E-Filed 05/15/2015 01:43:57 PM

Filing # 27349731 E-Filed 05/15/2015 01:43:57 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 / Counterclaim Defendants, v. ALAN M. DERSHOWITZ, Defendant / Counterclaim Plaintiff. DEFENDANT / COUNTERCLAIM PLAINTIFF ALAN DERSHOWITZ'S MEMORANDUM IN OPPOSITION TO JANE DOE NO. 3'S MOTION TO OUASH OR FOR PROTECTIVE ORDER Defendant / Counterclaim Plaintiff Alan Dershowitz ("Dershowitz") respectfully submits this Memorandum in Opposition to the Motion to Quash or for Protective Order Regarding Subpoena filed by non-party Jane Doe No. 3 (the "Motion to Quash"). INTRODUCTION The Motion to Quash presents Jane Doe No. 3 — who is a 31-year-old married woman — as though she were a minor who is being unwillingly dragged into a dispute not of her making and who would prefer to avoid public attention.' Nothing could be further from the truth. This case began when Jane Doe No. 3 and her lawyers, Bradley J. Edwards ("Edwards") and Paul G. Cassell ("Cassell") (together, "Plaintiffs"), made a deliberate decision to file a pleading in a federal lawsuit accusing Dershowitz of committing a heinous crime: sexually Jane Doe No. 3 has no right to proceed anonymously as she has been identified publicly on several occasions and has made public statements to the media using her own name, as indicated by the exhibits that she submitted with the Motion to Quash. See Motion to Quash, Exs. 1-4. Nonetheless, Dershowitz will refer to her as "Jane Doe No. 3" until the Court orders otherwise. EFTA01099175 abusing a minor. Jane Doe No. 3 and her attorneys made these allegations in public court pleadings and declarations, hoping to hide behind the litigation privilege to prevent Dershowitz from being able to hold them accountable for their false statements. Jane Doe No. 3's outrageous allegations were obviously intended to generate publicity for herself and her lawyers — not to advance any legitimate interest. As alleged in Dershowitz's counterclaim, Plaintiffs alerted the media to the filing of Jane Doe No. 3's accusations to maximize the resulting publicity. The allegations had absolutely no relevance whatsoever to the lawsuit in which the pleadings and declarations were filed and gratuitously included the names of prominent people, including Prince Andrew. Jane Doe No. 3 also alleged that Jeffrey Epstein ("Epstein") "trafficked her for sexual purposes" to other powerful and prominent men, including prominent American politicians and world leaders, yet withheld the names of those individuals in a transparent effort to generate media interest in potential future revelations. That the allegations were improper and irresponsible is not merely an assertion by Dershowitz; United States District Judge Marra has expressly held that the "lurid" allegations were "unnecessary," "immaterial," and "impertinent" to the federal lawsuit. See Ex. A, at 5. Judge Marra ordered the allegations stricken from the record and reminded the attorneys of their obligations under Rule 11 of the Federal Rules of Civil Procedure, which prohibits filings made for an improper purpose. Id. at 5-7. According to Judge Marra, "striking the lurid details from [the] submissions is sanction enough." Id. at 7. As Jane Doe No. 3 and her lawyers undoubtedly expected and intended, their "unnecessary," "immaterial," and "impertinent" allegations resulted in a firestorm of publicity about Dershowitz's alleged misconduct. With Plaintiffs and Jane Doe No. 3 seeking to hide behind the litigation privilege and relying instead on the media to circulate the false accusations 2 EFTA01099176 under the protection of the fair reporting privilege, Dershowitz responded as best he could by telling the press repeatedly and forcefully that Jane Doe No. 3's allegations about him are completely and categorically false. Edwards and Cassell used their own "credibility" as lawyers and, in Cassell's case, as a former judge and a professor (he used the name of his law school name and address on the pleading),in an effort to enhance the credibility of Jane Doe No. 3's false accusations against Dershowitz. Dershowitz responded by expressing his opinion that Plaintiffs knew or should have known the allegations were false, or would have known they were false if they had done even minimal investigation into Jane Doe No. 3's story. Edwards and Cassell then filed this action, alleging that Dershowitz committed the tort of defamation in making these statements to the media in order to defend himself. To prevail on their defamation claim and defeat Dershowitz's affirmative defenses, Plaintiffs must substantiate their allegation that Dershowitz made the statements to the media even though he "knew [the filing containing Jane Doe No. 3's outrageous allegations was] an entirely proper and well- founded pleading." See Compl. 17. In other words, Plaintiffs must prove both that the allegations asserted in the Joinder Motion were "well-founded" and that Dershowitz knew they were true. The testimony of Jane Doe No. 3 and the documents requested in the subpoena are at the very heart of this issue, which Edwards and Cassell have placed squarely in dispute. Although Jane Doe No. 3 is not a party to this case, she is, at bottom, the accuser making allegations of criminal misconduct, which Plaintiffs contend are true and which Dershowitz contends are complete fabrications. There simply is no basis for crediting Jane Doe No. 3's assertions of "irrelevance." Jane Doe No. 3's argument that she should be excused from providing relevant discovery because Dershowitz is "abusing" the subpoena power by seeking information that is "highly 3 EFTA01099177 personal" and "confidential" is completely meritless and, indeed, disingenuous in light of her deliberate actions as an adult to seek publicity. As an adult, Jane Doe No. 3 has voluntarily submitted multiple sworn declarations and has given numerous media interviews in which she has described, at length and in lurid detail, the very same events that she is now contending are "highly personal" and "confidential." Indeed, Dershowitz has learned that, since the filing of the Motion to Quash, Jane Doe No. 3 gave a recorded interview to the ABC television network in which she detailed her alleged experiences as a "sex slave" for Epstein. That interview was intended to be broadcast on several national platforms, although it has yet to air. An organization that Dershowitz believes to be affiliated with Edwards has promoted the interview on its social media page. See Ex. B, at II. The existence of the ABC interview had not been publicly disclosed previously, so the obvious inference is that the organization learned of it from Jane Doe No. 3 or her lawyers. Were Jane Doe No. 3 truly concerned for her privacy, she could have refrained from giving any media interviews and avoided rather than sought publicity. As to the federal lawsuit, Judge Marra has already held that the allegations against Dershowitz (and Prince Andrew) were not entirely proper, as Plaintiffs have alleged, but rather should never have been included in Jane Doe No. 3's pleadings at all. And, even if those allegations had some legitimate purpose, which Judge Marra held they did not, Jane Doe No. 3 and her lawyers could have made them in a sealed pleading. Instead, Jane Doe No. 3 (with Plaintiffs' assistance) made these accusations in the most public manner possible — seeking out the limelight rather than hiding from it. In light of these deliberate choices by Jane Doe No. 3, and considering the issues in dispute in this action, Dershowitz's need for the requested documents and testimony clearly outweighs any "privacy" interests that Jane Doe No. 3 could 4 EFTA01099178 conceivably assert. Indeed, by making her allegations publicly and by seeking publicity, Jane Doe No. 3 has waived any right to "confidentiality" or "personal privacy" that she may have had. A person cannot go to the press to publicize a topic, and then refuse to give relevant evidence to a court regarding that same topic based on "privacy" concerns. Swords may not be used as shields. The subpoena is not a fishing expedition, nor does it represent any sort of abuse of the discovery process. Jane Doe No. 3, along with Plaintiffs, set off the chain of events that led to the filing of this lawsuit by making false and gratuitous allegations against Dershowitz, to which Dershowitz had a constitutional right to respond in the court of public opinion. If she had not voluntarily made these scurrilous allegations, or if they had been true, there would have been no statements by Dershowitz and no lawsuit. She must be compelled to submit to questioning about those scurrilous allegations, which are the crux of the claims and defenses at issue in this defamation action. Like any witness, she is entitled to be treated with dignity and respect during the discovery process, and will be so treated by Dershowitz's counsel. But the notion that she is entitled to extraordinary protections, and to be excused from producing evidence that is central to this case, is frivolous. In particular, the Court should reject Jane Doe No. 3's request to bar Dershowitz from attending her deposition because of her purported "fear" of being in his presence. That "fear" cannot be credited without also crediting Jane Doe No. 3's false allegations of misconduct by Dershowitz, which would be entirely inappropriate at this stage given that Dershowitz is vigorously contesting those allegations. For these reasons and as explained in detail below, the Court should deny the Motion to Quash and reject Jane Doe No. 3's request for a protective order that imposes limitations on the subpoena. 5 EFTA01099179 FACTUAL BACKGROUND This defamation action arises out of an underlying lawsuit that Edwards and Cassell filed against the United States (the "Government") in the United States District Court for the Southern District of Florida (the "Federal Action") more than eight years ago. In the Federal Action, Edwards and Cassell represent certain alleged victims of Epstein, a client of Dershowitz's, who contend that the Government violated their rights under the Crime Victims' Rights Act (the "CVRA"). Specifically, the two alleged victims — known as "Jane Doe No. 1" and "Jane Doe No. 2" — assert that the Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement with Epstein, who allegedly subjected them to various sexual crimes when they were minors. On December 30, 2014 — more than eight years after the Federal Action began — Edwards and Cassell filed a motion to allow a third alleged victim, Jane Doe No. 3, to join in the suit as an additional plaintiff (the "Joinder Motion"). See Counterclaim, at 12. The Joinder Motion alleges that Jane Doe No. 3 first met Epstein in 1999 and that Epstein "kept Jane Doe #3 as his sex slave from about 1999 through 2002, when she managed to escape to a foreign country." Id. The Joinder Motion alleges that "Epstein also sexually trafficked the then-minor Jane Doe [No. 3], making her available for sex to politically-connected and financially-power people." Id. In several paragraphs that Judge Marra has since ordered stricken from the record, the Joinder Motion then alleged that Epstein required Jane Doe No. 3 to have sexual relations with Dershowitz in certain specific locations, among other allegations of criminal conduct by Dershowitz. The Joinder Motion includes similar allegations against Prince Andrew, which Judge Marra has also ordered stricken because they should never have been included in the 6 EFTA01099180 pleading. Edwards and Cassell filed the Joinder Motion on behalf of Jane Doe No. 3 on the public docket in the Federal Action, without any accompanying motion to seal. The Joinder Motion marked the first time that Jane Doe No. 3 (either directly or through her attorneys) publicly asserted any sort of allegations of misconduct against Dershowitz. To the best of Dershowitz's knowledge, Jane Doe No. 3 also had not previously communicated to any law enforcement officials or journalists that she had sex with Dershowitz. Certainly, no federal law enforcement agency, court or other objective investigator has ever investigated or acted on Jane Doe No. 3's belated accusations against Dershowitz. Yet, the Federal Action is not the first forum in which Jane Doe No. 3 has made public statements about her interactions with Epstein and others as a minor. In 2011, Jane Doe No. 3 gave an extensive interview to the Daily Mail, a British tabloid publication, during which she "agreed to waive her anonymity" and provided a number of specific details about her alleged abuse at the hands of Epstein. See Ex. C. Dershowitz intends to ask in discovery if Jane Doe No. 3 was paid for this interview, which seems likely. The Daily Mail quotes Jane Doe No. 3 as stating that "I was training to be a prostitute for [Epstein] and his friends who shared his interest in young girls." Id. According to the Daily Mail, Jane Doe No. 3 was very descriptive during her interview about her time with Epstein. Indeed, Jane Doe No. 3 stated that she was "telling [the news publication] things that even my husband didn't know." Id. The tabloid newspaper specifically noted that "for reasons of taste, not all the details [provided by Jane Doe No. 3] can be included here." Id. A person interested in privacy or confidentiality does not give interviews for publication providing sordid detail of her alleged experiences, apparently in exchange for money! 7 EFTA01099181 Jane Doe No. 3 used a similar level of detail in the two sworn declarations she submitted in the Federal Action following the filing of the Joinder Motion. The declarations — each of which consisted of more than 60 separate paragraphs — provided many details about Jane Doe No. 3's time with Epstein. The first declaration actually included multiple photographs purportedly of Jane Doe No. 3 as a minor, including one of Jane Doe No. 3 and Prince Andrew. With respect to Dershowitz, Jane Doe No. 3's first declaration provided gratuitous (and completely false) details about six specific instances in which Jane Doe No. 3 purportedly had sexual intercourse with Dershowitz. Of course, Jane Doe No. 3 failed to identify the specific dates (or even the specific months or years) when these purported instances occurred. Jane Doe No. 3 also falsely averred that Dershowitz watched Epstein engage in sexual acts with her. As with the Joinder Motion, Plaintiffs filed Jane Doe No. 3's declarations on the public docket in the Federal Action without any effort to seal the contents of the documents. In response to the false and outrageous allegations asserted against him in the Federal Action and the subsequent media coverage of those allegations, Dershowitz also made a number of public statements defending his previously unblemished personal and professional reputations. Because Edwards and Cassell tried to exploit their credibility as lawyers and, in Cassell's case, as a former judge and law professor, in an effort to bolster the credibility of the false accusations against Dershowitz, Dershowitz also expressed his constitutionally protected opinion that Edwards and Cassell acted improperly and deserved to be disbarred. Edwards and Cassell then filed this action, alleging that Dershowitz defamed them by "initiat[ing] a massive public media assault on the reputation and character of [Edwards] and [Cassell] accusing them of intentionally lying in their filing, of having leveled knowingly false accusations against [Dershowitz] without ever conducting any investigation of the credibility of the accusations and of having acted 8 EFTA01099182 unethically to the extent that their willful misconduct warranted and required disbarment" — even though Dershowitz "knew [the Joinder Motion] to be an entirely proper and well-founded pleading." Compl. 1 17. Plaintiffs' pleading thus placed at issue whether Dershowitz "knew" that Jane Doe No. 3's allegations against him were "well-founded" (i.e., true) and whether those allegations are, in fact, true. Pursuant to the stipulated order entered by this Court on March 20, 2015 that appointed a Commissioner in the State of Colorado, Dershowitz served a subpoena for the production of documents and a videotaped deposition on Jane Doe No. 3. See Motion to Quash, Ex. 6. The subpoena seeks, among other things: (1) documents supporting Jane Doe No. 3's allegations about Dershowitz in the Federal Action; (2) photographs and video of Jane Doe No. 3 with Dershowitz; (3) photographs, videos, and documents establishing that Jane Doe No. 3 was in the six locations identified in her declaration at the same time that Dershowitz also was in those six locations; (4) statements provided by, and notes from interviews given by, Jane Doe No. 3 referencing Dershowitz by name; (5) travel records, cell phone records, and diaries from the time period when Jane Doe No. 3 has proclaimed she was kept as a "sex slave" by Epstein; (6) drafts of any of Jane Doe No. 3's declarations referencing Dershowitz by name; and (7) documents concerning any actual or potential book, television, or movie deals concerning Jane Doe No. 3's allegations about being a "sex slave." Id. In short, the subpoena seeks documents and information that are directly relevant to the issues Plaintiffs have placed in dispute in this defamation action by alleging that Dershowitz "knew" that Jane Doe No. 3's accusations against him were "entirely proper" and "well-founded." Plaintiffs refused to accept service of the subpoena on behalf of Jane Doe No. 3, even though they represent her in connection with the Federal Action. Plaintiffs referred Dershowitz 9 EFTA01099183 to the law firm of Boies, Schiller & Flexner LLP ("BSF'), which is representing Jane Doe No. 3 for purposes of this action. BSF likewise declined to accept service on behalf of Jane Doe No. 3, which forced Dershowitz to seek the issuance of the subpoena through the commission process and ultimately to effect service on Jane Doe No. 3 in Colorado. After all that, Jane Doe No. 3's lawyers asked Dershowitz to consent to having this Court resolve the Motion to Quash and for her deposition to be in Florida, which Dershowitz did. Jane Doe No. 3's deposition and production of documents have been delayed by this unnecessary and inappropriate runaround. On April 7, 2015, Judge Marra issued an order in the Federal Action striking the portions of the Joinder Motion and Jane Doe No. 3's declarations referring to Dershowitz. See Ex. A. The court concluded that the allegations against Dershowitz, including the "lurid details" included in the Joinder Motion by Plaintiffs on behalf of Jane Doe No. 3, are "immaterial and impertinent" to the issues in dispute in the Federal Action and were "unnecessary" to resolving the Federal Action. Although he warned the attorneys of their obligations under Federal Rule of Civil Procedure 11, he ruled that striking these allegations was "sanction enough" for Edwards and Cassell. In a supplemental order also issued on April 7, 2015, Judge Marra ordered that the filings containing the stricken materials be restricted from public access. See Ex. D. Since the filing of the Motion to Quash, ABC contacted Dershowitz and others and informed them that Jane Doe No. 3 has given an on-air interview about her time with Epstein as a minor that was intended to be broadcast to millions of viewers on a number of the television network's programs. Although the interview was scheduled to be aired in April, it still has not aired. 10 EFTA01099184 MEMORANDUM OF LAW I. The documents and testimony that Dershowitz seeks from Jane Doe No. 3 are directly relevant to this defamation action. The thrust of Jane Doe No. 3's motion to quash is that Dershowitz is improperly using the defamation action to obtain backdoor discovery relating to the "different" matters at issue in the Federal Action. See Motion to Quash, at 8. In reality, however, the subpoena served on Jane Doe No. 3 seeks documents and testimony that are at the very crux of this action, as framed by Plaintiffs' own complaint. Moreover, the Federal Action is now over with respect to both Dershowitz and Jane Doe No. 3. Under Rule 1.280 of the Florida Rules of Civil Procedure, "[p]arties may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter of the pending action, whether it relates to the claim or defense of the party seeking discovery or the claim or defense of any other party[.]" Put differently, information is discoverable so long as it relates "to the issues involved in the litigation, as framed in all pleadings." Diaz-Verson v. Walbridge Aldinger Co., 54 So. 3d 1007, 1011 (Fla. 2d DCA 2010); see also Richard Mulholland & Assocs. v. Polverari, 698 So. 2d 1269, 1270 (Fla. 2d DCA 1997) (a protective order is required only "when the pleadings indicate that the documents requested are not related to any pending claim or defense"). Jane Doe No. 3 contends that she should not have to testify or produce any documents in this case because the allegedly defamatory statements at issue "are statements about [Plaintiffs] character as lawyers and do not directly involve non-party Jane Doe No. 3." Motion to Quash, at 3. This is simply wrong. The complaint expressly alleges that Dershowitz committed the tort of defamation by accusing Plaintiffs of having acted improperly by filing the Joinder Motion, even though Dershowitz "knew [the Joinder Motion] to be an entirely proper and well-founded 11 EFTA01099185 pleading." Comp. 1 17. Thus, the face of the complaint asserts that Jane Doe No. 3's accusations were "well-founded" and that Dershowitz "knew" they were true — allegations that necessarily establish that this case does directly involve Jane Doe No. 3 and the credibility of her accusations against Dershowitz. The relevance of Jane Doe No. 3's testimony and documents becomes even more apparent after considering what Plaintiffs must prove to prevail on their defamation claim and defeat Dershowitz's affirmative defenses. Under Florida law and the First Amendment, a defamation plaintiff must establish the following elements: (1) publication; (2) falsity; (3) actor must act with knowledge or reckless disregard as to the falsity on a matter concerning a public official, or at least negligently on a matter concerning a private person; (4) actual damages; and (5) statement must be defamatory. Jews For Jesus, Inc. v. Rapp, 997 So. 2d 1098, 1106 (Fla. 2008). Because Plaintiffs are public figures or limited public figures, they must also prove that Dershowitz acted with actual malice in making his statements, i.e., that Dershowitz "knew [the Joinder Motion] to be an entirely proper and well-founded pleading." Comp. 1 17. The truth or falsity of the accusations to which Dershowitz responded is certainly relevant to Dershowitz's knowledge of whether the allegations were proper and well-founded and his alleged "malice" in responding to them. Testing this allegation requires discovery into the credibility of Jane Doe No. 3's accusations against Dershowitz. Whether those allegations are true or false go directly to whether Dershowitz was properly defending his reputation or acting maliciously in his statements about Plaintiffs by vehemently denying Jane Doe No. 3's allegations. The subpoena served on Jane Doe No. 3 is intended to accomplish precisely that goal. For example, the subpoena seeks "[a]ll documents that reference by name, Alan M. Dershowitz, which support 12 EFTA01099186 and/or confirm the allegations set forth in" Jane Doe No. 3's declarations submitted in the Federal Action, as well as "[a]ny documents and information that support and/or confirm [Jane Doe No. 3's] presence at the various locations named in [Jane Doe No. 3's declaration] on the particular dates and times when [Dershowitz] was also present." Similarly, the subpoena seeks Jane Doe No. 3's diaries, cell phone records, and travel records during the time she asserts she was kept as Epstein's "sex slave," i.e., 1999 to 2002 — all of which could contain information that undermines or contradicts her allegations about when and where she allegedly had sex with Dershowitz (and that likewise disproves Plaintiffs' allegation that Dershowitz knew the Joinder Motion was a "well-founded pleading").2 This information also is relevant to whether Plaintiffs conducted an appropriate investigation, which would have included asking Jane Doe No. 3 for these documents and examining them to determine whether they support or undercut her allegations. The subpoena also requests documents that go to Jane Doe No. 3's general credibility — an issue that is directly relevant to the truth of Jane Doe No. 3's allegations against Dershowitz, whether Dershowitz knew the Joinder Motion to be "well-founded," and what type of investigation (if any) Plaintiffs conducted into Jane Doe No. 3's allegations. For example, Jane Doe No. 3 has made statements to the media about meeting former President Clinton and former Vice President Gore on Epstein's private island in the Caribbean. Dershowitz is entitled to explore the veracity of Jane Doe No. 3's accounts of these meetings, because any inconsistencies are obviously relevant to Jane Doe No. 3's credibility as a witness regarding her alleged 2 Of course, if Plaintiffs or Jane Doe No. 3 were to identify and disclose the specific dates of the purported six instances when Jane Doe No. 3 allegedly had sex with Dershowitz, the scope of the requested discovery (as well as Plaintiffs' own discovery requests) could easily be narrowed. To date, however, Plaintiffs and Jane Doe No. 3 have conspicuously refused to make any specific allegations of timing. 13 EFTA01099187 experiences as a "sex slave" for Epstein. That evidence is also directly relevant to the sufficiency of any investigation undertaken by Plaintiffs before filing the Joinder Motion. Dershowitz expects the evidence to show that Jane Doe No. 3's public accounts of her alleged interactions with President Clinton and Vice President Gore are complete fabrications, just like her allegations against Dershowitz. Similarly, Dershowitz has a right to explore Jane Doe No. 3's potential book, movie, and television deals as a means of establishing her bias, as well as Plaintiffs' (i.e., whether the lawyers had a financial incentive to help sensationalize Jane Doe No. 3's story by identifying Dershowitz by name in a public pleading). See Steinger, Iscoe & Greene, P.A. v. GEICO Gen. Ins. Co., 103 So. 3d 200, 203 (Fla. 4th DCA 2012) (discovery aimed at obtaining evidence of a witness's bias is permissible). Jane Doe No. 3 has discussed her allegations in public and in detail, naming some of the prominent people with whom Epstein allegedly forced her to have sex but pointedly withholding other names, presumably in order to "sell" them to a book publisher or the tabloids. She has also sought out publicity, including through her recent interview with ABC Television. The obvious inference to be drawn from Jane Doe No. 3's behavior is that she and her lawyers are attempting to cash in on her alleged experiences by way of a book or movie deal or otherwise. Dershowitz is entitled to test that inference in discovery. And, as discussed in detail below, Jane Doe No. 3 has waived any confidentiality or privacy interests she may have in this type of information through her voluntary disclosures and public statements. No one is entitled to titillate the public by asserting to the media and in public filings that she had improper sexual relations with prominent public figures (naming some while saving others for potential future disclosure), while at the same time refusing to provide evidence on the same subject. 14 EFTA01099188 The cases relied upon by Jane Doe No. 3 in support of her relevance argument are inapposite because they involved attempts to obtain information that had no "possible relevance" to the issues in dispute. For example, in Calvo v. CaIvo, 489 So. 2d 833, 834 (Fla. 3d DCA 1986), the Third District held that an ex-wife's financial records had no "possible relevance" to her post-judgment action seeking to compel payments that the ex-husband owed under a previously entered final judgment dissolving their marriage. In Toledo v. Publix Super Markets, Inc., 30 So. 3d 712 (Fla. 4th DCA 2010), the Fourth District held that a party cannot issue an indiscriminate request to the attorney of a non-party seeking the attorney's entire client file in an unrelated litigation, absent some showing of how specific documents in that file might possibly be relevant. Here, by contrast, Dershowitz is seeking specific types of information from Jane Doe No. 3 and has established how that information is directly relevant to matters put at issue by this defamation action, as framed by the operative pleadings. The subpoena issued to Jane Doe No. 3 is in no way, shape, or form a fishing expedition. II. Jane Doe No. 3's "confidentiality" and "privacy" assertions cannot excuse her from testifying or producing documents given her repeated public statements about these issues. Jane Doe No. 3 also attempts to use "confidentiality" as a shield to protect her from having to participate whatsoever in discovery. Specifically, Jane Doe No. 3 argues that it would be "oppressive and unreasonable" to force her to provide any testimony or documents about her time with Epstein because that topic is "highly personal and sensitive." Motion to Quash, at 4. Jane Doe No. 3 therefore asks the Court to quash the subpoena in its entirety so that she is not "forc[ed]" to testify about her experiences at the hands of Epstein. Id. Jane Doe No. 3's assertions of "privacy" and "confidentiality" are untenable in light of what she and her lawyers have deliberately exposed to the public. Jane Doe No. 3 has made 15 EFTA01099189 public, detailed statements about her interactions with Epstein, as well as her purported encounters with Dershowitz during her self-described time as Epstein's "sex slave." Jane Doe No. 3 has even given lengthy interviews describing her experiences as a "sex slave" in such detail that not even a tabloid newspaper that paid for it was willing to print all of the remarks she voluntarily made about her alleged experiences. See, e.g., Ex. C. Edwards and Cassell have also submitted numerous unsealed pleadings and declarations on behalf of Jane Doe No. 3 in the Federal Action that were available to the public (until Judge Marra appropriately struck those filings from the record as being lurid and impertinent). Jane Doe No. 3 made all of these voluntary statements as an adult, many years after she allegedly "escaped" from Epstein. She can hardly now say that such matters are so "personal" or "private" as to warrant an order from the Court that excuses her from testifying about facts within her personal knowledge. "When confidential information is sought from a non-party, the trial court must determine whether the requesting party establishes a need for the information that outweighs the privacy rights of the non-party." Westco, Inc. v. Scott Lewis' Gardening & Trimming, Inc., 26 So.3d 620, 622 (Fla. 4th DCA 2009). Assuming that the testimony and information sought in the subpoena is, in fact, "confidential" — a conclusion that is farfetched indeed given Jane Doe No. 3's penchant for discussing that information in the most public of ways, presumably for financial gain — Dershowitz has indisputably met his burden of establishing a need for that information. Dershowitz has no way to test the essential elements of Plaintiffs' defamation claim or certain of his affirmative defenses without questioning Jane Doe No. 3 about her false and outrageous allegations against him. Moreover, by publicly discussing her experiences as a "sex slave" in general and by naming some of the people who allegedly abused her, and describing others without yet naming 16 EFTA01099190 them, Jane Doe No. 3 has waived any right to withhold additional information on the same subjects based on "confidentiality" or "privacy." See Berkeley v. Eisen, 699 So. 2d 789, 791 (Fla. 4th DCA 1997) (voluntarily disclosing confidential information or otherwise taking "steps inconsistent with a reasonable expectation of privacy" results in a waiver of privacy rights). This is particularly true with respect to Jane Doe No. 3's diaries, portions of which have already been published online by the Daily Mail and are in the public domain. See Ex. E. It is also true of her photographs and travel records, some of which she has voluntarily disclosed. For these reasons, Jane Doe No. 3's reliance on Peisach v. Antuna, 539 So. 2d 544, 547 (Fla. 3d DCA 1989), is misplaced. In Peisach, the Third District held that an ex-husband in a post-divorce custody dispute was not entitled to depose his ex-wife's gynecologists because (1) those physicians were unlikely to have information about the ex-wife's migraine headaches, which was the specific condition the ex-husband contended interfered with the ex-wife's ability to care for the children; and (2) the ex-husband was already deposing the wife's neurologist, who was "far more likely to shed light on the subject of migraine headaches than any testimony from a gynecologist." Unlike in Peisach, there are no obvious alternative avenues to pursue to test the veracity of Jane Doe No. 3's allegations against Dershowitz. Moreover, there was no suggestion in Peisach that the ex-wife had voluntarily disclosed the substance of her consultations with her gynecologists or otherwise acted in a manner that was inconsistent with her privacy interests. In sum, there is no sound basis for excusing Jane Doe No. 3 from having to testify or produce documents in this action. Jane Doe No. 3, along with her lawyers, set in motion the events that led to this defamation action, and she should be compelled to submit to questioning and document production in accordance with Florida's broad parameters for discovery and pursuant to fundamental principles of fairness. Holding otherwise would insulate false accusers 17 EFTA01099191 from being tested by the adversarial process and would impede the ability of parties such as Dershowitz who seek to prove the falsity of outrageous allegations against them. This would constitute a fundamental violation of principles of justice and due process, and would encourage false accusations. HI. Jane Doe No. 3's requested limitations on the subpoena duces tecum are unfounded and should be denied. Jane Doe No. 3 alternatively argues that, if the Court does not quash the subpoena in its entirety, the Court should limit the scope of her document production. According to Jane Doe No. 3, the requests can be grouped into four objectionable categories: (1) documents that contain highly personal and sensitive information; (2) documents unrelated to this action; (3) documents that contain personal financial or other confidential information; and (4) "plainly privileged" communications between Jane Doe No. 3 and her lawyers. None of Jane Doe No. 3's objections have merit, and the Court should reject her request for a protective order. First, Jane Doe No. 3's arguments with respect to Categories I and 3 fail for the reasons discussed above. Having publicly and repeatedly discussed her purported experiences as a minor with Epstein (and allegedly with Dershowitz) — including to the point of volunteering details that not even a tabloid would publish — Jane Doe No. 3 can hardly claim these issues are confidential or private. Jane Doe No. 3's actions in this regard constitute a waiver of any legitimate privacy and confidentiality interests she may have had with respect to these subject matters. In any event, Dershowitz has established that his need for the information outweighs any privacy interests held by Jane Doe No. 3. Second, the so-called "Category 2" arguments represent another misguided attempt by Jane Doe No. 3 to contend that the subpoena seeks information that is not relevant to this action. Dershowitz is seeking documents and other materials that are relevant to the claims and defenses 18 EFTA01099192 in this action, as framed by the operative pleadings. In fact, it was Plaintiffs' improper filing of lurid statements about Dershowitz in the Federal Action that gave rise to this action. Jane Doe No. 3's attempt to distinguish the Federal Action as involving entirely "different" issues is unavailing. With respect to Category 4, the only information that Jane Doe No. 3 specifically identifies as being "plainly privileged" is the request for "All documents concerning your retention of the law firm Boies, Schiller & Flexner LLP, including but not limited to: signed letter of retainer, retention agreement, explanation of fees, and/or any documents describing the scope of retention." Contrary to Jane Doe No. 3's unsupported assertions of privilege, a retainer letter between a client and her attorney generally is not protected by the attorney-client privilege, nor is other information relating to the financial arrangements between the attorney and the client. See, e.g., Lainfinders Assocs., Inc. v. Legal Research Ctr., Inc., 193 F.3d 517, 518 (5th Cir. 1999) ("[T]he attorney-client privilege does not protect the type of information contained in the retainer letters."); United States v. Davis, 636 F.2d 1028, 1043-44 (5th Cir. 1981) (explaining that "[f]inancial transactions between the attorney and client, including the compensation paid by or on behalf of the client" generally are not protected by the attorney-client privilege). Even if the information Dershowitz seeks in Request No. 25 were deemed to be "confidential" as distinguished from privileged, Dershowitz's need for the information requested outweighs any privacy interests held by Jane Doe No. 3 in her financial dealings with lawyers. The timing of Jane Doe No. 3's retention of BSF is relevant to determining when Jane Doe No. 3 first raised allegations against Dershowitz and Plaintiffs' corresponding investigation into those allegations. 19 EFTA01099193 Likewise, as noted above, information about movie deals, book deals, or other financial arrangements that could give Jane Doe No. 3 and her lawyers an incentive to invent sensational allegations like those she has made against Dershowitz are directly relevant and highly probative of Jane Doe No. 3's credibility. Finally, and dispositively, any purported privilege for the financial relationship between Jane Doe No. 3 and BSF has plainly been waived. In particular, BSF has publicly stated that it is representing Jane Doe No. 3 on a pro bono basis, including in statements to The American Lawyer. See Ex. F. So too have Edwards and Cassell. In this way, Jane Doe No. 3 and BSF have sought an advantage by disclosing publicly the purported terms of BSF's engagement. Doing so works as a plain waiver of any privilege that might otherwise attach. E.g., Visual Scene, Inc. v. Pilkington Bros., PLC, 508 So. 2d 437, 440 (Fla. 3d DCA 1987) ("[V]oluntary disclosure to a third party of the privileged material, being inconsistent with the confidential relationship, waives the privilege."); First Union Nat'l Bank of Fla. v. Whitener, 715 So. 2d 979, 984 (Fla. 4th DCA 1998) (voluntary production of privileged information results in a waiver of privilege for all information on that same specific subject). The Court should order Jane Doe No. 3 to produce all documents that are responsive to the subpoena or, at a minimum, present those documents to the Court for in camera review. IV. The proposed "limitations" on Jane Doe No. 3's deposition are not reasonable. Jane Doe No. 3 also contends that if the Court is not prepared to excuse her from testifying altogether, the Court should issue a protective order that places the following extraordinary limitations on her deposition: (I) narrows the scope of testimony to preclude Dershowitz's counsel from pursuing certain lines of questioning; (2) includes a "cautionary notice" to Dershowitz's attorneys not to use derogatory terms in the deposition; (3) precludes 20 EFTA01099194 Dershowitz from being physically present for the deposition; and (4) requires the deposition to be taken at the offices of her counsel, BSF. None of Jane Doe No. 3's proposed modifications are warranted under Florida law. First, the proposed "limitations" on Jane Doe No. 3's questioning would unreasonably narrow the scope of the deposition. Jane Doe No. 3 requests that she not be asked any questions "about [her] experiences as a sexually trafficked minor"; "about individuals that she was sexually trafficked to"; "about any rapes that occurred when she was a minor child"; or "about anything related to her sexual activity either as a minor or thereafter." Motion to Quash, at 12. As set forth above, these issues are directly relevant to the issues in dispute in this litigation — namely, whether Dershowitz made the purportedly defamatory statements while knowing that the Joinder Motion was "well-founded." Moreover, Jane Doe No. 3 has provided first-hand, public accounts regarding these very topics on several different occasions, including in an on- the-record interview that was published by a widely read British tabloid and in which she included details that not even a tabloid would publish them. The obvious inference is that Jane Doe No. 3 received payment for her "exclusive interview" to the tabloids, and in all events she voluntarily spoke to the media about the same experiences as to which Dershowitz seeks discovery. She can hardly claim "embarrassment" as a reason not to give important evidence within her knowledge in light of her previous volunteered and detailed public accounts of her time as a "sex slave." These voluntary disclosures necessarily constitute, as a matter of law, a waiver of any assertion of privacy. See Berkeley, 699 So. 2d at 791. Second, Jane Doe No. 3 has not provided any support for her speculative assertions that Dershowitz's attorneys are likely to use harassing or derogatory language in a deposition, and the suggestion that they would do so insulting. The topics at issue (which Jane Doe No. 3 herself put 21 EFTA01099195 at issue) must be fully explored, but counsel for Dershowitz will of course treat the witness with courtesy and respect and will conduct the deposition in a manner that fully comports with the Florida Rules of Civil Procedure, as well as the Florida Rules of Professional Conduct. Moreover, it was she, through her lawyers, who made the most insulting and derogatory allegations against Dershowitz, which he has the right to challenge. As explained below, Dershowitz is concerned about the conduct of the deposition from the other side, namely whether Jane Doe No. 3's counsel will improperly instruct the witness not to answer or otherwise coach the witness. To avoid any problems, Dershowitz requests that the Court appoint a Special Magistrate to preside over the deposition pursuant to Rule 1.490(b) of the Florida Rules of Civil Procedure and handle any disputes that may arise during the course of the deposition.3 Third, the Court may not, as a matter of law, preclude Dershowitz from being physically present at the deposition of Jane Doe No. 3. "It is a venerated principle that a party has a right to be present at an oral deposition." Ferrigno v. Yoder, 495 So. 2d 886, 888 (Fla. 2d DCA 1986) (citing Cacace v. Associated Technicians, Inc., 144 So. 2d 82 (Fla. 3d DCA 1962) and further explaining that, although a court may properly exclude a party in some circumstances, that measure should be "ordered rarely indeed" because a party's right to be present at each stage of a lawsuit is "virtually sacrosanct" (internal quotation marks omitted)). Jane Doe No. 3's purported fear of being in close physical proximity to Dershowitz because he is an "incredibly powerful individual," Motion to Quash, at 5, is not the sort of "rare" circumstance that warrants an order precluding Dershowitz from attending the deposition in person. 3 The appointment of a Special Magistrate requires the consent of the parties. Accordingly, Dershowitz has asked counsel for Jane Doe No. 3 and counsel for Plaintiffs to consent to this request. That request is pending. 22 EFTA01099196 Dershowitz is 76 years old. He has been a professor (now emeritus) at Harvard Law School for decades and is a highly regarded attorney, who is bound to act and will act in accordance with professional standards, as he always has. Jane Doe No. 3 will be accompanied by counsel, as will Dershowitz. The notion that Jane Doe No. 3 is afraid to be in the same room with Dershowitz is a preposterous litigation tactic, and Dershowitz intends to challenge the truthfulness of that assertion if Jane Doe No. 3 makes it under oath. Moreover, the whole premise for Jane Doe No. 3's request (and many of the other limitations on discovery sought in the Motion to Quash) is that her allegations against Dershowitz are true. The Court cannot and must not accept that premise, which Dershowitz contests in the strongest possible terms. This is especially true in light of the fact that none of Jane Doe No. 3's allegations have ever been investigated or corroborated by any law enforcement or objective investigators, and at least some of her allegations — especially those involving former President Clinton and Vice President Gore — are preposterous on their face. Fourth, the Court should deny Jane Doe No. 3's request to conduct the deposition at the offices of her counsel, BSF. Because Jane Doe No. 3's lawyers refused to accept service of a subpoena and put Dershowitz to the trouble and expense of obtaining a commission and serving Jane Doe No. 3 in Colorado, Dershowitz could have insisted on taking the deposition in Colorado. Instead, the parties have agreed that Dershowitz will take the deposition of Jane Doe No. 3 in Florida. There is no reason that the deposition should not be taken at the office of the attorneys who noticed the deposition as is customary, absent agreement on some other mutually acceptable site in the Fort Lauderdale area. 23 EFTA01099197 REOUEST FOR APPOINTMENT OF SPECIAL MAGISTRATE As set forth above, Dershowitz respectfully requests that the Court appoint a Special Magistrate to preside over the deposition of Jane Doe No. 3. Rule 1.490(b) provides that "[t]he court may appoint members of The Florida Bar as special magistrates for any particular service required by the court, and they shall be governed by all the provisions of law and rules relating to magistrates except they shall not be required to make oath or give bond unless specifically required by the order appointing them." As noted previously, Dershowitz has asked counsel for Jane Doe No. 3 and counsel for Plaintiffs to consent to the appointment of a Special Magistrate. That request is pending. CONCLUSION The Court should deny the Motion to Quash because (1) the documents and testimony that Dershowitz seeks are relevant to this litigation; and (2) Dershowitz's need for this information clearly outweighs Jane Doe No. 3's privacy interests, which she has waived in any event given her voluntary statements to the press and the public about the very same issues. The Court also should deny Jane Doe No. 3's request for a protective order because the proposed modifications to the subpoena are not reasonable. The Court should also enter a reference pursuant to Rule 1.490 that appoints a Special Magistrate to preside over the deposition of Jane Doe No. 3. 24 EFTA01099198 Dated: May 15, 2015 Respectfully Submitted, s/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 [email protected] Steven R. Safra Florida Bar No. 057028 [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Richard A. Simpson (admitted pro hac vice) [email protected] Mary E. Borja (admitted pro hac vice) [email protected] Ashley E. Eiler (admitted pro hac vice) [email protected] WILEY REIN LLP 1776 K Street NW Counsel for Alan M. Dershowitz EFTA01099199 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E- mail on May 15, 2015 to: Jack Scarola, Esquire, Searcy Denny et al [email protected] and [email protected], counsel for Plaintiffs, and to Sigrid McCawley, Esquire, Boies Schiller & Flexner, counsel for Jane Doe No. 3, at [email protected]. COLE, SCOTT & KISSANE, P.A. Attorneys for Defendant 9150 S. Dadeland Blvd. Suite 1400 Miami, Florida 33156 [email protected] steven.safra @cskle al.com By: s/ Thomas E. Scott THOMAS E. SCOTT FBN: 149100 STEVEN R. SAFRA FBN: 057028 26 EFTA01099200 EXHIBIT A EFTA01099201 Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:08-CV-80736-ICAM JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. ORDER DENYING PETITIONERS' MOTION TO JOIN UNDER RULE 21 AND MOTION TO AMEND UNDER RULE 15 This cause is before the Court on Jane Doe 3 and Jane Doe 4's Corrected Motion Pursuant to Rule 21 for Joinder in Action ("Rule 21 Motion") (DE 280), and Jane Doe 1 and Jane Doe 2's Protective Motion Pursuant to Rule 15 to Amend Their Pleadings to Conform to Existing Evidence and to Add Jane Doe 3 and Jane Doe 4 as Petitioners ("Rule 15 Motion") (DE 311). Both motions are ripe for review. For the following reasons, the Court concludes that they should be denied. I. Background This is an action by two unnamed petitioners, Jane Doe I and Jane Doe 2, seeking to prosecute a claim under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771. (DE I). Generally, they allege that the respondent Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein, who subjected them to various sexual crimes while they were minors. (Id.). Petitioners initiated this action in July 2008. I([LO. EFTA01099202 Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 2 of 10 On December 30, 2014, two other unnamed victims, Jane Doe 3 and Jane Doe 4, moved to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280). Petitioners (Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. (LI. at 11). Jane Doe 3 and Jane Doe 4 argue that they "have suffered the same violations of their rights under the [CVRAJ as the" Petitioners, and they "desire to join in this action to vindicate their rights as well." ( at I). The Government vehemently opposes joinder under Rule 21. (DE 290). The Government argues that Rule 15 is the proper procedural device for adding parties to an action, not Rule 21. (a. at 1). "[O]ut of an abundance of caution," Petitioners filed a motion to amend their petition under Rule 15, conforming the petition to the evidence and adding Jane Doe 3 and Jane Doe 4 as petitioners. (DE 311 at 2). The Government opposes the Rule 15 Motion as well. (DE 314). Among other things, the Government argues that amending the petition to include Jane Doe 3 and Jane Doe 4 should be denied because of their undue delay in seeking to join the proceedings, and the undue prejudice that amendment will cause. (Id.). After considering the parties' submissions and the proposed amended petition, the Court finds that justice does not require amendment in this instance and exercises its discretion to deny the amendment. II. Discussion "The decision whether to grant leave to amend a complaint is within the sole discretion of the district court." Laurie v. Ala. Ct. Crim. Apps., 256 F.3d 1266, 1274 (11th Cir. 2001). "The court should freely give leave when justice so requires." Fed. R. Civ. P. 15(a)(2). Justice does not require amendment in several instances, "includ[ing] undue delay, bad faith, dilatory motive 2 EFTA01099203 Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 3 of 10 on the part of the movant, . . . undue prejudice to the opposing party by virtue of allowance of the amendment, [and] futility of amendment?" Laurie, 256 F.3d at 1274 (quoting Foman v. Davis, 371 U.S. 178, 182 (1962)). In addition to considering the effect of amendment on the parties, the court must consider 'The importance of the amendment on the proper determination of the merits of a dispute." 6 Wright & Miller, Fed. Prac. & Fed. P. § 1488, p. 814 (3d ed. 2010). Justice does not require amendment where the addition of parties with duplicative claims will not materially advance the resolution of the litigation on the merits. See Herring v. Delta Air Lines. Inc., 894 F.2d 1020, 1024 (9th Cir. 1989). A. Rule 21 Motion Jane Doe 3 and Jane Doe 4's first attempt to join in this proceeding was brought under Rule 21. (DE 280). "If parties seek to add a party under Rule 21, courts generally use the standard of Rule 15, governing amendments to pleadings, to determine whether to allow the addition." 12 Wright & Miller, Fed. Prac. & Fed. P., p. 432 (3d ed. 2013); see also Galustian v. Peter, 591 F.3d 724, 729-30 (4th Cir. 2010) (collecting cases and noting that Rule 15(a) applies to amendments seeking to add parties); Frank v. U.S. West. Inc., 3 F.3d 1357, 1365 (10th Cir. 1993) ("A motion to add a party is governed by Fed. R. Civ. P. 15(a) ...."). Rule 21, "Misjoinder and Non joinder of Parties," provides the court with a tool for correcting the "misjoinder" of parties that would otherwise result in dismissal. Fed. R. Civ. P. 21. Insofar as Rule 21 "relates to the addition of parties, it is intended to permit the bringing in of a person, who through inadvertence, mistake or for some other reason, had not been made a party and whose presence as a party is later found necessary or desirable." United States v. Com. Bank of N. Am., 31 F.R.D. 133, 135 (S.D.N.Y. 1962) (internal quotation marks omitted). 3 EFTA01099204 Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 4 of 10 In their Rule 21 Motion, Jane Doe 3 and Jane Doe 4 do not claim that they were omitted from this proceeding due to any "inadvertence" or "mistake" by Petitioners; rather, they seek to join this proceeding as parties that could have been permissively joined in the original petition under Rule 20 ("Permissive Joinder of Parties"). As courts generally use the standards of Rule 15 to evaluate such circumstances, the Court will consider the joinder issue as presented in the Rule 15 Motion.' The Court will consider the arguments presented in the Rule 21 Motion as if they are set forth in the Rule 15 Motion as well. Because the arguments are presented in the Rule 15 Motion (and because the Court is denying the Rule 15 Motion on its merits, as discussed below), the Rule 21 Motion will be denied. The Court also concludes that portions of the Rule 21 Motion and related filings should be stricken from the record. Pending for this Court's consideration is a Motion for Limited Intervention filed by Alan M. Dershowitz, who seeks to intervene to "strike the outrageous and impertinent allegations made against him and [to] request[] a show cause order to the attorneys that have made them." (DE 282 at 1). The Court has considered Mr. Dershowitz's arguments, but it finds that his intervention is unnecessary as Federal Rule of Civil Procedure 12(0 empowers the Court "on its own" to "strike from a pleading an insufficient defense or any redundant, immaterial, impertinent, or scandalous matter." Fed. R. Civ. P. 12(f). Petitioners' Rule 21 Motion consists of relatively little argumentation regarding why the Court should permit them to join in this action: they argue that (1) they were sexually abused by The Court notes that, regardless of which motion it considers, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 EFTA01099205 Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 5 of 10 Jeffrey Epstein, and (2) the Government violated their CVRA rights by concealing the non- prosecution agreement with them. (DE 280 at 3; see a at 7-8). However, the bulk of the Rule 21 Motion consists of copious factual details that Jane Doe 3 and Jane Doe 4 "would prove" "[i]f allowed to join this action." (a. at 3, 7). Specifically, Jane Doe 3 proffers that she could prove the circumstances under which a non-party introduced her to Mr. Epstein, and how Mr. Epstein sexually trafficked her to several high-profile non-party individuals, "including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders." ( at 3-6). She names several individuals, and she offers details about the type of sex acts performed and where they took place. id. at 5).1 At this juncture in the proceedings, these lurid details are unnecessary to the determination of whether Jane Doe 3 and Jane Doe 4 should be permitted to join Petitioners' 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 immaterial and impertinent to this central claim (i.e., that they were known victims of Mr. Epstein and the Government owed them CVRA duties), especially considering that these details involve non-parties who are not related to the respondent Government. These unnecessary details shall be stricken. The original Rule 21 Motion (DE 279) shall be stricken in its entirety, as it is wholly superseded by the "corrected" version of the Rule 21 Motion (DE 280). From the corrected Rule 21 Motion, the Court shall strike all factual details regarding Jane Doe 3 between the following sentences: "The Government then concealed from Jane Doe #3 the existence of its NPA from 2 Jane Doe 4's proffer is limited to sexual acts between Mr. Epstein and herself. (See DE 280 at 7-8). 5 EFTA01099206 Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 6 of 10 Jane Doe #3, in violation of her rights under the CVRA" L at 3); and "The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it listed her as a victim in the attachment to the NPA" (E:l. at 6). As none of Jane Doe 4's factual details relate to non-parties, the Court finds it unnecessary to strike the portion of the Rule 21 Motion related to her circumstances. Regarding the Declaration in support of Petitioners' response to Mr. Dershowitz's motion to intervene (DE 291-1), the Court shall strike paragraphs 4, 5, 7, 11, 13, 15, 19 through 53, and 59, as they contain impertinent details regarding non-parties. Regarding the Declaration of Jane Doe 3 in support of the Rule 21 Motion (DE 310-1), the Court shall strike paragraphs 7 through 12, 16, 39, and 49, as they contain impertinent details regarding non- parties. Jane Doe 3 is free to reassert these factual details through proper evidentiary proof, should Petitioners demonstrate a good faith basis for believing that such details are pertinent to a matter presented for the Court's consideration. As mentioned, Mr. Dershowitz moves to intervene "for the limited purposes of moving to strike the outrageous and impertinent allegations made against him and requesting a show cause order to the attorneys that have made them." (DE 282 at 1). As the Court has taken it upon itself to strike the impertinent factual details from the Rule 21 Motion and related filings, the Court concludes that Mr. Derschowitz's intervention in this case is unnecessary. Accordingly, his motion to intervene will be denied as moot.' Regarding whether a show cause order should This also moots Mr. Dershowitz's Motion for Leave to File Supplemental Reply in Support of Motion for Limited Intervention. (DE 317). Denying Mr. Dershowitz's motion to intervene also renders moot Petitioners' motion (DE 292) to file a sealed document supporting its response to Mr. Dershowitz's motion. It will accordingly be denied as moot, and DE 293 (the sealed response) will be stricken from the record. 6 EFTA01099207 Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 7 of 10 issue, the Court finds that its action of striking the lurid details from Petitioners' submissions is sanction enough. However, the Court cautions that all counsel are subject to Rule 11's mandate that all submissions be presented for a proper purpose and factual contentions have evidentiary support, Fed. R. Civ. P. 11(b)(1) and (3), and that the Court may, on its own, strike from any pleading "any redundant, immaterial, impertinent, or scandalous matter," Fed. R. Civ. P. 12(f). B. Rule 15 Motion Between their two motions (the Rule 21 Motion and Rule 15 Motion), Jane Doe 3 and Jane Doe 4 assert that "they desire to join in this action to vindicate their rights [under the CVRA] as well." (DE 280 at 1). Although Petitioners already seek the invalidation of Mr. Epstein's non-prosecution agreement on behalf of all "other similarly-situated victims" (DE 189 at 1; DE 311 at 2, 12, 15, 18-19), Jane Doe 3 and Jane Doe 4 argue that they should be fellow travelers in this pursuit, lest they "be forced to file a separate suit raising their claims" resulting in "duplicative litigation" (DE 280 at 11). The Court finds that justice does not require adding new parties this late in the proceedings who will raise claims that are admittedly "duplicative" of the claims already presented by Petitioners. The Does' submissions demonstrate that it is entirely unnecessary for Jane Doe 3 and Jane Doe 4 to proceed as parties in this action, rather than as fact witnesses available to offer relevant, admissible, and non-cumulative testimony. (See, e.g., DE 280 at 2 (Jane Doe 3 and Jane Doe 4 "are in many respects similarly situated to the current victims"), 9 ("The new victims will establish at trial that the Government violated their CVRA rights in the same way as it violated the rights of the other victims."), 10 (Jane Doe 3 and Jane Doe 4 "will simply join in motions that the current victims were going to file in any event."), 11 (litigating Jane Doe 3 and 7 EFTA01099208 Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 8 of 10 Jane Doe 4's claims would be "duplicative"); DE 298 at 1 n.1 ("As promised ... Jane Doe No. 3 and Jane Doe No. 4 do not seek to expand the number of pleadings filed in this case. If allowed to join this action, they would simply support the pleadings already being filed by Jane Doe No. 1 and Jane Doe No. 2."); DE 311 at 5 n.3 ("[A]ll four victims (represented by the same legal counsel) intend to coordinate efforts and avoid duplicative pleadings."), 15 (Jane Doe 3 and Jane Doe 4 "challenge the same secret agreement i.e., the NPA that the Government executed with Epstein and then concealed from the victims. This is made clear by the proposed amendment itself, in which all four victims simply allege the same general facts.")). As the Does argue at length in their Rule 15 Motion, Jane Doe 1's original petition "specifically allege[s] that the Government was violating not only her rights but the rights of other similarly-situated victims." (DE 311 at 2). The Court fails to see why the addition of "other similarly-situated victims" is now necessary to "vindicate their rights as well." (DE 280 at 1). Of course, Jane Doe 3 and Jane Doe 4 can participate in this litigated effort to vindicate the rights of similarly situated victims there is no requirement that the evidentiary proof submitted in this case come only from the named parties. Petitioners point out as much, noting that, regardless of whether this Court grants the Rule 15 Motion, "they will call Jane Doe No. 3 as a witness at any trial." (DE 311 at 17 n.7). The necessary "participation" of Jane Doe 3 and Jane Doe 4 in this case can be satisfied by offering their properly supported and relevant, admissible, and non-cumulative testimony as needed, whether through testimony at trial see DE 280 at 9) or affidavits submitted to support the relevancy of discovery requests° see The non-party Jane Does clearly understand how to submit affidavits. (See DEs 291-1, 310-1). 8 EFTA01099209 Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 9 of 10 id. at 10). Petitioners do not contend that Jane Doe 3 and Jane Doe 4's "participation in this case" can only be achieved by listing them as parties. As it stands under the original petition, the merits of this case will be decided based on a determination of whether the Government violated the rights of Jane Doe 1, Jane Doe 2, and all "other similarly situated victims" under the CVRA. Jane Doe 3 and Jane Doe 4 may offer relevant, admissible, and non-cumulative evidence that advances that determination, but their participation as listed parties is not necessary in that regard. See Herring, 894 F.2d at 1024 (District court did not abuse its discretion by denying amendment where "addition of more plaintiffs . . . would not have affected the issues underlying the grant of summary judgment."); cf. Arthur v. Stern, 2008 WL 2620116, at *7 (S.D. Tex. 2008) (Under Rule 15, "courts have held that leave to amend to assert a claim already at issue in [another lawsuit] should not be granted if the same parties are involved, the same substantive claim is raised, and the same relief is sought.").5 And, as to Jane Doe 4 at least, adding her as a party raises unnecessary questions about whether she is a proper party to this action.6 Petitioners also admit that amending the petition to conform to the evidence by including references to the non-prosecution agreement itself is "unnecessary" as the "existing petition is broad enough to cover the developing evidence in this case." (DE 311). The Court s The Court expresses no opinion at this time whether any of the attestations made by Jane Doe 3 and Jane Doe 4 in support of their motion will be relevant, admissible, and non- cumulative. 6 The Government contends that Jane Doe 4 is not a true "victim" in this case because she was not known at the time the Government negotiated the non-prosecution agreement, and accordingly she was not entitled to notification rights under the CVRA. (See DE 290 at 10). Any "duplicative" litigation filed by Jane Doe 4 would necessarily raise the issue of whether she has standing under the CVRA under these circumstances. 9 EFTA01099210 Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 10 of 10 agrees, and it concludes that justice does not require amending the petition this late in the proceedings. III. Conclusion Accordingly, it is hereby ORDERED AND ADJUDGED as follows: the Rule 21 Motion (DE 280) is DENIED; the Rule 15 Motion (DE 311) is DENIED; Intervenor Dershowitz's Motion for Limited Intervention (DE 282) and Motion for Leave to File Supplemental Reply in Support of Motion for Limited Intervention (DE 317) are DENIED AS MOOT; Petitioners' Motion to Seal (DE 292) is DENIED AS MOOT; the following materials are hereby STRICKEN from the record: • DE 279, in its entirety. • DE 280, all sentences between the following sentences: "The Government then concealed from Jane Doe #3 the existence of its NPA from Jane Doe #3, in violation of her rights under the CVRA" (DE 280 at 3); and "The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it listed her as a victim in the attachment to the NPA" (DE 280 at 6). • DE 291-1, paragraphs 4, 5, 7, 11, 13, 15, 19 through 53, and 59. • DE 310-1, paragraphs 7 through 12, 16, 39, and 49. • DE 293, in its entirety. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 61° day of April, 2015. KENNETH A. MARRA United States District Judge 10 EFTA01099211 EXHIBIT B EFTA01099212 912/2015 Hurnan Trafficking Caliber-10' Tte Pain BeaCheS I Facebock 'nail or Phone Password Keep me logged in Human Trafficking Coalition Of The Palm Beaches is on Facebook. Forgot yourpeasword? Log In To connect with Human Trafficking Coalition Of The Palm Beaches. sign up for Facebook today. L_1 1 1 Human Trafficking Coalition Of The Palm Beaches 111 Community Organization PEOPLE ABOUT Timeline About Photos Likes Videos 303 likes the Human Trani/long Coalition of the Palm Beaches (H 7CPB) is a coalition of concerned individuals from agencies. organizations. and commvnity members.... READ MORE http imnverJ7tcpb.orgi PHOTOS r'r.) I GC Human Trafficking Coalition Of The Palm Beaches via sec= Lauren's Kids 1 hr • Statewide Teachers' Institute Gives South Florida Teachers Training in Child Safety Curriculum -... - Teachers from salami-Dade. Broward and surrounding counties team to leach child abuse prevention Molls with help from Lauren's Kids - TALLAHASSEE. Fla. Like • Comment • Share Todd Shoemaker likes this. H T Human Trafficking Coalition Of The Palm Beaches mixtal shared Jordan Garnett's photo. 9 hrs • Another missing child._ Boynton Beach. Nips /AvvAv facebookiccadpagesdiurnan- Trafficking-Coalition0f-The Palm -BeaChEs/145953982139669 1/12 EFTA01099213 5/12/2015 Hunan Trafficking Coaliticn O' The Palm Meades Facebock brabolGomos IF January 4 at 5.13pm http.i.tn.whitehouso.govere-press- ace/2014/12/3i tproclamaton-natonal-slavery-and- human-trafIcking-prevenson-rtionin-291 Like • Comment • Share UKED EY TIRS PAGE Polaris irs--0 Fair Trade Certified 1 1" ‘ /\ Friends of Foster Children of Palm ... 9C English (US) • Privacy • Terms Cookies Advertising • Ad Choices. • More Facebook G 2015 KAITLANSARSRALL 14 YEARS OLD 0 Ban BEACH. Ft MISSING SINCE 5/3 PLEASECONTAC HIRATIFIER IF YOU HAVE ANY IDEA WHERESHE MAY BE 561.904-1799 Jordan Garnett FACEBOOK FAMILIMI I realty need everyone's help, A lankly friend of ours has gone mssing.She was iASI seenbeard from on May 3rd, Her name is Ka 'land Marsh.. See More Like • Comment • Share HT Human Trafficking Coalition Of The Palm Beaches El= shared a photo. 9 hrs • Another missing chili.. West Palm Beach. Comrrents 19,.'a ta. ChWIOCIe• now ar4 on:soy:N.1 please a Sell DIO•fr troryine rase Yap fr, fray inn, nyrs 1.1, w Intact maw urger • MOT la . "or last teee ems tswe •0rInants heal:010 Pabero 4.arlowts it '7 at..• 1 o' Wou -ear 0' "eirreq skate Cal int WM/ ....cc tio>01 ier ,-a+ sun xarrg log vs sae Won Nikki Carter URGENT Ok b we repost Foolishness all the tme._someeoeys baby is missing. Let's join together and bring him home. He went missing last night at about 91... See More Like • Comment Share HT Human Trafficking Coalition Of Tho Palm Beaches shared TOLE- Florida Department of Law Enforcement's photo. 9 ha • https thyme facebook ccadpages'Hisnan-Trafficking-Coalition-Of-ThePalm-Beachestit5953982139669 2/12 EFTA01099214 5012.12C15 Human Traffick ng CosMien O' The Palm Beaches I Facabock I reel like I lust keep sharing missing children. Its so sad to me how many children go missing per year. Please share and keep an eye for this little one. FDLE - Florida Department of Law Enforcement Pi mi-Dade Pt) asked us to share ihis informaton about Isabella Fernandez who has been missing since yesterday May 7. Please share this post, Miamr-Dade See More Like • Comment • Share Todd Shoemaker likes This. 81 Human Trafficking Coalition Of The Palm Beaches MrMI shared Crystal Lee Evans's post. May 10 at 424pm • FOUND! a Oak ra ay. ••••••• Yogi 4 crystal Lee Evans added 30 new photos —cc.‘)feeeng thankful with Jackie Smith and 17 others. I just want you all to know that my daughter was found safe and C will be home soon. I also want to thank all of you ner helping us look for her. I would love See More Like • Comment Human Trafficking Coalibon Of The Palm Beaches. Elizabeth Bennett Clawson, Mips/Amy/ facebook.ccrh/pageslitrnan-Trafficking-Coalikoff Of-The Palm-Beaches/1459539821 3/12 EFTA01099215 5/12/2015 Human Trafficking CoditicnOi The Palm Beaches I Facebook Rogers Clawson and 4 others like this. HT Human Trafficking Coalition 01 The Palm Beaches min May 9 a: 07pni • Missing from Palm Beach Gardens!!! IONAL Have you seen this child? HANNAH TIER FOR ZARZA Missing From: PALM BEACH GARDENS. FL. Missing i ssiNG Date. OSA5r2015. Hannah may sti be in the local CPLOITE area or she may travel to Hollywood. Florida. Her nose is pierced and she has gauges in her ears. H I LDRE'"'"" Like • Comment Share Human fralicking Coalition Of The Palm Beaches and Todd Shoemaker like this. HT Human Trafficking Coalition 01 The Palm Beaches via Human Trafficking Awareness USA May 9 at S:2Sam • Like • Comment • Share Detective Segura of the SAPD's Vice Unit speaks on the Speaks on tie public issues of human trafficking and how it destroys the lives of those it seeds. m... Human Trafficking Coalffion Of The Palm Beaches likes this. wr Human Trafficking Coalition Of The Palm Beaches = EN May 8 at 6 58am • Mother sais to not have previous legal problems httpllwww.palmbeachpost.conV /cops-morn-traded-11-ye fnkclOm/ Cops: Mom traded 1-year-old for sex to get heroin Mother sais to not have previous legal problems ViMNItattLMBEACHPOST.COM Like • Comment Share H T Human Trafficking Coalition Of The Palm Beaches via a ' a' Rescue Upstream Maya alb loam • Protecting children takes a community-wide effort. 021..'s Stewards of Children, approaching one million trained nationvride, shows you how chid Ittcsliwwwfacetookcom/pages/Human-Trafficking-CoalitiorrOf-The Palm -Beaches/145953982139669 4/12 EFTA01099216 Like • Comment Snare 5/12/2015 Human Trafficking Coalition Of The Palm Beaches I Facebook sexual abuse can be prevented and stopped. This program gives adults the tools to keep kids safe. The next Stewards of Children community training will be held on Saturday, May 16th. from 9:30-11:30 am. at Journey Church West. 6201 S. Military Trail, Lake Worth. The cost is 512.00 (payable by cash or check at the training) and includes an Interactive Workbook For more information or to RSVP contact us at [email protected]. Stewards of Children -'[bailer YOMUESE.001/ Todd Shoemaker likes this. III Human Trafficking Coalition Of The Palm Beaches via asCBS 12 News May 8 at 4.12am • Please share MISSING SISTE Two girls missing overnight : 9 and 13-years-old Isabela and Michelle Fernandez were last seen walking. Police think the girls— CBS12.COM I BY SINCLAIR BROADCAST GROUP Like • Comment • Share Teresa Nightingale, Todd Shoemaker and Rogers Clawson like this. 34 snares H T Human Trafficking Coalition Of The Palm Beaches via CBS 12 News May? at 923pm Video shows 13-year-old girl fighting off sexual predator hors //www facebook com/pages'Hurnan-Trafficking-Coalitico0f-The-Palm-Beathea/145953962136039 5/12 EFTA01099217 5/12/2015 Human Trafficking Coaliticn C:e The Palm Beaches I Facebook inside her home SAN JOSE. Calif. —A brave 13-year-okl gkl saved Imam life from e sexual— CBS12.COM l By siNclAIR BROADCAST GROUP Like • Comment - Share Rona Heymann. Susan Rogers Da Isle and 2 others like this. A t - Todd Shoemaker VVow!Glad she is safe. 2 May 8 al 4 16am W it Human Trafficking Coalition Of The Palm Beaches a shared Truckers Against trafficking's post. May 6 at 6 Siam • PLEASE SHARE! Truckers Against Trafficking added 2 new photos. Boys are trafficked too. PLEASE SHARE Warren is 16 and missing out of Everglades National Park. Fonda and has been calegonzed as a Iffigh Risk Child (HRC) See More Like • Comment Haley Marguenle. Susan Rogers Daigle. Judie" Hinsch and 4 others like this. WE Human Trafficking Coalition Of The Palm Beaches rs=2 May 4 at 10 15pm - This is a telling video... Nips /Avww facebookccm/pageseiuman- Trafficking-Coalition-Of-The. Palm -Sextiss/lt595.398211066, 6112 EFTA01099218 912/2015 Human Trafficking Coalition Of The Palm Beaches I Face:bock Man Lures Children Away From Playground in Chilling Social Experiment As a parent, you by to teach your child about safety and how Important it is to avoid strangers, but are they listening? Do they realy gel it? Every parents worst... POPSUGAR.COM I BY ALSSIA SAN1000 Like • Comment • Share Rogers Clawson hkes this. H T Human Trafficking Coalition Of The Palm Beaches IS= shared Office for Victims of Crime's photo. April 30 at 4 55am • Office for Victims of Crime FU 'ING OPPORTUNITY gOVOILm0100 Opportunity We wl make awards of up ^.o 4600.000 to enhance the quality and quantity of specialized services available to assist victims of hum_ See More Like • Comment Share W I Human Trafficking Coalition Of The Palm Beaches - shared Human Trafficking Awareness USA's photo. fass April 30 at a 50am • We posted this a few weeks back after It was seen in Oklahoma... Now in Florida... Iltps://www.facebookcom/pmeselitrnan-Trafficking-Coalition-Of-The-Palm-Beachcs/145953982139659 7/12 EFTA01099219 5/12/2C15 Human Traffick ng Coalition &The Palm Beaches I Facebook RN JOBS la 5190 Saall WI litlY NAatraa Fume ritaVIIII2 an it a %MT MAXIMS HIDDEN REAT Human Trafficking Awareness USA FLORIDA: (VIDEO) - New warning about Sex Trafficking in Florida PARENTS BEWARE -A new warning for parents about a possible scam aimed al recruiting teens into — See More Like • Comment • Share IN T Human Trafficking Coalition Of The Palm Beaches via WPBF 25 News April 29 at 8 agpm • Delray Beach police search for man suspected of lurking around children Delray Beach poke say they are looking for a man who was reported lurking near... VtiMii.l5PErF.COM I BY TERRI PARKER Like • Comment • Share Todd Shoemaker likes this. HT Human Trafficking Coalition Of The Palm Beaches via m Truckers Against Trafficking April 29 at t 21 pm • One of the most important rules of the pimping game is revealed in a book that's on the required-reading list for many Orange County vice squads and prosecutors. "Most (prostitutes) have low self-esteem for a reason." observes pimp- turned-author Ken I. 'A pimp looks for that weakness.... Then he uses those weaknesses to his advantage. Weakness is the best trait a person can find in someone they want to control. It you can't find a weakness, you have to create one. You have t... See More https /Mww facebookcctrn/pagesliuman-Trafficking-CpalitionOf-The-Palm-BeachiEs/tg.5953982139669 8/12 EFTA01099220 S'12/2C15 Hunan Trafick ng Co.lificng The Palm Beaches I Facebook Throwing the book at pimps One of the most important rules of the pimping game Is revealed in a book MASTS— OCREGISTER COP Like Comment Share Rosalie Weiss Almborg and Arlene Davidson like this. HT Human Trafficking Coalition Of The Palm Beaches a• shared Human Trafficking Awareness USA's photo. April 29 at 3 16am • HomANTRAcFiCI0NG ARRESTS )12y714Wai I Kalb 0.-Ot Human Trafficking Awareness USA DADE COUNTY. FL (VIDEO) - Man and Woman Charged in Sex Trafficking of Teen. Woman. klianv-Dade Police A Monk-Dade man and woman are thong Human TraMclung ch... See More Like • Comment Share Erin Greer likes this. H T Human Trafficking Coalition Of The Palm Beaches via a Rescue Upstream Inn April 27 812 32pm • Watch this short new video and learn about human trafficking in its different forms. As awareness around this issue grows. so does our abilty to fight it. Spread the word by sharing this with your friends and ferny. Human Trafficking: It Happens Here Although slavery n commonly thought to be a thing of the past human trafficking shit exists today throughout the United States and globally. Human traffic... you 1 WIt.CO/I Like • Comment - Share Human Trafficking Coaliben Of The Palm Beaches. Edn Greer and Todd Shoemaker ke this. 2 shares https //www fasebook.ccm/pagesel-Rrnan- Trafficking-Coalition-Of-The Palm-Beaches/1‘59539.92139669 W12 EFTA01099221 5/12/2015 Human Trafficking Coati= O' The Pam Beaches I Facet:took aT Human Trafficking Coalition Of The Palm Beaches shared Truckers Against Trafficking's photo. April 27 at 7:04am • NOTHING HAPPENS JUST BECAUSE WE ARE AWARE OF MODERN-DAY SLAVERY. BUT Nan iNc n f1 [yr) !inp:[-N UNTIE. Apr." -CAP'Y HAUQI-N- te% and www. Tru(kersAgainstTralkicken ors Truckers Against Trafficking Just a little Monday Motivation for you! Learn about it. Tell ohers about Then get Make the call. save Wes' 1488-3737-888 Like • Comment • Share eyed in combating A Human Trekking Coalition Of The Palm Beaches, Nicole Monnin, Arlene Davidson and 3 others like this. EARLIER IN 2015 M T Human Trafficking Coalition Of The Palm Beaches via a CBS 12 News Apnl 23 at 3 57am • Registered sex offender steals school bus, tries to pick up children; police EMERY COUNTY. Utah—KUTV Police arrested a registered sex offender C8512.COM I BY SINCLAIR m000cAsT GROUP Like • Comment • Share https /Avww facebook.ccm/pagesliumao Trafficki ng-Coalition- Of-The Palm-Beaches/145953962139339 10112 EFTA01099222 5/12t2015 Hunan Trafficking Coalition Of The Palm Beaches I Facebock Human Trafficking Coalibon Of The Palm Beaches and Erin Greer like this. I share HT Human Trafficking Coalition Of The Palm Beaches April 21 al 10 Slam • Brad EctwardsnArginia Roberts Story: ABC airing of the [REDACTED] interview — This Thursday, April 23. during GMA 7 am —9am (don't have specific lime yet). Thursday night on World News at 6:30 Thursday night on Nigh tine after Jimmy Kimmel at 12:35 am. Again on Friday on GMA. Hope you will all be able to tune-in! Like • Comment Human Trafficking Coalition Of The Palm Beaches likes this. I share WI Human Trafficking Coalition Of The Palm Beaches cc= Ap I 21 at 13.55am • CNN: Senate Majority Leader Mitch McConnel announced today that negotiators had reached a bipartisan deal on a bill to fight human trafficking. clearing the way for a vote to confirm attorney general nominee Loretta Lynch "hopefuly in the next day or so." Like • Comment Human Tralaing Coalition Of The Palm Beaches and Elizabeth Bennett Clawson Ike this. 2 shares w r Human Trafficking Coalition Of The Palm Beaches a shared Human Trafficking Awareness USA's photo. April 21 at 3 4 I am • *e V tc I Seeking Information his UNKNOWN INDIVIDUAL Human Trafficking Awareness USA FROM Doel of Justice fill Needs Your Help - John Doe a 28 Images relevant le the 'rives:Tipton include those depicting the 'kilned and the Child Victim inside a... See More Like • Comment - Share Human Trekking Coalition Of The Palm Beaches, Todd Shoemaker and Christine Parsley like this. Mrs/Airs/Ay facet ook ccrm/pagesdiuman-Trafficking-Coalition-Of-ThePalm-Beaches/1&5953982139669 11/12 EFTA01099223 912/2015 Hunan Trafficking Coalition Of Tte Palm Beaches I Facebock HT ItSE Human Trafficking Coalition Of The Palm Beaches shared a link- April 17 alb 1 gam • Sex Trafficking: Should All Perpetrators Be Sentenced As Sex Offenders? When tarsi began anti-tracking advocacy in 2009.I believed any person convicted of human traffilting should face mandatory sentences. inducting registration as a— Like • Comment • Share Human Trafficking Coalition CI The Palm Beaches likes this. 1 share HT Trafficking Coalition Of The Palm Beaches via A Human Trafficking Awareness USA April 16 al 3:61am • Human Sex Trafficking Overview YOUTVBE.COM Like • Comment Share Teresa NightingaleIkeaHs. 2 shares See More Stories • Sign Up Login Messenger Mobile Find Friends Badges People Pages Places Games Locations About Create AO Create Page Developers Careers Privacy Cookies Ad Choices t> Terms Help Fay*** 02015 English (US) httpslAwAv.facebookeantmesliunan-Trafficking-Coalition-0f-The-Palm-Beaches/145953982133669 12/12 EFTA01099224 EXHIBIT C EFTA01099225 Prince Andrew and gut 17, wig sex offender friend 'ere to Britain to meet him i Daily Mail Online Feedback Polar (pEaDOnUn• Monday, Apr 20th 2015 - TVF . GAT 5-Day rOft`C.,, l DailyinctO Home I U.K. Latest hoodlums Sports I U.S. Showbiz I Australia I Femall I Health I Science I Money I Video I Travel I Columnists AA. •iera Mon Pktuteir Most teat Ness Searo Vane has Prince Andrew and the 17-year-old girl his sex offender friend flew to Britain to meet him Fiy CHURCHER UPDATED: DEMIST. 2 March 2011 101 Vsow corrrnare • [REDACTED] 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. Bud those quallies 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 solcibng underage prostitutes. appeared last weekend. Today. however, even more serious doubts are cast on his suitabilty after a woman at the centre of the Epstein case revealed to The Mail on Sunday that she had, as a 17-yearold employed by Eosin!, been Sown across the world to be introduced to the Prince, Woe Enter your search http://wwwdaitymail.colk/nays/article-1361039/Prince-Arctew-grl-17-sez-offerder-friend.flew-Brilain-meet-rim html EFTA01099226 Prince Andrew and gal, 17. who sex offender friend new to Elritan to meet him I Daily Mail Online First meeting: Prints Andrew puts It inns arounc111-year-old Virginia. centre On one of those occasions [REDACTED] was subsequently paid 415,000 (E9,400). Her shocking account of her four years as Epstein's personal masseuse is supported by court documents. an eyewitness, photographs and fight 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 rs not the first time the Duke of York's judgment and choice of associates have been questioned. He appears to relsh the company of super-rich of blionaires from the Middle East. North Africa and the former Soviet Union. The peculiar sale of his former marital home to a Kazakh businessman for E15 million after it had languished unsold for five years at E12 million has never been satisfactorily explained. In the recent leak of American diplomatic cables it was revealed that he had crittised an official corruption investigation into the huge AI-Y amarnah arms deal between Britain and Saudi Arabia. while he Is also said to be close to Sall AI-Islam Gaddafi. son of the beleaguered Libyan president. and may have had a role in the early release of Locker-be bomber Abdenaset Al Megrahi. But it is Andrew's friendship with Epstein. whom he has known since at least 2000, and with Epsten's confidante Ghislane Maxwell. daughter of the late disgraced newspaper baron Robert Maxwell. that gives most concern. He was first seen with the pair on holiday in Thailand. and was pictured cavorting with Ghislaine at a Halloween fenstithemed 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 Alen. al 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 n 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 While on the streets, I slept with men for money. I was a paedophile's dream ANN TAYLOR 50 % EVERYTHING! FREE SHIPPING! SHOP NOW+ Uke Dab Vail Foto. I any Ilan FEMAIL TODAY Bruce Jenner inns • sports bra on motorcycle cruise whb recovering from surgery m Id gender Ira es Idea Ahead of his interview win Dane Sawyer 'Robert De Nko wa s rat C' nolo and Ertc Roberts was a monster and spt in my taco': 'Cursed' Nadel Hemingway dishes on the mon who hit on her Need a holiday? Angelina Jobe loots a title stressed as she takes the children to vest Brad Pitt onset Recently had surgery lo prevent cancer Roseanne Barr.82, reveab she is slow*/ going bird from Mac Air degeneration and gleesome but says marque& helps rake. symptoms Spat! Aria na Grande and 84 Sean break up aver only elgM months of dating The Love Me Harder crooner, 21, and tie rapper. 27. are over Harry Connick Jr. tics and a baby-laced teenager wflo coup be ❑ie nest !Latin Bieber. View we're In love WM. American Idol Sponsored http://inww.daymail.co.vk/natis/arbcle13610391Prince-Ardrew.g rl-17-sex-offender-friendflew-Britain-mee-him.hfrnl EFTA01099227 Prince Andrew and girt. 17, vino sex offender friend fen to Britain to meet tam I Daily Mal Online sentence for offences relating to mild prostitution. However, he avoided tnal an more serious charges that caned a potential We sentence. And no one reading The Mail on Sunday's interview with the woman who was prepared to test ly against hm can be in any doubt of the seriousness of the charges. Epstein. a Wall Street money manager who once counted Bill Clinton and Donald Trump among his friends. became the subjed of an undercover investigation in 2005 after the stepmother of a 10-year Old girl claimed she was pad 5200 (f 125) to give him an 'erotic massage' true subsecuent FBI probe uncovered at least 20 girls levelling sexual allegations against him Eventually. Epstein struck a 'plea bargain' with prosecutors - a practice net permitted under British law- under Wirth he was allowed 10 plead gully to two relatively mina charges. Pelee claim that his donations to plebeians and his 'dream team of inluential lawyers deterred prosecutors from bringrig niece serious charges of sex-traftickng. The deal cenainly kept the names of a lot of Epstein's famous friends out of an embarrassing mud case However. an unusual part of the agreement was that Epstein's alleged vidsms were alowed to bring civil proceedings against him. He has so far made 17 ouleof-oour1 settlements. and some cases are ongoing One of these girls 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 moil writ against him. under he pseudonym Jane Doe 102' she alleged thal her duties included bang sexually exploited Cy Epstein's adult male peers indudng royalty. Now, horrified by the evidence of Epstein and Andrew enjoying each other's company in New York. Jane Doe 102 has agreed to waive her ancerrymity and tell for the fest tine her deeply dislurtwig story. Her real name e Vrgina Roberts and she now lives in Australia, where she is a rupee/ married mother of three. over the COWSe of a week during which she spoke at length In The Nail on Sunday she appeared sometimes vulnerable. and sometimes steely. bun annoys guiety resolute and consistent Revisiting events from a past that she had hoped she had left behnd.Vergnia occasionally but e-d her Late in tier hands Some recolectains - and. kir reasons of taste, not all the detals can be included here - caused her to flush with shame 'I'm !cling you things that even rry husband didn't know, she sad. Virginia, who has undergone counselling to try to come to terms wen her past, is honest about her initiation into Epsten's depraved world. She was a troubled teenager, whose sender figure. delicate complexion hesitant voice and SOurful blue eyes made her look young for her years. Born in Saaarrento. California. in August 1983 Virginia spent her early years cn a small ranch on the West Coast of America. This seemingly idyllic childhood ended when she was serumly molested oy a man close to ner family The fallout ;tom that led to her parents tenporanty splitting up. Blaming herself. Virgin a began to gel Into trouble Aged 11, she was sent to we with an ant but Tpeatedly ran away. Living on the streets. she was beaten up and slept with at least two older men in retun for food. was a psedopiSe's dream.' she says. Three years later, she was reunited with her 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. Mara-Logo. Virginia got a part tale job at a changing room assistant -which is where. soon after her 15th birthday. She met Gnisiaine Maxweii, who invited her to work as Epstein's personal masseuse 'I was weanng my uniform - a while insIrSkrt and a skin-bght vale° polo top - wren I was approached by Ghislane: Virginia says. *I told her I warted to become a masseuse and she sad she worked for a very wealthy gentleman who was looking for a traversing masseuse. I'd gel trailing and tie paid well. Virginia's lather gave his LieSSalgl. beleving he daughter was being handed the opportunity to learn a skit and to work for a wealthy and respectable employee He drove her to Epstein's pnk rnarsion on the Palm Beach waterfront - he also aims a nne-storey home in New York, the city's biggest private residence a 7.500-acre ranch caled Zorro' in New Mexico and Little Saint James, a private 70- acre atoll in the US Virgin Islands A now We: Wet saws matherettariar Australia That Ionics a Moard. Sten...fated hick. Mrrial •volas Wok ire el Bayonet as they watch Orate onstage at Coaches' She dem show any row Troubled baseball star :van tiarroiROn files for divorce from Real Housewives tf Orange County accuse Katie hallowing he drug elapse Rise of Kyrie Janney Ao It year oil poste n a sheer lasaysok at Coachella with rawer boyfriend Tyga, is she set to be the noel sueeaseful of the Mre/ Disturting now 'Kyrie Jonner doable.' seas roans suck shot grasses to blow up their lips to double their sae_ with OtSastrauf results A dangerous rew craze body hOOK days aver baby' Corermersei nee ria moor Ha lets her ads nese a. lad figure teas than a week alter owing Min Barely bat a baby PUMP Mad Mar star Charlet Theron larks /mann' hot in racy ploriging jumps utt for magazine shoot She's dating kilowatts Sean Penn Kanye WeStIllamS perception Mal Intaktana Central society 'Me the 'laminate as he covers me magazinethat Kim 'broke the rate/nor was a has hoped ire save twos .and eve loved every minute of it' John 'ravotta defends Soomokey AGAIN as he Ives to promote he new lam Jessit•Clestam buts up in motley.' attire as She and Chris Hernsworth shoot scores erne ancient UK ruins for apeon-ny move Tee Iltritsman • uet AS: Mcrae 1> http://www dailymail.co.ukinewStattide-136103WPrince-Ardrew-grl-17-sex-offender-frieroflew-Eintain-meet-lim hen' EFTA01099228 Prince Andrew and girl. 17. va0 sex offender friend flew to Britain 10 meet rim I Daily Mal Online Virginia says- 'Cnisiaine sad I was to start mmediateN and that scmeone world drive me home. My lather left and I was told to go spstaas. She was led by another woman through Epstein's bedroom into a massage room where he lay face Corm 'bared on a table. He stared lo intervewed Virginia. This was unnpnventonal. but Vrgina had no suspicions. Presumably, she thought, this was how the wealthy conducted tier titsiness. Epstein thread 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 it The massage Duddy developed into a sexual encounter. Virginia was uncomfortable. NA reluctant to deny such important people. 'My face was red win embarrassment.' she says. 'But I felt under immense pressure to please them The whole lime it was going on they were promising me the world that I'd travel with Jeffrey on his private /et and have a well-paid profession' Afterwards, she was Gwen two $100 bills and told to return the next day That was the beginning of the four years she spent with Epstein. For three o' those years, she was under Florida's age of consent, Alien is 18. Troubled teenager. Virginia on the lailleonskela Zone ranch In New Mealcoln 2001 Virginia was fascinated by his life say the son or a hunlble New TOM City parka worker, Ise Was a teacher before becoming a Wait Sheet broker and friends with the upper echelons of the tandem. financial and academic establishment. As a confused teenager. Vrgna easily fell Into the practice of sexually gratifying rim for money. He guaranteed her a minimum of 5200 each time she gave him what he called an 'erotic massage.' Virginia said 'I matid aways receive the money immediate-ht. He would give rte the cash from a wad ne carried in a back dtrtfel Dag or an assistant pea me. 'MIXT, because of the way Epstein had warped ner sensthaties. every tale she too( the cash. Virginia felt even more indebted to him Secretly. he was also preparing her for an even more disturbing role. 'Basically. I was trailing to be a prostitute for Ism and his Mends' ho shared his interest in young girls,' She says" After abort Iwo years, he started to ask me to 'entertain' his trends: It started when Epstein called Vrginia at the Palm Beach apartment he had rented tot her. She recalls 'He sad, "rye got a good friend and I need you to fly to the island to entertain him. massage him and make him fee how you make me feel' He didn't spell out what I had to do He didn't have to. He'd Vaned me to do whatever a man wanted I was shocked but I loll myself he was sharing roe around because he rusted rise and I was special I was worried. but I would 60 anythng b keep Jeffrey happy and to keep my place as his norther one girl He wand keep telling me haw kicky I was with the life I was leading and the money I was mak ng It was easy to fall Into his grasp. 'The way it usually worked was I'd be sent Io meet a mart on the private Island Jeffrey owned n the Canbbean. or at his ranch in New Mexico. which was really iscrated' She was 'given' lo men ranging in age from their 40s to they 60s. They included a wen-known businessman (whose pregnant wife was asleep in the net room). a world-renowned scientist. a re-seec'ed betel politician and a foreign head of slate None appeared to think the arrangement was unusual. Virginia says there were many other gib in Epstein's cit.* and that she was paid extra money to help recuit 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 'entertan- his (rents' Virginia took the sedative Xanax to detach herself from sordid realty. it was an escape drug,' she says. 'It oldie nit call arid helped me forget about what I had to do. I was up to eight pills a day.' Epstein had no obyecticn to Virginia's toe of prescription drugs, no doubt recognising that they made her even more malleable. 'I didn't want to oo back to the life I'd had before' she says. Epstein had trained me to do whatever men wanted. I told myself I was special 'She would Ncire nor drinking': Cast and crew el ReillN3 el 'derided' over dine Richards' sotrkt) haute Following her arrest at lie theory it as IloWl Bobby Flay, SO, accused of creating with assistant Ma his age as brier divorce from Stophane March gets uglier ElySe Tartu IS Caron Marro opts for casual leak as he tOPC has down in LOOdOO while rurnOted girittand Taylor Sarti was honored at the AChias Kendall icnacr posts a VENT racy listagrarn dead'a of a naked bottom (but don't worry Prue.. it's not yaw, daughter's!) A provo‘ave5lool stuffiest Catum Bey and tee IlltiniLlad girlfriend tante& Ft At frolic on d beach as ow ) Orliny a commits( kissed getaway Lindsay Iplumb ea Selena Gomez shows (Mlle, WA (Alves IA a skimpy frilled triklai top and tolpents as sly his the Mark n elcorktb a hea1 01 nor arrival back in LA Kristen Stewart gets houchy-footy with her IV0.1,1 gal pal AMU.) Gargle as they celebrate star's 25th birthday 41 COSA M4 leant election 'Kapp/ 4201' Miley Cyrus smokes a bong in lust pasties as sober Demi Lovato collects co getting Joe Jo as high In/ MI 'hitt lime' en Meriiilelt. celebration Not ready la her hosoup' Tito Mindy ProfeLt's Julia 3tilets Iv almost urrocogntrable without makeup as she beach to a NYC salon ACIreSS was au nabrel Prom and proper Maisie %mans goes losthitirritso in a sm., prom dress al The samba screwing Game Of Thrones star past turned 18 ast week http./Nwrw.daitymakcaticinewsrarticle-1361039/Prince-Andreer-grl-17-sex-offerder-frieni-flew-Britain-meral-tim htrnl EFTA01099229 Prince Andrew and girt, 17, vet sex offender friend flew to Britain to meet tam I Daily Mal Online 'That made me totally obedient.' Despite the fact that Epstein was, essentiagy. her pimp. this Ife now seemed normal to Virginia. felt that he and Ghislaine really cared for me: she said. Wed do lamy things, bke 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 Klan and Naomi Campbel, He eitroduced me as his 'traveang masseuse.' Some people mistook me for his daughter. When we were in New York or Palm Beach, Ghislaine and I would shop al 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 sad 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. Finely. they went to London. 'After we landed, we drove straight to Ghislane's house.' says Virginia. 'I was given a smal upstairs bedroom. The Sawing morning. Pisgah* came In. 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 Pnnce tonight: She said I needed to be Voles( and bubbly because he was the Queen's son. Ghislaine and I went to Burberry. where the bought ma a £5,000 bag, and to a few other designer stores where we bought a couple of dresses. a pair of embroidered leans and a pink singlet. perfume and make-up. We got back to Ghlslaine'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. Ghislasne led Andrew in and we kissed each Sher on the cheek. Ghislaine served lea from a porcelain pot and biscuits. She knew Sarah Ferguson and they talked fondly about Andrew's daughters. 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 elf for Jeffrey. She said. 'Hal soon have to trade her n: h 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 oath her. 'After about an hour-and-a-half. we drove back to Ghislaine's. CesielNillig Ville Mier mother e home at Palm Bath In 1 WI Al 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 wel. He had fun'. We Sew 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 Von. On the last leg of the trip. Virginia was paid about $15,000 (£9.100) by Epstein. 'It was amazing money. more than I'd ever made on a tnp with him before. He didn't say there was arty special reason. but I felt Ike I'd done everything he wanted. He was very pleased.' There is no suggesbon that there was any sexual I took eight pills a day to contact between Virginia and Andrew, or that 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 Now York in December. Virginia says she met Andrew for a second time around Easter 2001 al Epstein's Manhattan mansion. When I got to the mansion. I was told. 'Get ready. You are meeting someone in the office" —whip[ is what they called the library. Andrew was sitting there in a big leather armchair. Ghislaine had just given him a present, a big toy that was his Spitting Image puppet. 'He was sming ear-to-ear. He looked like a kid whose parents were taking him to Disney World. A beautiful gel called [REDACTED] who worked for Jeffrey was sitting on Andrew's knee. Ghislaine guided me over to Andrew and I think he recognised me. though I don't know if he remembered my name. 'Please focus on my show,. Conan Ogren hits back at one of his show writers who went on Twitter rant about 'suits of Isle night comedy' Aaron TaylonJohrson, 24, and Sam Taylor• Wood. 45. hold hands as they touch down In London ahead of the Avengers: Age Of hire-, premiere Reality star Lauren Stoner shows oft her Incredible beach body Si tiny black and white biked as she his Miami with friends She insect up Miami 'learn let myself hurt thent Bruce Jenne; reveals his chard/an are the only ones he's concerned with' Si new cap from Ma Mini Diane Saw, or Interview 'It's Idling for sport- Jurassic World troller reveals Chris Pratt and Bryce Dales Howard must stop genalkagy modeled dinosaur that's eating tourists 'lam very proud, Taylor Swine maths, pees moving shoot h as she honors singer la th ACM Mission* Award_ a week after revealing cancer signoras Elizabeth Olsen looks fresh faced as she touches down In London to promote ante gonad Avengers sequel Stan in Avengers Age Of Mon Pregnant Pi ourtney SardeS hien shows off her Ik , curves as she poses nude on KUYITI(— as Kris Jonnor scolds drunk Scott Belch Doing a Darn Moore' First plot details for Star Wars sPirwoff move Rogue One starring British actress Felicity Jones are revealed at convention foe the kook franchise 'The Timberlake, are ready I' Justin shores the first photo of gorgeous baby Sibs in mom Jess ka Biers arms as they cheer on he basketball team hive you at: Zayn Male breaks monthlong Twiner seems as he thanks fans in feat tweets since quitting One Direction He's gone solo OeIghted Harper Beckham grins broadly at LAX airport while in the arms of her doting bad Davit-. Mtn her Mr00 brothers In tow Dawd with his Wood Y'__. http://wvAv daitymail.cauk/nays/article-1361039/Prince-Antew-grl-17-sex-offenier-frierd-fiew-Eintain-meet-rim html EFTA01099230 Prince Anctew and girl, 17, who sex offender friend flew to Britain to meet lam I Daily Marl (mine Organiser. Ghielaine Mammal looks on as Andrew put his arm around Virginia. Robin Maxwell's daughter invited her to Work as Epstein's personal masseuse soon after her 15th birthday We kissed on the cheek and Gluten° placed me on his other knee.' Johanna spoke to The Mal on Sunday three years ago about this incident, 'Much 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 pke. 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 loo obi' for him. Bu1 during one trip to the island. Epstein and Ghislaffie made their most astonishing proposition, and one which repulsed her. 'They said Jeffrey wanted me to have his child; she saYk- They said I was part of their family and I was beautifulyoung, loyal and nurturing and would be a great mother. They said I watt have to sign a contract 'anguishing 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. finay, was a wake-up cal to Virginia and she began to see the way in which she had been groomed. 'It was a smack in the face.' she says. I finaly 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 aedentiab. then maybe we• do it': The tycoon took her at her word and. for her 19th birthday in August 2002, lbw her to Thailand where he enrolled her n a massage course. Shortly after arriving there. she met an Australian martial arts expert caled Robert. They fell in love and, lust ten days later. married in a Buddhist ceremony. 'I called Jeffrey and told him I'd fallen madly in love.' Virginia says. '1 was hoping he'd be delighted. But he said. 'Have a rice Ile? and hung up on me.' The couple now have two sons. aged five and rots. and a daughter who recently turned one. CenvIelker Jeffrey Epstein Beckham. win battle to stay coot David and victoria get go ahead to InstalMr-con to fin bedrooms, gym and wine can at thee Selmilon mansion Snakeskin on a ohne! Lady Gaga slithers into LAX In reptile print coa with her two precious puppies In tow SW* knows how to mane Out Of a CrOwd Rea Ora goes from casualto dam as .1w changes out of patchwork leans and Into a Icy black dress for live TV performance BOInh singer m NY KOS/ Clerk' on Ms the ACM Awards in a figure- hugging floral dress as she presents the Mission* prize to her 'legendary' mot/whin- law Robe McEntire She's a tentless beauty! New mother Blake Live& looks stunning In a scarlet gown as she attends The Age Git Adeline's NYG premiere Bhke Lively hits her movie's after-party In • eery trodysun loo wonder husband Ryan Reynolds Joke* that he's Jealous of her oneic mon by. Interest) 'I prefer to look at natural woman: Giorgio Armen says women should look towerds Cate Blenched for inspiration about growing old grecatugy The worlds he oyster: Gisela 8 undchen wears checked shirt and skinnier; as she arrives in LA_ following retirement from catwalk modetg First class departure! Gwy meth ea thew looks city chic in striped sweater and cropped Jeans as she lets out of New York Jelaettng actress First lady of country! Miranda Lambert wow* at thy AGM Awards In *aging gown and thigh- high me as she leads the pack of country's biggest names Hotel Hell Gordon Ramsay reveals he caught hair lice Boat plow case In Vermont— after Initialer blaming his daughter Celebnty chefs woes Beck to school Brooklyn Beckham. 16. heads back home to England with his firmly folovAng the 'best Easter ever' Hum outwit Mst pals httr:/hmvw darlymarl.covkinewS/artiCle-1361039fPrince-Ardrew.g 17-sex-offiander-friendIfleav-Britain-meet-nim.hfrnl EFTA01099231 Prince Andrew and gill. 17. who sex offender friend flew to Britan to meet Ism I Daily Mail °Sine 'The first few months after I married Robert were the worst; she says. 'I couldn't bong myself to tel him much. No man wards to know his wife has been traded out. 1 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. lEpstein 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 wth his menage of minors. to took the Frith Amendment, refusing to answer. indicating that if he were to answer the question. d could be incnrmnating; a source told The Mai on Sunday. Epstein struck a deal resulting in what commentators diaractensed 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 Mn the way they would an average Joe. they sent a dear message that wth enough money and power and influence. the system can be bought' Virginia was spared her the humiliation of having to go before a (try. and has kept her feelings bottled up until last weekend's photograph of Andrew with Epstein triggered distressing memories. Virginia says. 'I am appaled. To me. it's saying. 'We are above the law." But Jeffrey is a monster. Last night. neither Epstein, Ghislane Maxwell nor Prince Andrew would comment on Virginia's story. Share or comment on this article Pay ASSAsIy No Credit Card Interest Ont.2017MM These Jar Dropping Cr.* Cards WatAdvisor 20 Stars Who Are Aging Terri* MI WI Make You Cringe! PressRoomVP Forget the Cola War... Now is Ruselies 'GM War Money Morning Neersietter 13 Stars You DWI Know Mien Banned from MIL Answers-corn Meet BM Moat Exclusive Card in D.C. Tech,co l Whet What to expect from Up Sync Batik. the most s Lerwludded show on IV Take a look at a Princess Female Air Force vet Diana inspired Beanie arrested try .ng to stop Baby US flag Proth'i Bonne the teiy Sam rt.ovIrens ci bah, doet n't like r ahng alone sobers crawl from ,nuamod mot, 0 r Ads by Goodie Typing Work AI Horne Jobs jobsnnw t.ini Make $17-2441r.Wth Paid Benefits No Experience Needed. 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Mustratd model Miley Cyrus causes ANOTHER online backlash by ravaging her arrnpl hair b a Nolte ... but she's not the orty celebrity to ditch the razor PregnantJennifer Love Hewitt covers up her growing baby bump In cake green coat as she goes makeup free for shopping hip In Peale Palisades Stylish as ever the second tine around- How Kate made affordable look high-end - and even managed to ro.wear her favorites from not first pregnancy cheers to than Ratans shows corn. saki In a teeny mini- dress as she treats herself to a cocktail during Hewett beach day In Hawaii for wedding Bon Affirm it takes his children to the farmer's market in find sighting InCe news broke that he concealed skier owning ancestor in PBS show Mariah Carey 'rules out reconciling with estranged husband Nick Carmen— after he hinted hopes of a romantic reunion' They have two children Christina Milian catches a ride on the underground as she checks out some famous sites around London Down b earth star Miranda thwart scores nymple wins at 50th annual ACM Awards but co-host Lute Bryan wins Entertainer of the Year gong The °barna,* escape from Use White Bowel Michele. Baradk and the girk ditch the mess peck for an Impromptu nature hike Firm FamlY in Virgin'', Lest Gay in paradise. Stephanie Pratt and Josh Shepherd show Off their beach hods as they let back to really following luxury trip to the Bahamas The show must go oni Country star Keith Urban hits the ACM Awards without wife Nicole Kkbnan— as she fens In Mebane Jeetetbng couple http1Mww.dailymail.co.ukinews/artide-1361039/Prince-Ardrew-gri-17-sex-oflerder-fdend-flew-entain-meet-tim.htrnl EFTA01099232 EXHIBIT D EFTA01099233 Case 9:08-cv-80736-KAM Document 325 Entered on FLSD Docket 04/07/2015 Page 1 of 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:08-CV-80736-ICAM JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. SUPPLEMENTAL ORDER This cause is before the Court on its Order Denying Petitioners' Motion to Join Under Rule 21 and Motion to Amend Under Rule 15. (DE 324). In accordance with the portion of that Order striking materials from the record L id. at 10), the Court informs the parties of the following: The affected docket entries (DEs 279, 280, 291-1, 293, and 310-I) shall be restricted from public access on the docket in their entities. Docket entries 279 and 293, which were stricken in their entirety, shall remain so restricted. Regarding the docket entries of which portions were stricken (DEs 280, 291-1, and 310-1), Petitioners may re-file those documents omitting the stricken portions. The re-filed documents must conform to the originally filed documents in all respects, but with the stricken portions omitted. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 71° day of April, 2015. KENNETH A. MARRA United States District Court EFTA01099234 EXHIBIT E EFTA01099235 Diary cf Virgina Roberts whc clams she had sex with Prir'ce Andrew reveals details I Daly Mail Online Foodback Dailyinctil Yerdnesday, May SUP' 2016 68•F GrF S-7,,ty Foto Hon* I U.N. Sports I U.S. Showbiz I Australia I Femall I Health I Science I Money I Video I Travel I Columnists I Latest Ea Am Pewits Menlo,. Nem Bowe Vann Ar 4 MEM I• See Web Amon 'He was caressing every part of my naked body': Explicit 'diary' of billionaire's 'sex slave' alleges she bathed with Prince Andrew at a London townhouse, and then had sex with him following night of dancing [REDACTED] claims that she slept with the prince when she was 17 Roberts claims in diary he was 'concentrating at my plunging V-neck top' during a dinner in London Alleges they went to club where the Royal was londling her on dance floor Says they went to London townhouse and they had a bath during which time Prince Andrew licked her toes' Claims they had sex and then he quickly got up and left the townhouse The Duchess of York, passionately defended her ex-husband during an interview on the Today show on Tuesday morning Buckingham Palace has strongly denied tho allegations WARNING: GRAPHIC LANGUAGE By JLL REILLY FOR IAAILOUNE IRISLISNES ILO ElIT.13 Anysy20I6 I UPDATED U 21 EST ia .ar tat y 2015 935 A never-seen-before diary purportedly belonging to the woman who claims she had underage sex with Prince Andrew reveals exploit claims of the alleged night they slept together In London. [REDACTED]. now 30, darns that she had sex with the prince when she was 17 and a 'sex slave' to his brignaire friend Jeffrey Epstein. the convicted pedophile. In the 24-page diary. obtained by Radar Online. Roberts details the night they siege: 9y met as wei as graphic detat of their sexual encounter. Enter your search Real Housewives Of OC anemic peek. MID star Jim Edmonds and woo Moghan ,on cant stile Tamara goes toploss and proper*, to diva Into pOol Kyle Jenn•r • 'lam* httr://ming da ymal.co ukinews/article-2908852/Teertdiary-beloning-wornan-clams-tncleragesex-Princea-drew-reveals-exclicit-cleails.richt-Londan.html EFTA01099236 Dray cf *gin a Roberts who clams she hal sex With Prime Andrea reveals deals I Daly Mail Online [REDACTED], pictured at Prince Andrew. clams *hewn Ocala WY,* lerd•Ron oho Yes wkWF•IP corwIcted adopt Jeffrey Epstein y. Sk e- S n A otkn. Past_ ' an I it).5 - 40 oneows^ its( ctv'4. •ICA& re-e_ cace4,:,k vsniist.a— aLAA- I V.Cfleick e..t4i to ck.0—An_c....- p c4rst- woyckS kArshi- pow. I t41u hw-6. V.-Ck NO4 O."-5 if matani c- ITOC1.1-st 0 eTn. eAAV.V+ClAtlmo..AI For ca_sno A ;a , II e , eti. st-x— itroixhy1/4)0t 5 I-, bunt Con titnet0 ii ko a S ex firLA Roberts. who hid told her area she vase being triad •• • Maletse. aye OM al Wen Waal by ktarael for oxpeneNo clothes, before mooting this Duke of York at Os prIva townhouse Wt. k? -k rnacia. on 04 unto, 0...nc..-• 0.1 Tr orrie, uu tO- - Un Jr1/4._. cc mon did_ no* LSI 4-0 yeaD 00c. C. A o-d) an Fown.A. o- Jra_t-sils eor nate OC Qx'crt irwasn (nob. lAk ;Wit- O.. its.> Sips c-I-Vats1 Nnti-c-cte.S, frAta-S t$4. n 54 Int red.-, hi, c&ztetcs.r 111.E • ta.a...t_s S-12_an soAv:A. not 1.0 iv:jut:hat kno TD o rya Ins- aS .5 rkart.sIna_anike lie-tea: kocuo.— O.. p V" • ‘'s.) 0. DILL\ 61 ante>, Roberts writes the group went to private, members-only nightclub Tramp In central London whore she clekns Prince Andrew grabbed them both en 'alcohok cocktail'. She adds: 'He wes the most incredibly hideous dancer Shed ever seen She claims Epstein invited her to accompany him on a sot week trip in 2001 -they flew to Pans. then Spain, then Tangier and finely, they went to London. She sieges the first lime she met the prince was at the home of Epstein's friend Ghislaine Mamma. daughter of disgraced tycoon Robert Maxwel, in the city. think rumoured boyfriend Tyga, 25.4 • bad influence on the 11. year-ad Wonted' about sew, snel headed 'Jem irn• in her panties!' Lens Dunham shares an underwear photo of her Girls co- star Kn. on Instagram Candid moment Best at spas? Nina Dobrey shows Conan how Seale she Is... as she breaks her silence on ea Ian Somerhslders wedding awed the audience Silm Bey once cuts • glamorous figure In ai. white as she sports a jaunty fedora sae stepping out in NYC Look was s bar cry Porn her Met Gala Kee 'This is not where I went to ter Married at First Sight star reveals he lea 'trapped' In his merriest,. after spending weeks Dying to as his wife over Pasha Lain and Derek Hough head home after shocking thnlnalkan as beaming Rumor Was leads the final three teams on Cancers With The Stan Pink and husband C•rey Hart put on an affectionate display as they share a sweet smooch on red carpet of BIN Musk Awards Load up couple Pang a Bayonet.? Khoo Kardashlan copies her idol as she strikes seductive poses with her earner* pointed al the camera Instagrem snap Thar• not like you! Arlene Grande is uncharacterlstkagr shy as she's greeted by lens in Los Angeles Big tan of revealing Quells EXCLUSIVE Whoop Goldberg's fin* tragrache Star misses httrimww.dalymaii.covkinewsiarticie-29C0152ffeeadiary-beiorging-wcmavcrams-inderagesex-Prince-Andrew-reveas-exciicit-detaiis-ncht-Loncon.htmi EFTA01099237 Diary CIMr4ptia Roberts who dams she haf sex with Prute Andrew reveals det» I Daly Mal Online SHARE THIS ARTICLE 935 sn... FtELATED AR11CLES EXCLUSWE: BIE Clinton pIcturad with Mae/ Epstein'a— Raedophile bekom» Mirty Epstein bostad Stephen— i Sarah Ferguson slams .. , . sex ave allogab ens t d z,.,. , naivist Prince... -- em SPONSORED Office ir jargon wo hata the most Roberts. who road told her paroma she was being trained as a masseuse, says she was taken shopping by Maxwell for expansiva clothes. belom motana the Duke of York at the private lownhouse. o o, a a. e rteN..42. %Je O 64 -0.....4-ek tie -% Ukt.slo bor a. 0.5 an inemAil h.2...80, t•kr-4-- kierk-5 Wara-. 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C owi—fri; yv .s.."..F5c9ibeavh-4 r.w ) o sson4,244, „ c›, . Robs nowa reah•botown. nye the palt fehlrered e Maronts hOulitl led han inb te mieln teethroom matho roomlem stosina In: she wrak§ Inlo Iksy obielma exclushrely by Rader Roberts. who hes in a smal loven in Colorado. daims the filth in Inc to the throne «spoke kindly of his daughters [and) the conversation toned to me next. stanna vntti Ciesaka plaWng the 'guess my ago' game. włoci was one of her favonte's among her mordy impairen friondo.' guessed 17 and Ghtslaine cluckled. Shel be too old sotin: and fotel him I was realt' ony 16: One potom. sard to have been taken by E pstein during this ~ed encounter in March 2001 shows the Prince w4ti his arm around her »Ist as Maxwell boks on. ' 1 wacA- in. kelt (1.O^...t.r:rns.».4- Wir Alę,. \nur_ Forfl . Forreplcvi s %v i SSin 5 Clon.a. \KUM Q,ka.txl 1-Ze-.C.I.rI N-41 %es • k lela- ka - 4 k/t.e. 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Roberts. now a married mother-of-three. writes the group then went to private. members-onty nightclub Tramp in central London where she darns Prince Andrew grabbed them both an 'alcoholic cocktail.' 'He was the most inaedibly hideous dancer I had ever seen and not to mention how embarrassing it was to have to be the one he was smashing pehics with, even rf he was a pnnce.' Family outing: [REDACTED] pith ore el her tree children as they head for lunch at McDonakts near the Colorado heartening* they an now Wing. She Spa she bailees with Prince Andrew when underage She writes how they stayed at the club for just over an hour, but she could tell he wanted to move on by the way he was 'fondling me on the dance boor, I knew that was a man's pa rte way of saying he wanted to intimately get acquainted.' Roberts now a mother of three, says the par returned to Maxwers house. 'I led him into the upstairs bathroom next to the room I was staying in: she writes in the diary obtained exdLrsively by Radar. 'I was doing my best trying to put on a good show for him by slowly undressing and started to pour a bath. 'The room quiddy filed with steam from the hot water as I turned to Andrew and began to kiss his neck and undress him. 'He was caressing every part of my naked body and filling my head with endless compliments about my blossoming figure: Reese Witherspoon flashes a glimpse at her gyrn-noned thighs and behind a. she sports bright workout wear for food shop She's a busy bee Who's that gri? duty Rooney Meta is Dingy recognizable as she swaps glamor for grunge on casual day out In downtown LA Cara Santana keeps casualIn skinny ripped loans and white sweater while running errands Headed out for a day of pampering and cupcakes \A& Dog days are over. Demi Lovett; and Wilmer Valderrama take their beloved dog for a work Reunited in New voni Miser her Asia tour Alec Baldwin dotes on pregnant wile H dada as she dresses her growing belly in a tight shirt during family *wog through the perk Proud father Indls's luck in out as she does not sunk.* another strig-off with the final four set for The Voice finale Singing competbon tog conclude neat week That's ono sty ash pupl Lady Gags dresses her dog Koji In nautical outfit— as eh* reveab aMY Lek* fiancé Taylor Kinney's last name Tier:M.0nd trt heart Back to business for the Princess: Mary Es out of sports clothes and back Into a chic •newntle at event Danish royal was in a sheernertng gold jacket Poised in Miami Chokes Clinton folows In her mother's footstep* with inspirational speech about women and education at awards Eva 1011901111 00114 glamor in backless too at gab honoring SO moat beautiful people in Hispanic entertainment She's a VP httrINAvw daiymal.covkinews/arhcle-29081352/Teen-diartbeloning-woman-clams-inderagesex-Prince-Andrew-reveals-explicit-details.nicht-Lonton.htmi EFTA01099239 Diary cf Virgina Roberts whc clams she had sex with Prime Andrew reveals deals I Daly Mail Online [REDACTED], now 30, chime that she slept with the prince when she was and a 'sex slave' to his billlorabe friend Jeffrey Epstein, the convicted pedophile Hatred: Prince Andrew left and right. Epstein She claims Prince Andrew, father to Beatrice, 26, and Eugene, 24, paid pariscular attention to her toes and claims he was licking them. 'That was definitely a 1st for me. but I went with it all. fearful of letting down the Prince and in turn Jeffrey and Ghislaine: In her large and curly scrawl. she writes they had sex, which was' short-wed and then he 'quickly got dressed. said his goodbyes and added out of my bedroom to the driver stil waiting for him outside.' In her entries she also saints that Epstein Icid her to recruit other girls. writing: 'I never brought back a girl that ever said no. or didn't want to participate in an erotic massage.' On Tuesday his ex-vide Sarah Ferguson defended him against 'shockingly accusatory allegations' that he had sex with Roberts, The Duchess of York described Prince Andrew as a 'humongously good man' when she was asked about the scandal on US morning television show Today. - • • vaavack 1.t_t Nat r' 1/46 ova- uSF Ate yr% t., WES (y. \ oat l'ics PV "Al Wv 1°" ilf" •"*t- %DLit +EX. I I.O(AwSlat Uprer kteses-, INNOA-f-‘i to Cowes hnciA dvwl crkk.k.rmoun Fv xi Auk clay)._ Et k I..10.oanx Pei, Skew...) Vv.-O 3ic, rinno.Jk5 /Lie— 1 nasvokei tAJ`e-n SW-Ok f10 n or Ci.4a.n....4 watt lh (u \ I eNCA.S1/4,.(...,!..„, roc rtrIC•rt-t-t-I • In her entries she aho claims that EpsteinWM her Ur nicrult other girls. realer 'leaver brought back • gkl that ever said no, or didn't want to partkipote In an week maser? She told the presenter the family stood by the denial issued by Buckingham Paha. Sarah said 'I won't stand by. because I Mow what it feels like to have salacious les made up about you. and not support him so publicly because they are just shockingly accusatory allegations, which I httrihmvw dalymal.co.vkinews/arbele-29C6S52/Teen-diary-belonang-womas-clams-Lnderagesex-Princeandrew-revealsexclidt-delailsrscht-Londan.htmi Over to the dark side! Megan Ode puss wimpy spin on her sophisticated attire as she saps her model body IMo gothic suit N Mad Max premiere Mix is Aimheed cl American Idol as Clark Beckham and Nick F rattan' are set to face. off for finale Popped perimeter Jax got the saX EXCLUSTVE: Sox addict Thin Woods CHEATED on ex- girfriond Lindsey Venn - the fool reason they spat Strayed again Doing some research? Solna Bleb cos les up to Kris Jenne, after a Is revealed she will portray really star in Amerkan Crime Story. The People V OJ Simpson Love is in the Brody Jenrar locks Spa with model girlfriend KanSinri Carter The 31-year-cal has been <Meng the model for over a year Kris et/Met and Mebane Griffith support Kay Rutherford's chanty event— as star gets 100K signatures on petition to get her kids back 't got • poled rotten!' Catharine Zata-Jonos Braga about her excelent Mother's Day_ as husband Michael Douglas gushes over his beautiful bride They got the power' Kerry Washington scales in sparkly bustler and black trousers with pretty Egon Pompon at ABC Upfront XO)(O Files! David Duchovny and Son Anderson kiss (on the IPS) at concert a he performs music from debut album Hell Or Hlghwater Man Cyrus tries out long lair extensions whit dressed In VERY renewing blouse and fishnets during sleeporet with eels Hader Break all hes, don't say 'we' and stop believing In The One: Tracey Cox reveals how to get over your as... for good Some good adwoe Dianna Agron Is weighed down by bouquets of flowers as she and cowtst Stephen WrigM wrap opening night of new London play McQueen EFTA01099240 Diary Cf *gin a Roberts whc clams she had sex with Brute Andrew reveals Details I Daly Mal Online donl think that's right. 'It's defamabon of character and. as a great father and humongously good man and al the work he does for Britain. I won't stand by and let tin have his character defamed to this level: She added: 'II have not one word said about him on any level' When asked if Andrew knew the woman Involved Sarah said she would not discuss the subject. She said 'Buckingham Palace haS put out the denial and I. as his best friend and my best ex husband ever and the most wonderful father to the girls. will not be drawn on any subject.' TODAY'S ROYALS SARAH FERGUSON SPEAKS OUT DUCHESS TALKS PRINCE ANDREW & WEIGHT LOSS C. NBC Adamant Sarah Ferguson passionately defended her ex-husbands Prince Andrew, as she appeared on the Today show on Tuesday morning She used accusations against Nrn Salacious has' Fumbling Kate Upton attempts to play catch with a footba I on the set of The Layover... before taking fligM in a hot air baloon Ferning latest movie Was that an eye rog? DINTS cornet Erin Andrews accused of looking 'annoyed' when Noah Gamey proposed Ivo on-a Says She was crying Newlywed Amy Adams treats herself to an ice cream cone Mtge c rang out at the LA Zoo with her husband Duren and their daughter Wed two weeks ago 'Courtney 'Carlos ten shoes off her post. pregnancy figure in retro outfit as she gets back to work at the DASH store with Scott Derck and son Mason The yolks on you' Anna Kendrick smashes Jimmy Fallon in a game of egg Russ Ian roulette... but she doesn't eggs-cape clean Manus slot Mk heel J. Fox cuts a dapper figure as he makes a rare outing with he wife of 16 years Tracy Pollan SOH gong Wong aikr all mess years Did Lindsay fe about her whereabouts? Lobito spotted arriving in New York a day after tweeting 'Happy to be home b N Vt~ as she Es set to fulfil community service Carrie Fisher's daughter Bile Lourd confirms she's NOT *Poi • young Princes* Lela in Star Wars: Episode VII Fans'spemlotion Ira his turn to be starstruckl George Cloonan and the cast of Astronauts Wives Club Celebrate the 45th anniversary of the Ape 13 mission Kate Bosworth rocks 90s.inspired wideleg denim trousers and open-toe lace-up boots as she strolls around LA Displayed her talque sense of style Real Housewives star Kenya Moore reveab heartbreak after discovering Millionaire Matchmaker boyfriend got MARRIED to blonde volsybel babe 'I didn't eat for 10 clays: Portia de Rossi revisals how being put on a diet at lust 12 years old develeped Into starving herself and eventually bulimia f SAG AeNt 1 - t http:/NWyw.elan'ymal.co vkinws/arbcle.2908852/Teemckary-beloDyng-w0manclams-Lnderagesex-Princea-drew-reveals-explicibdelails.ncht-Loncbn.html EFTA01099241 Diary cf Virgule Roberts whc clams she had sex with Nitre Anclrew reveaS details I Daly Mail prime Al min: Ts Duchess or York smiled as a W left the Today flaw In NewYork on Tuesdey morning in a strongly-worded statement Buckingham Palace has said: 'it is emphatically denied that the Duke of VOrk had any form of sexual contact or reiationship with [REDACTED]. The allegations made are false and without any foundation' Andrew was named in US civl court documents as having sex with Roberts on three separate occasions when she was a minor. She is said to have been procured for him by convicted sex offender Jeffrey Epstein. a billionaire American financier. who she accuses of using her as a 'sex slave. The Duke vehemently denies the alegations against hint Maxwell and Epstein have also dismissed the allegations. Roberts, a US rittren, waived her anonymity in an interviewwith The Mail On Sunday in 2011. in with she claimed she had been sexually exploited by Epstein - a former friend of the Duke. In the US court papers, she alleges that between 1999 and 2002 she 'was forced to have sexual relations with this prime when she was a minor in London. New York and on a pnvate Caribbean island owned by Epstein where an orgy took place. Others named in the lawsuit have also denied the claims. Cate BlanchetTs bisexual revelation. Oscar winner admits she's had 'many' Imamate relatiOnsiSPII with woman as she promotes movie Carol Joe Gludke Ores a up at dinner kvIth s female companion whits wife Teresa serves lane in prison His wife O lour manilla lit 15-moriet sentence Taking the plunge to a newlavell Barefaced Miranda Kerr shows a lot of front in a daring jumpsuit with a nec keno that reaches her navel model looked incredible Vanessa Nucleons Bashes her logs in split• to-the-thigh denkn skirt as she stops out In Now York Had a ManlYn Monroe moment in NYC i r l striking makeover In ril Pectres of a Dame' Helen M Von gots . Sara. caricature portrait to celebrate her p „: 4 i , 1 Broadway run Play corning lo NYC Make-up free Anne rti Hathaway gets coloortd ...- .i tplt ersi i In bright romper during If romantic stroll with husband Adam Shulman Laldtack afternoon for lr' low-key court 'They hay* their own zip coder Modelwth sae DD breast implants in her BUTTOCKS (works for Botched doctors whole hogging them to fie her Chest a glimpse! Sharon Stone. 57. takes the plunge in allibleck at TV party in Now York The 57-year-o41 Bast Instnd star wore an all bladt oval to the event Doting mom All Latter hands with daughter Vivienne es they head to a baby doss ki Los Angeles Resident Evil Legends actress has two children Jennifer Hudson Bashes cleavage during a photoshoot in the Meatpacking District of New York Sipped on Coffee in- between takes Carey Mulligan wears loose-fitting sheer top as she takes a snot with her beau Marcus Mundord In NYC Traded in the glitz and glamor prison. pro wrestling and perseverance' How Mad Max star Nathan Jones wont from Australia's most wanted criminal to Hollywood star Si the making tilt :ad Li d httrihmvw dalymal.covidnews/artmle-2908852/Teurchary-belonyng-womai-clams-inderagesex.Princea-drew-reveals-exclicit-details.recht-london.htmi EFTA01099242 Diary cf VirginaRcterts whc clams she had sex with Prime Andrew reveals detals I Daly Mail Online FINM/y; Ferguson end Prince Andrew. INOBINd welt their daughters argonle. lett, end Beata, NOM la 2001 marled in 1986 and divorced 10 yen law, but him remand good friends Attorney and former Harvard Law school professor Alan Dershowitz said the accusations were 'totally false and made up'. The accusation is contained In a motion flied last month m a Florida court by Roberts who wants to pin an existing lawsuit launched by two other aleged Epstein victims, against federal prosecutors' handling of the financier's case. Epstein was laded for 18 months in 2008 for soliciting a minor for prostitution but lawyers for the women dairn a secret plea deal he struck with prosecutors granting him. and any potential co- conspirators. immunity from further prosecution violated thee dents' rights. Two years after his 2009 release. Epstein was pictured in New York City with the pnnoe. and their friendship was a source of controversy. Prince Andrew ultimately stepped down from his role as a U.K. trade ambassador in July 2011. Court documents also allege that Prince Andrew was among those who made 'efforts' to secure Epstein a favorable plea deal but Buckingham Palace has denied this. In a strongly-worded statement. a palace spokesman said: 'It is emphatically denied that the Duke of York had any form of sexual contact or relationship with [REDACTED]. 'The alegations made are false and without any foundation.' Read more: Sarah Ferguson defends 'good man' Prince Andrew on underage sox claims -News - T0DAY.com Jeffrey Epstein 'Sox Slave' Ympnta Roberts Writes About Sox With Prince Andrew l Radar Online Share or comment on this article 935 shares Enter Anyerw's Name and Sae Mat IS Entertainers Who Traglray Died Former 'Bachelors' They Miry Be MISPerrformance tirchrobretki: When Are They Background Meet Suggest NoWt (PHOTOS) Stirring Daily These Rarely Soon Historkal Photos are Pretty Unnerving Tragic News: Nick Cage la_ PmsRoorna. These 13 Easy Tricks Could Save Huge Amounts of Time httribmvw dalymal.corldnews/arbcfe-29C6852/Tceadiary-belonging-woman-claims-inclerage-sex-Prince-A-clrew-reveals-exclicd-delals.richt-London.htmi Get a room) Sting and Trude Styles pucker up for a smooch as they had the Car be at c hefty fundraiser in New York Noting latent pkasel 'Sher/time. Synergyr: Jam And The Holograms first tram and movie poster hint at • Meyers transformation to superstar 1980s animated series 'We love having another ger: The Queen gushes over the arrtval of her groat- granddaughter Princess Charlotte Al palace garden party Jessie a Alba puts on a tough front •e she dons tight loather ensemble for Taylor Swift's upcoming Bad Blood musts video InNagrarnrix4 by Taylor The ultimate snub? Vogue reveals cover of Met Gala issue with an Image of ADianna alongside a Helot Atat attendees -but lab to include Kan Nerd's hen Three Lyons: Empire's Tral Meyers. Lash Smolett and Brython, Gray show off ripped physiques for Essence magazine as they gear up for season two Not quite Masterpiece Class kr Mogen Fox is Joined by Laws Linney (with curlers in heir) on sot of Teenage Mutant NIMa Turtles 2 Fplming sequel Miss Piggy, Kermb the Frog and the real of the gang return in first Usk, for ABC's al new 'grownup version of The Muppets ReLm of !amity favorites Fashion's new Rebel Pitch Perfect star Wiser. set to design a new 'dope' pluseirra clothing Ines. and It features a nod to home with Keels T-shirts NkoY Rktge puts her wedding ring back ON as reports col marital woos with rocker husband Joel Madden continue to swirl Rumors of divorce Knocked ups Leek Mann rocks baby bump prosthetic while hen hg new rorn-com How To Bo Single in NYC Married dinner Judd Apakive in 1997 Cara Cielevingne to take starring rob In comic book adaptation Valerian And The Cray Of A Thousand Planets as director Luc Beason confirms her casting EFTA01099243 Diary cf Virgina Roberts whc clams she had sex with Prince Andrew reveals details I Daly Mail Online Out:lamp Cog phone video shows gang SA* attack Baltimore man Dawn*&tom CCTV shows woman Sing Sisk beaten by another drNer Prince Harry rcustes with his framer ma Iron Vicki McBratncy Powo restore order after mass brawl on Revere Beach Ads Support the President? Do you approve of his job performance? Veto Hate wnw.nows may cossurveys Degree In Game Design Take Game Design Courses Online at Northeastern. Apply Today! nonheastem.eduiDigitalVedia AncestryDNA "' Test Discover Your Ethnicity vs' Just One Test From The Comfort of Home. ancestry.cesDNA MOST REAll NEWS 7 •7•51 Sorry we are not currently accepting comments on ems article. MORE TOP STORIES Unusual 91M Ern" Clarke reveals Jay Z may have bought a Game Of Thrones dragon egg for wire Beyonc• Sought after gill 'Someone will change genders every week" Jimmy Kimmel jokes about Bruce Jenne?. transition as he roasts ABC network Took ban wig! jibe Jennifer Lawrence looks effortlessly beautlti In simple yet stunning pholoshoot for her first Dior testy campaign New fact of Dice Addiff Daddy's gall David Beckham walks hand in hand with daughter Harper as they enjoy a day In the sunshine Quality One with his lie gad in London Looking tot love! 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Stele Bundchen pictured for the first time since husband Tom Brady, game bank. Deflategate tagout She', hro biggest fan http:thwvw.dalymail.colidnews/article-29C6852ficeadiary-belorging-womanclams-Lnderagesex-Princea-drew-reveas-exciicit-details.richt-Londen.htmi EFTA01099244 EXHIBIT F EFTA01099245 Boles Takes on Dershovntz in Sex Case I The American lawyer AMERICA& LAWYER NOT FOR REPRINT - Click to Print or Select 'Print' in your browser menu to print this document. Page printed from: The American Lawyer Boles Takes on Dershowitz in Sex Case Vivia Chen, The Careerist April 23, 2015 I've been worried that the Alan Dershowitz Show is coming to a close. After writing a bunch of posts about the allegations that Dershowitz had sex with an underage girl I fear the story is getting stale. I mean, how many times can you invoke the image of the septuagenarian Harvard law professor romping naked on some private island? (In March, the judge threw out those "lurid" sex charges against Dershowitz.) Thank goodness a striking new character has emerged to give the story a second wind. And a bold face name to boot: David Boies, reports Reuters. Boies and his firm are representing [REDACTED] (also known as Jane Doe 3), who alleges that Dershowitz, Prince Andrew and other luminaries had sex with her when she was a teenager at the behest of billionaire Jeffrey Epstein, a convicted sex offender. (Roberts is also being represented by Brad Edwards and Paul Cassell—see interview with Cassell—whom Dershowitz has countersued for defamation.) According to a statement by Boies, Schiller & Flexner. the firm is representing Roberts on a pro bono basis: The firm's pro bono program focuses on meaningful cases including trying to assist women and children who are the victims of abuse. Boies Schiller & Flexner LLP took on Ms. Roberts' representation because she was a victim of abuse when she was a minor child. While Dershowitz has been less than flattering about Edwards and Cassell. Robert's other lawyers he's had cordial relations with Boies. "I wrote him a nice congratulatory note when he did the case of gay rights," says Dershowitz. That was back then. Now, the two legal giants are locking horns. Beside the soured personal relationship. Dershowitz makes a much more serious charge: Boies Schiller has a conflicts problem. According to Dershowitz, Boies Schiller partner Carlos Sires in Florida had volunteered to represent him in his defamation suit against Roberts. After delivering a confidential memo to Sires about the matter, Dershowitz said he learned that the firm already represented Roberts. "I wrote to Sires that you are such a mensch, and I'm sorry you're in the middle of all this," says Dershowitz. "But your firm can't continue to represent [Roberts] because you've all read my httr amer icarlawyer comiprintednertlyhth 1202724439959 12 EFTA01099246 Boies Takes on Dershowitz in Sex Case I The American Lawyer material." Dershowitz says he asked Boies Schiller to recuse itself: "They answered no." He says, "They are arrogant; they think they're above the law." He adds, "they have a long sordid history with conflicts," citing the firm's most recent sanction in Boies Schiller & Flexner v. Host Hotels & Resorts, in which the Second Circuit noted that the firm "willfully refused to recognize the obvious conflict" in taking on a client. (Boies Schiller has not responded to our questions.) Meanwhile, Dershowitz seems a bit offended that Boies is ignoring him. "I'm willing to talk to him, but he won't talk to me." So will the legal drama/soap opera keep on going? Oh, yeah, says Dershowitz. "There's more coming." [email protected] Copyright 2015. ALM Media Properties, LLC. All rights reserved. http://www.amer icanlawyer.comiprinterfrierdlytth 1202724439959 2/2 EFTA01099247