Skip to main content
Skip to content
Case File
sd-10-EFTA01412453Dept. of JusticeOther

EFTA Document EFTA01412453

Page 1 of 32 Report Created: Monday, April 30, 2018 21:12:50 (GMT) by Nathan Head Research Information: This document contains investigations on: SOUTHERN TRUST CO; SOUTHERN FINANCIAL LLC; DARREN K INDYKE; RICHARD KAHN; JEFFREY E EPSTEIN; JEFFREY EDWARD EPSTEIN https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412453 Page 2 of 32 SOUTHERN TRUST CO 1 Tennessee Court of Appeals Opinion: Alexis Breanna Gladden v. Cumberland Trust a

Date
Unknown
Source
Dept. of Justice
Reference
sd-10-EFTA01412453
Pages
63
Persons
0
Integrity
Loading PDF viewer...

Summary

Page 1 of 32 Report Created: Monday, April 30, 2018 21:12:50 (GMT) by Nathan Head Research Information: This document contains investigations on: SOUTHERN TRUST CO; SOUTHERN FINANCIAL LLC; DARREN K INDYKE; RICHARD KAHN; JEFFREY E EPSTEIN; JEFFREY EDWARD EPSTEIN https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412453 Page 2 of 32 SOUTHERN TRUST CO 1 Tennessee Court of Appeals Opinion: Alexis Breanna Gladden v. Cumberland Trust a

Ask AI About This Document

0Share
PostReddit

Extracted Text (OCR)

EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
Page 1 of 32 Report Created: Monday, April 30, 2018 21:12:50 (GMT) by Nathan Head Research Information: This document contains investigations on: SOUTHERN TRUST CO; SOUTHERN FINANCIAL LLC; DARREN K INDYKE; RICHARD KAHN; JEFFREY E EPSTEIN; JEFFREY EDWARD EPSTEIN https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412453 Page 2 of 32 SOUTHERN TRUST CO 1 Tennessee Court of Appeals Opinion: Alexis Breanna Gladden v. Cumberland Trust and Investment Company et al. Financial Law Reporter (Global), May 19, 2016 Thursday, (3166 words) Note: Immaterial SOUTHERN FINANCIAL LLC 2 No Documents Found DARREN K INDYKE 3 RICHARD KAHN 4. No Documents Found Once feared lost, black films to screen at DIA; Actors, directors offer own take on Hollywood during segregation Detroit Free Press (Michigan), February 2, 2017 Thursday, LIFE AND ENTERTAINMENT; Pg. D7, (1427 words), By, John Monaghan, Special to the Detroit Free Press Note: Immaterial JEFFREY E EPSTEIN 5 Donald Trump denies rape of teenage girl at 'sex party with convicted paedophile Jeffrey Epstein'; The presidential hopeful categorically denies sexually assaulting and raping the woman at his New York residence back in 1994 mirror.co.uk, April 28, 2016 Thursday 11:23 PM GMT, NEWS,WORLD NEWS, (977 words), By Christopher Bucktin Note: Does not relate to money laundering or terrorist financing. 6 Lawyer Denies Suit's Allegations of Sex With a Minor The New York Times, January 7, 2015 Wednesday, Section A; Column 0; National Desk; Pg. 13, (591 words), By TIMOTHY WILLIAMS Note: Does not relate to money laundering or terrorist financing. 7. TRUMP 'RAPED ME AS A TEEN AT SEX PARTY'; LAWSUIT PRESIDENTIAL HOPEFUL SUED ; Woman makes astonishing underage 'slave' claims in US court Daily Record and Sunday Mail, April 29, 2016 Friday, NEWS; Pg. 13, (588 words), CHRISTOPHER BUCKTIN Note: Does not relate to money laundering or terrorist financing. 8. A ROYAL 'SEX SLAVE' Forced me to do it with him 3 times, she says Perverted N.Y. money big arranged it all A pack of lies, says spokesman for Brit family Daily News (New York), January 3, 2015 Saturday, NEWS; Pg. 8, (753 words), BY DARER GREGORIAN and CORKY SIEMASZKO NEW YORK EFTA01412454 DAILY NEWS Note: Does not relate to money laundering or terrorist financing. 9. British royal is named in suit alleging unlawful sex; Motion claims that minor was forced into relations with prince and others International New York Times, January 5, 2015 Monday, NEWS; Pg. 5, (716 words), EMMA G. FITZSIMMONS Note: Possible match- sex trafficking could relate to money laundering. 10. Prince Is Named in Suit Alleging Sex With Minor The New York Times, January 4, 2015 Sunday, Section A; Column 0; National Desk; Pg. 16, (673 words), By EMMA G. FITZSIMMONS Note: Possible match- sex trafficking could relate to money laundering. 11. Dershowitz on the Defense The New York Times, December 13, 2015 Sunday, Section BU; Column 0; Money and Business/Financial Desk; Pg. 1, (2607 words), By BARRY MEIER Negative News / English Negative News / English Negative News / English Negative News / English Negative News / English Negative News / English Negative News / English Negative News / English Negative News / English Negative News / English Negative News / English https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412455 Page 3 of 32 Note: Possible match- sex trafficking could relate to money laundering. 12. Labor Pick's Role in Sex Case May Cloud Bid The New York Times, February 18, 2017 Saturday, Section A; Column 0; National Desk; Pg. 14, (536 words), By BARRY MEIER Note: Possible match- sex trafficking could relate to money laundering. 13. Prince, Back in News, Faces Curse of the 'Spare' The New York Times, January 17, 2015 Saturday, Section A; Column 0; Foreign Desk; Pg. 4, (1191 words), By STEVEN ERLANGER Note: Does not relate to money laundering or terrorist financing. 14. President's Pick to Lead Labor Dept. Is Confirmed The New York Times, April 28, 2017 Friday, Section A; Column 0; National Desk; Pg. 14, (594 words), By MAYA SALAM Note: Does not relate to money laundering or terrorist financing. 15. Labor Nominee Dismisses Fears of Political Pressure The New York Times, March 23, 2017 Thursday, Section A; Column 0; National Desk; Pg. 15, (862 words), By YAMICHE ALCINDOR Note: Does not relate to money laundering or terrorist financing. 16. Dershowitz and 2 Other Lawyers Settle Legal Fight The New York Times, April 12, 2016 Tuesday, Section B; Column 0; Business/Financial Desk; Pg. 2, (425 words), By BARRY MEIER Note: Does not relate to money laundering or terrorist financing. 17. No Documents Found JEFFREY EDWARD EPSTEIN 18. No Documents Found 19. No Documents Found Return to List Cases Negative News / English Cases Negative News / English Negative News / English Negative News / English Negative News / English Negative News / English Note: Immaterial 1 of 19 Documents Financial Law Reporter (Global) May 19, 2016 Thursday Tennessee Court of Appeals Opinion: Alexis Breanna Gladden v. Cumberland Trust and EFTA01412456 Investment Company et al. LENGTH: 3166 words DATELINE: New York Nashville: Tennessee Court of Appeals has issued the following Opinion: IN THE COURT OF APPEALS OF TENNESSEE AT KNOXVILLE https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412457 Page 4 of 32 November 19, 2015 Session ALEXIS BREANNA GLADDEN v. CUMBERLAND TRUST AND INVESTMENT COMPANY, ET AL. Appeal from the Circuit Court for Hamblen County No. 12-CV-119 Thomas J. Wright, Judge No. E2015-00941-COA-R9-CV-FILED-MARCH 24, 2016 We granted an interlocutory appeal pursuant to Tenn. R. App. P. 9 in this case to consider whether the signature of the trustee of the Alexis Breanna Gladden Irrevocable Trust ("the Trust") on an investment/- brokerage account agreement agreeing to arbitration binds the minor beneficiary of the Trust to conduct arbitration of unknown future disputes or claims. We find and hold that while the plain language of the trust agreement does allow the trustee to agree to arbitrate claims and disputes that have arisen, it does not allow the trustee to agree to arbitration of unknown future disputes or claims. Therefore, the signature of the trustee of the Trust on an investment/brokerage account agreement agreeing to arbitration does not bind the minor beneficiary to conduct arbitration of unknown future disputes or claims. Tenn. R. App. P. 9 Interlocutory Appeal by Permission; Judgment of the Circuit Court Reversed; Case Remanded D. MICHAEL SWINEY, CHIEF JUDGE, delivered the opinion of the court, in which CHARLES D. SUSANO, JR., and JOHN W. MCCLARTY, JJ., joined. F. Braxton Terry, Morristown, Tennessee and W. Lewis Jenkins, Jr., Dyersburg, Tennessee, for the appellant, Alexis Breanna Gladden b/n/f Wade Harvey, Jr. Mark D. Griffin and Will E. Routt, Memphis, Tennessee, for the appellees, Wunderlich Securities, Inc. and Albert M. Alexander, Jr. 2 OPINION Background Alexis Breanna Gladden ("the Minor") is a minor who was catastrophically injured at a young age and suffered severe disabilities. The Trust was created for the benefit of the Minor in Hamblen County, Tennessee, and was approved by and subject to the order of the Circuit Court for Hamblen County ("the Trial Court"). As pertinent to this appeal, the trust agreement establishing the Trust by order of the Trial Court ("Trust Agreement") provides: Section 11.01 Introduction to Trustee's Powers The Trustee may exercise, without prior approval from any court, all powers conferred by this trust agreement and any other powers conferred by law, including, without limitation, those powers set forth under the common law or any fiduciary powers act or other laws of the State of Tennessee, except as otherwise specifically provided in this agreement. Each power conferred upon the Trustee by state or federal statutes shall be subject to any express limitations or contrary directions contained in this agreement. * * * Section 11.05 The Trustee's Administrative Powers In addition to the other powers granted the Trustee in other provisions of EFTA01412458 this agreement, the Trustee shall have the following administrative powers: * * * (e) Settlement Powers The Trustee may settle, by compromise, arbitration or otherwise any and all claims and demands in favor of or against, or in any way relating to, any trust created under this agreement upon such terms as the Trustee may determine. The Trustee may release or abandon any claims in favor of this trust. 3 Wade Harvey, Sr. ("Plaintiff") was appointed as the guardian of the Minor in June of 2011. In May of 2012, Plaintiff filed suit on behalf of the Minor against several defendantsl alleging, among other things, failure to properly manage the Trust funds, breach of fiduciary duty, and misappropriation of the Trust funds. https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412459 Page 5 of 32 Defendants Wunderlich Securities, Inc. ("Wunderlich") and Albert M. Alexander, Jr. ("Alexander") filed a motion to compel arbitration and stay the proceedings alleging, in part, that in connection with opening an account at Wunderlich in the name of the Trust, the trustee, the Minor, and Wunderlich had entered into a binding compulsory agreement to arbitrate all controversies.2 After a hearing on the motion to compel arbitration, the Trial Court entered its order on February 12, 2013 granting the motion to compel arbitration and stay the proceedings. Plaintiff then filed a motion seeking an interlocutory appeal pursuant to Tenn. R. App. P. 9 from the February 12, 2013 order compelling arbitration. The Minor died in July of 2013 and an Agreed Order was entered on September 18, 2013 substituting Plaintiff for the Minor in this suit. After a hearing on the motion for interlocutory appeal, the Trial Court entered its order on May 12, 2015 finding that an interlocutory appeal was justified because if Plaintiff were correct any arbitration decision could be invalid as the arbitrator would not have authority to hear the matter. An interlocutory appeal, therefore, would assist in potentially reducing needless litigation. The Trial Court granted Plaintiff leave to seek permission for an interlocutory appeal with this Court. This Court granted permission for an interlocutory appeal by order entered June 23, 2015 on the sole issue of whether the trustee's signature on an investment/brokerage account agreement agreeing to arbitration binds the Minor beneficiary to conduct arbitration of unknown future disputes or claims. Discussion Wunderlich and Alexander raise an issue regarding whether this Court has subject matter jurisdiction to hear this interlocutory appeal. Jurisdiction is a threshold issue as our Supreme Court explained in v. Hopkins, stating: 1 Plaintiff sued Cumberland Trust and Investment Company, Joi S. Chatman, Albert M. Alexander, Jr., Wells Fargo & Company, Wells Fargo Advisors, LLC as successor in interest to A.G. Edwards, Inc., d/b/a A.G. Edwards & Sons, Inc., A.G. Edwards, Inc., A.G. Edwards & Sons, Inc., and Wunderlich Securities, Inc. 2 Defendants Wells Fargo & Company, Wells Fargo Advisors, LLC as successors in interest to A.G. Edwards, Inc. d/b/a A.G. Edwards & Sons, Inc., A.G. Edwards, Inc. and A.G. Edwards & Sons, Inc (collectively "Wells Fargo") joined in the motion to compel arbitration. Plaintiff later took a voluntary non-suit without prejudice as to Wells Fargo. 4 Subject matter jurisdiction involves the court's lawful authority to adjudicate a controversy brought before it. Chapman v. DaVita, Inc., 380 S.W.3d 710, 712 (Tenn. 2012); Meighan v. U.S. Sprint Commc'ns Co., 924 S.W.2d 632, 639 (Tenn. 1996). Subject matter jurisdiction is conferred by statute or the Tennessee Constitution; the parties cannot confer it by appearance, plea, consent, silence, or waiver. In re Estate of Trigg, 368 S.W.3d 483, 489 (Tenn. 2012). Any order entered by a court lacking jurisdiction over the subject EFTA01412460 matter is void. Id. Therefore, subject matter jurisdiction is a threshold inquiry, which may be raised at any time in any court. Id. Johnson v. Hopkins, 432 S.W.3d 840, 843-44 (Tenn. 2013). Given all this, we will address this issue. Wunderlich and Alexander argue in their brief on appeal that subject matter jurisdiction in this case is governed by Tenn. Code Ann. ] 29-5-319, and because an order to compel arbitration does not fall within one of the enumerated categories in this statute, subject matter jurisdiction is lacking. Although Plaintiff did not have the right to an appeal pursuant to Tenn. Code Ann. ] 29-5-319 in this case at this juncture, this fact did not preclude Plaintiff from filing an application seeking an interlocutory appeal by permission pursuant to Tenn. R. App. P. 9, which is exactly what Plaintiff did. In pertinent part, Rule 9 provides: Except as provided in Rule 10, an appeal by permission may be taken from an interlocutory order of a trial court from which an appeal lies to the Supreme Court, Court of Appeals or Court of Criminal Appeals only upon application and in the discretion of the trial and appellate court. Tenn. R. App. P. 9. Plaintiff filed a motion with the Trial Court seeking leave for an interlocutory appeal pursuant to Tenn. R. App. P. 9. The Trial Court considered Plaintiff's motion, exercised its discretion, and granted permission to file for an interlocutory appeal to this Court. This Court then considered Plaintiff's motion and in the exercise of our discretion granted the motion for interlocutory appeal. Wunderlich and Alexander are simply incorrect in their assertion that this Court lacks subject matter jurisdiction to hear this interlocutory appeal by permission pursuant to Tenn. R. App. P. 9. Wunderlich and Alexander attempt to raise other issues in this appeal including whether Plaintiff lacks standing and whether Plaintiff's claims fall within the scope of the 5 arbitration agreement. These issues were not certified in our order granting this interlocutory appeal. In addition, the issue of standing was not presented to the Trial Court. As the Trial Court did not have an opportunity to consider this issue, and as the record on appeal has not been developed with regard to this issue, we are unable to consider the issue of standing at this time. For all of these reasons we will not address the other issues that Wunderlich and Alexander attempt to raise. In Trigg v. Little Six Corp., a case involving a Rule 9 interlocutory appeal of a trial court's decision on a motion to compel arbitration, we explained the standard of review to be applied stating: Our review of a trial court's grant or denial of a motion to compel arbitration is governed by the same standards that apply to a bench https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412461 Page 6 of 32 trial. Mitchell v. Kindred Healthcare Operating, Inc., 349 S.W.3d 492, 496 (Tenn. Ct. App. 2008). As we observed in Rosenberg v. BlueCross BlueShield of Tenn., Inc., 219 S.W.3d 892, 903-04 (Tenn. Ct. App. 2006), [a]s a general rule, a court's enforcement of an arbitration provision is reviewed de novo. See Cooper v. MRM Inv. Co., 367 F.3d 493, 497 (6th Cir. 2004). A trial court's order on a motion to compel arbitration addresses itself primarily to the application of contract law. We review such an order with no presumption of correctness on appeal. See Pyburn v. Bill Heard Chevrolet, 63 S.W.3d 351, 356 (Tenn. Ct. App. 2001); see also Nelson v. Wal-Mart Stores, Inc., 8 S.W.3d 625, 629 (Tenn. 1999). However, to the extent that findings of fact are necessary concerning the "cost-prohibitive" nature of the arbitration sought, these findings come to us with a presumption of correctness absent a preponderance of evidence to the contrary. Tenn. R. App. P. 13(d); T.R. Mills Contractors v. WRH Enterprises, LLC et al., 93 S.W.3d 861, 864 (Tenn. Ct. App. 2002). Trigg v. Little Six Corp. 457 S.W.3d 906, 911 (Tenn. Ct. App. 2014). We granted this Tenn. R. App. P. 9 interlocutory appeal on the sole issue of whether the signature of the trustee on an investment/brokerage account agreement agreeing to arbitration binds the Minor beneficiary of the Trust to conduct arbitration of unknown future disputes and claims. As this Court has explained: Trust instruments are interpreted similarly to contracts, deeds, or 6 wills. Marks v. Southern Trust Co., 203 Tenn. 200, 205, 310 S.W.2d 435, 437-38 (1958). Determining the settlor's intent is important and may be easily done by looking to the four corners of the trust instrument. Marks v. Southern Trust Co., 203 Tenn. at 205, 310 S.W.2d at 438. Unless the trust instrument is ambiguous or allegations of fraud, accident or mistake have been made, parol evidence or evidence of surrounding facts and circumstances that contradicts or varies the terms of a written instrument may not be considered. HMF Trust v. Bankers Trust Co., 827 S.W.2d 296, 299 (Tenn. Ct. App. 1991); Brown v. Brown, 45 Tenn. App. 78, 95, 320 S.W.2d 721, 728 (1959). In re: Estate of Marks, 187 S.W.3d 21, 28 (Tenn. Ct. App. 2005). With regard to interpretation of contracts, this Court has explained: In resolving a dispute concerning contract interpretation, our task is to ascertain the intention of the parties based upon the usual, natural, and ordinary meaning of the contract language. Planters Gin Co. v. Fed. Compress & Warehouse Co., Inc., 78 S.W.3d 885, 889-90 (Tenn. 2002)(citing Guiliano v. Cleo, Inc., 995 S.W.2d 88, 95 (Tenn. 1999)). A determination of the intention of the parties "is generally treated as a question of law because the words of the contract are definite and undisputed, and in deciding the legal effect of the words, there is no genuine factual issue left for a jury to decide." Planters Gin Co., 78 S.W.3d at 890 (citing 5 Joseph M. Perillo, Corbin on Contracts, ] 24.30 (rev. ed. 1998); Doe v. HCA Health Servs. of Tenn., Inc., 46 S.W.3d 191, 196 (Tenn. 2001)). The central EFTA01412462 tenet of contract construction is that the intent of the contracting parties at the time of executing the agreement should govern. Planters Gin Co., 78 S.W.3d at 890. The parties' intent is presumed to be that specifically expressed in the body of the contract. "In other words, the object to be attained in construing a contract is to ascertain the meaning and intent of the parties as expressed in the language used and to give effect to such intent if it does not conflict with any rule of law, good morals, or public policy." Id. (quoting 17 Am.Jur.2d, Contracts, ] 245). This Court's initial task in construing the Contract at issue is to determine whether the language of the contract is ambiguous. Planters Gin Co., 78 S.W.3d at 890. If the language is clear and unambiguous, the literal meaning of the language controls the outcome of the dispute. Id. A contract is ambiguous only when its meaning is uncertain and may fairly be understood in more than one way. Id. (emphasis added). If the contract is found to be ambiguous, we then apply established rules of construction to 7 determine the intent of the parties. Id. Only if ambiguity remains after applying the pertinent rules of construction does the legal meaning of the contract become a question of fact. Id. Kafozi v. Windward Cove, LLC, 184 S.W.3d 693, 698-99 (Tenn. Ct. App. 2005). When interpreting the Trust Agreement, we must take care not to render any of the language superfluous by our interpretation. As this Court explained in Associated Press v. WGNS Inc.: It is the universal rule that a contract must be viewed from beginning to end and all its terms must pass in review, for one clause may modify, limit or illuminate another. As is said in 6 R.C.L. page 838 under the title "Contracts", "Taking its words in their ordinary and usual meaning, no substantive clause must be allowed to perish by construction, unless insurmountable obstacles stand in the way of any other course. Seeming contradictions must be harmonized if that course is reasonably possible. Each of its provisions must be considered in connection with the others, and, if possible, effect must be given to all. A construction which entirely neutralizes one provision should not be adopted if the contract is susceptible of another which gives effect to all of its provisions. The courts will look to the entire instrument, and, if possible, give such construction that each clause shall have some effect, and perform some office." Associated Press v. WGNS Inc., 348 S.W.2d 507, 512 (Tenn. Ct. App. 1961) (citation omitted). https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412463 Page 7 of 32 The Trust Agreement provides in plain unambiguous language that the trustee has the right to "settle, by compromise, arbitration or otherwise any and all claims and demands . . .," and "may release or abandon any claims in favor of this trust." Thus, without question the trustee has the right under the Trust Agreement to agree to arbitration binding the Minor beneficiary as to claims or demands once they have arisen. This provision in the Trust Agreement is consistent with the Tennessee Uniform Trust Code, Tenn. Code Ann. ] 3515-101, et seq. Specifically, Tenn. Code Ann. ] 35-15-816 provides: 8 35-15-816. Specific powers of trustee. * * * (b) Unless the terms of the instrument expressly provide otherwise and without limiting the authority conferred by ] 35-15-815, a trustee may: * * * (14) Pay or contest any claim, settle a claim by or against the trust, and release, in whole or in part, a claim belonging to the trust; Tenn. Code Ann. ] 35-15-816(b)(14) (2015). In their brief on appeal Wunderlich and Alexander argue, in part, that the "any and all" language contained in Section 11.05(e) of the Trust Agreement shows that the clause does not refer only to existing claims and demands, but also can include disputes that have not yet arisen. Black's Law Dictionary, however, defines the term "claim" as: 1. The aggregate of operative facts giving rise to a right enforceable by a court <the plane crash led to dozens of wrongful death claims>. 2. The assertion of an existing right; any right to payment or to an equitable remedy, even if contingent or provisional <the spouse's claim to half of the lottery winnings>. 3. A demand for money or property to which one asserts a right <an insurance claim>. BLACK'S LAW DICTIONARY 240 (7th ed. 1999). The word "claim" simply does not include disputes that have not yet arisen. As such, the "any and all" language contained in Section 11.05(e) of the Trust Agreement, which modifies the words "claims and demands," cannot refer to disputes not yet in existence. The Trust Agreement does not provide that the trustee has the right to agree to arbitration prior to a claim or demand arising. To hold that it does would result in re-writing the agreement, which clearly and unambiguously provides the trustee the right to agree to arbitration only after claims or demands arise. Furthermore, it is difficult to comprehend how a trustee could foresee that agreeing to arbitrate a claim or dispute would be in the best interest of a minor when the trustee lacks knowledge of what that future claim or dispute might encompass. Given the nature of the claim or dispute arbitration may very well not be in the best interest of a minor beneficiary and agreeing to arbitration could potentially violate the duties that a trustee owes to a minor beneficiary 9 of a trust. See Tenn. Code Ann. ] 35-15-801 et seq. (discussing duties and EFTA01412464 powers of trustee). As the plain and unambiguous language of the Trust Agreement did not give the trustee the power to agree to arbitration of unknown future claims or disputes, we find and hold that the signature of the trustee on the investment/brokerage account agreement agreeing to arbitration does not bind the Minor beneficiary of the Trust to conduct arbitration of unknown future disputes or claims. Conclusion The judgment of the Trial Court granting the motion to compel arbitration is reversed, and this cause is remanded to the Trial Court for further proceedings consistent with this Opinion and for collection of the costs below. The costs on appeal are assessed against the appellees, Wunderlich Securities, Inc. and Albert M. Alexander, Jr. D. MICHAEL SWINEY, CHIEF JUDGE In case of any query regarding this article or other content needs please contact: [email protected] LOAD-DATE: May 19, 2016 LANGUAGE: ENGLISH PUBLICATION-TYPE: Journal https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412465 Page 8 of 32 Copyright 2016 Plus Media Solutions Private Limited All Rights Reserved Return to List 2 of 19 Documents No Documents Found - Negative News / English Search Terms:(((Southern Financial LLC)) w/25 (abus! or allegati! or ambush! or apprehen! or arraign! or arrest! or assault! or asset freez! or bankrupt! or blackmail! or brib! or captive or class action or contrab! or convict! or corrupt! or counterfe! or drug dealer or embez! or extort*** or extremis! or felon* or fined or fraud! or fugit! or guilt! or illegal! or illicit! or impris! or incarc! or incrim! or indict! or jail! or kickback or kidnap! or larcen! or launde! or liquidat! or mafi* or miscond! or murde! or narcot! or parole! or politically exposed or racketee! or rape* or robbery or robbed or robber or robberies or sanction! or smuggl! or steal or stealing or stole* or terroris! or theft or traffick! or traffik! or unlaw! or violat!)) and INDEX-CODE( BANKING & FINANCE OR COMPANY ACTIVITIES & MANAGEMENT OR CRIME, LAW ENFORCEMENT & CORRECTIONS OR INTERNATIONAL RELATIONS & NATIONAL SECURITY OR LAW & LEGAL SYSTEM OR SOCIETY, SOCIAL ASSISTANCE & LIFESTYLE OR TRENDS & EVENTS) AND NOT (PUBLICATION-TYPE(Newswire or depeche or Presseagentur or Agencia or Agenzia or Persbureau or Comunicado de imprensa or بيان صحفي or Пресс- релиз or Pressemeddelelse or Pressemelding or Lehdist6tiedote or Pressmeddelande)) AND (DATE >=2013-04-30) Source:All English Language News Return to List 3 of 19 Documents No Documents Found - Negative News / English Search Terms:((Darren K pre/2 Indyke)) and ((Indyke) w/25 (abus! or allegati! or ambush! or apprehen! or arraign! or arrest! or assault! or asset freez! or bankrupt! or blackmail! or breach! or brib! or captiv! or class action or contrab! or convict! or corrupt! or counterf! or court case or drug dealer or deceive* or decept! or deprav!! or detain! or detention or disgra! or disquali! or drug abuse* or drug addict! or drug user or embez! or extort*** or extremis! or felon* or fined or fraud! or fugit! or guilt! or illegal! or illicit! or impris! or incarc! or incrim! or indict! or injunct! or inside! deal! or inside! info! or jail! or kickback or kidnap! or larcen! or launde! or liquidat! or litigat! or mafi* or manipul! or miscond! or misdem! or murde! or narcot! or nefario! or offen! or parole! or politically exposed or prohibit! or prosecu! or racketee! or rape* or robbery or robbed or robber or robberies or sanction! or scam! or scandal! or sexual! or smuggl! or steal or stealing or stole* or terroris! or theft or traffik! or traffick! or unlaw! or verdict or violat!)) and INDEX-CODE( BANKING & FINANCE OR COMPANY ACTIVITIES & MANAGEMENT OR CRIME, LAW ENFORCEMENT & CORRECTIONS OR INTERNATIONAL RELATIONS & NATIONAL SECURITY OR LAW & LEGAL SYSTEM OR EFTA01412466 SOCIETY, SOCIAL ASSISTANCE & LIFESTYLE OR TRENDS & EVENTS) AND NOT (PUBLICATION-TYPE(Newswire or depeche or Presseagentur or Agencia or Agenzia or Persbureau or Comunicado de imprensa or بيان صحفي or Пресс-релиз or Pressemeddelelse or Pressemelding or Lehdistetiedote or Pressmeddelande)) AND (DATE >=2013-04-30) Source:All English Language News Return to List Note: Immaterial 4 of 19 Documents https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412467 Page 9 of 32 Detroit Free Press (Michigan) February 2, 2017 Thursday 1 Edition Once feared lost, black films to screen at DIA; Actors, directors offer own take on Hollywood during segregation BYLINE: By, John Monaghan, Special to the Detroit Free Press SECTION: LIFE AND ENTERTAINMENT; Pg. D7 LENGTH: 1427 words James Wheeler was about 9 when he first saw Spencer Williams' "The Blood of Jesus," in which a woman is shot by her husband and journeys to the crossroads between heaven and hell. He watched the movie, which featured an all-black cast, not in a theater but on a portable 16mm projector in a cafe his mother ran in Waldo, Ark. He figures it was around 1948. "That movie, man, it made you feel like you were following the spirit of this woman all the way to heaven," remembered Wheeler, who now lives in Southfield. "As a kid growing up in the South, it all seemed so real. I can't even begin to tell you the impression that left on me." Screening this Sunday, "The Blood of Jesus" serves as the centerpiece of "Pioneers of African-American Cinema," running primarily this weekend (and two additional dates) at the Detroit Film Theatre at the Detroit Institute of Arts. The series takes nine features from a recently released Kino Lorber set of rare black films and projects them on the DFT screen in high-definition digital. All screenings are free "We wanted to show several films to provide the broadest possible overview," said Elliot Wilhelm, the DIA's film curator. "We have the heralded movies of Spencer Williams and Oscar Micheaux, and others made primarily for their entertainment value, movies emulating the Hollywood product that black audiences would see at segregated theaters throughout the South." Movies made by and for African Americans, sometimes called "race films," were shown in theaters, but more often screened in popular community gathering places like churches or cafes like the one in which Wheeler saw many of these films for the first time. For Wheeler, this led to a lifelong study of the movies and their makers, including Williams, who made "The Blood of Jesus," and Micheaux, whose ingenuity behind the camera and subject matter have made him the most famous of the early black filmmakers. Three of his titles will be shown. Micheaux's films are often called a response to the racist images of D.W. Griffith's "The Birth of a Nation," which showed black characters (often portrayed by white actors in black face) as lazy and often evil. Yet these films also featured racial stereotypes. The stories often involved drinking, gambling and other illegal activities, with the church the sole road to salvation. Wheeler defends the overt melodrama of these early films as an important stepping stone to more nuanced works. "Those filmmakers did what they could to get these works out and seen by the public," he said. EFTA01412468 "And sometimes, they relied on familiar stereotypes." An exception is "The Flying Ace," a 1926 aviation drama made by Southern- born white director Richard E. Norman and featuring African Americans in roles that traditionally had been played by white actors. This Friday night offering screens in a stunning new digital restoration and with live musical accompaniment. Just over an hour long, the movie will be shown with home movies taken by the Rev. Solomon Sir Jones, who took priceless footage of African American life in his rural Oklahoma hometown. Motown connections are strong in two of the titles. Detroit-born Herb Jeffries stars in "The Bronze Buckaroo" (1939), one of several films in which he starred as the first black singing cowboy. Jeffries (sometimes billed as Herbert Jeffrey) had a long career in movies and on television as an actor, musician and singer-songwriter. He died in 2014 at the age of 100. The Detroit-made "Eleven P.M." (1928), which screens on Saturday afternoon, is fascinating on several levels, first for its exterior shots of black neighborhoods around the time it was made in the late 1920s and for its subject matter, which puts a surrealistic spin on a seemingly simple morality tale about a slick hoodlum who preys on the poor violinist who once tried to help him. The movie ends with one of the strangest images in all of cinema, in which a character returns in the form of a half-man/half-dog to take revenge on the man who killed him. Wilhelm likens the movie to something from surrealist artist and poet Jean Cocteau. Along with "The Blood of Jesus," it is a must-see title in the program. "Eleven P.M." is one of two features produced in Detroit by Cuba-born Richard Maurice, who worked as a tailor before launching the Maurice Film Co. in 1920. There are no known prints of his first feature, "Nobody's Children," from 1920, but "Eleven P.M.," which he also starred in, has only gained in reputation since it screened about 20 years ago at the DFT in a grainy and incomplete video print. The digital restorations (more than half of them screening in professional- quality DCP) will be an eye-opener for film buffs. With a film like "Eleven P.M.," the heightened clarity will have them reading street and window signs, license plates and even manhole covers looking for clues for how Detroit found its way into the film. https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064SAnldFil... 4/30/2018 EFTA01412469 Page 10 of 32 This is exactly what film historian Wheeler did when he first got his first VHS copy of "Eleven P.M." decades ago and examined it with a fellow scholar. "We must have watched that movie a hundred times. ... The best we could figure is that it was filmed on Gratiot near downtown," Wheeler said. "Some of the actual locations are lost to me now, but the idea of having any documentation of that area makes the film even more special." Many of these films were once considered lost. A now-legendary discovery of black films in a warehouse in Tyler, Texas, in the mid'80s resurrected many of the titles, including "The Blood of Jesus." In 1991, that movie became the first so-called race film to be added to the U.S. National Film Registry. Wilhelm notes that the continued efforts of individuals like Wheeler - along with institutions like Yale University, the Museum of Modern Art, the Library of Congress and the Martin Scorsese-led Film Foundation have discovered and preserved movies that would otherwise be lost. "The fact that any of these movies have survived is miraculous," he said. The "Pioneers of African-American Cinema" series schedule "The Flying Ace" (1926, director Richard E. Norman): Aviators are rivals on the ground in the air in this Hollywood-style adventure filmed in Jacksonville, Fla. (7 p.m. Fri.) "Dirty Gertie From Harlem, U.S.A." (1946, director Spencer Williams): This loose adaptation of W. Somerset Maugham's "Miss Sadie Thompson" pits a nightclub entertainer against a reformer at a Caribbean resort. (9:30 p.m. Fri.) "Eleven P.M." (1928, director Richard Maurice): A Detroit-filmed blend of melodrama and surrealism features director Maurice as a poor violinist whose family is preyed upon by a hoodlum he once helped. (3 p.m. Sat.) "Hell-Bound Train" (1930, directors James and Eloyce Gist): Created by African-American evangelists, this a 50-minute non-narrative film depicts drinking, dancing, gambling and other Jazz Age sins presided over by the figure of the devil. (3 p.m. Sat., showing on the same program with "Eleven P.M.") "Body and Soul" (1925, director Oscar Micheaux): Paul Robeson stars as twin brothers, one hard-working and the other a predatory minister in a tinted print with musical score by Paul Miller, a.k.a. DJ Spooky. (7 p.m. Sat.) "Ten Nights in a Bar Room" (1926, director Roy Calnek): Based on a popular 19th-Century temperance novel, the film features Charles Sidney Gilpin as a man whose alcoholism wrecks his life and those around him. (9:30 p.m. Sat.) "The Blood of Jesus" (1941, director Spencer Williams): Williams' religious parable overcame its low budget with inventive images about a murdered woman's journey to the afterlife. (2 p.m. Sun.) "Within Our Gates" (1920, director Oscar Micheaux): A young woman's plan to open an elementary school for the black community is thwarted by religious, social and political forces in this earliest EFTA01412470 surviving feature by an African-American director. (4:30 p.m. Sun.) "The Girl from Chicago" (1932, director Oscar Micheaux): Dramatic scenes and musical numbers punctuate this early sound film from Micheaux about a federal agent who falls in love while on assignment in Mississippi. (3 p.m. Feb. 18) "The Bronze Buckaroo" (1939, director Richard C. Kahn): The best of several films in which dashing, Detroit-born Herb Jeffries plays a black version of a Gene Autry-style singing cowboy, this time enlisted to locate a girl kidnapped by unscrupulous ranchers. (3 p.m. April 22) The "Pioneers of African-American Cinema" series Fri.-Sun., Feb. 18 and April 22 Detroit Film Theatre at the Detroit Institute of Arts 5200 Woodward Ave., Detroit 313-833-4005 www.dia.org/dft Free LOAD-DATE: March 3, 2017 LANGUAGE: ENGLISH https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412471 Page 11 of 32 GRAPHIC: Detroit Film Theatre A loose adaptation of "Miss Sadie Thompson," the 1946 film "Dirty Gertie From Harlem, U.S.A." pits a nightclub entertainer against a reformer. Detroit Film Theatre The Detroit-filmed "Eleven P.M." looks at black life in the '20s and puts a surrealistic spin on a morality tale. PUBLICATION-TYPE: Newspaper JOURNAL-CODE: dfp Copyright 2017 Detroit Free Press All Rights Reserved Return to List Note: Does not relate to money laundering or terrorist financing. FOCUS - 5 of 19 Documents mirror.co.uk April 28, 2016 Thursday 11:23 PM GMT Donald Trump denies rape of teenage girl at 'sex party with convicted paedophile Jeffrey Epstein'; The presidential hopeful categorically denies sexually assaulting and raping the woman at his New York residence back in 1994 BYLINE: By Christopher Bucktin SECTION: NEWS,WORLD NEWS LENGTH: 977 words US presidential hopeful Donald Trump has been accused of raping a woman when she was a teenager. The Republican front-runner has been accused of sexually assaulting the alleged victim with Jeffrey Epstein. The bombshell claim threatens to derail Trump's bid for the White House , as he is currently on course to win the party's nomination for the November election. The billionaire businessman responded last night saying the "allegations are not only categorically false". The alleged victim lodged her claim in the Central District Court of California on Tuesday. She accused Trump and fellow billionaire Epstein of "sexual abuse under threat of harm" and "conspiracy to deprive civil rights." In her claim, the woman "alleges she was enticed by promises of money and modelling career to attend a series of underage sex parties held at the New York City residence of defendant Jeffrey E Epstein and attended by Donald J Trump." She claims she was forced to perform a sex act on Trump, 69, and "engage in an unnatural lesbian sex act with her fellow minor and sex slave". She said on the "fourth and final sexual encounter" Trump "proceeded to forcibly rape the Plaintiff." The woman alleges in her claim she "loudly pleaded with defendant Trump to 'please wear a condom'." She claims the acts took place from June to September 1994. EFTA01412472 https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412473 Page 12 of 32 Read more : Girls aged 8 and 11 pepper-sprayed during Donald Trump rally chaos as opponents and supporters clash The woman alleges "she was subject to extreme sexual and physical abuse" from the age of 13. "On the first occasion," the alleged victim said she "was forced to manually stimulate Defendant Trump with the use of her hand ... until he reached sexual orgasm." She then goes on: "On the second occasion," the documents state, she "was forced to orally copulate Defendant Trump by placing her mouth upon Defendant Trump's erect penis until he reached sexual orgasm. In response to the allegations Trump told Radar Online: "The allegations are not only categorically false, but disgusting at the highest level and clearly framed to solicit media attention or, perhaps, are simply politically motivated. "There is absolutely no merit to these allegations. Period." Epstein has yet to comment on the allegations. The woman claims she was threatened with her life if she ever spoke of the abuse she alleges she suffered. In closing her statement she added: "[The alleged victim] was fully warned on more than one occasion by both defendants, Donald J. Trump and Jeffrey E, Epstein, that were she ever to reveal any of the details of the sexual and physical abuse that she had suffered as a sex slave for defendant Trump and defendant Epstein, that plaintiff Johnson and her family would be in mortal danger. "The Plaintiff was warned that this would mean certain death for herself and the Plaintiff family unless she remained silent forever on the exact details of the depraved and perverted sexual and physical abuse she had been forced to endure from the defendants." According to the documents, the woman is representing herself in the case. The allegations emerged less than 24 hours after Trump attracted criticism after proudly boasting while on the campaign trial in Indianapolis that he had been endorsed by Mike Tyson. The state is where the former world heavyweight champion was convicted of raping beauty pageant contestant Desiree Washington in 1992. He was jailed for three years for the attack. "Mike Tyson endorsed me," Trump told the crowd. "I love it. He sent out a tweet. Mike. Iron Mike. You know, all the tough guys endorse me. I like that, OK? "But Mike said, 'I love Trump. I endorse Trump.' And that's the end. I'm sure he doesn't know about your economic situation in Indiana. But when I get endorsed by the tough ones, I like it, because you know what? We need toughness now. We need toughness." Read more : Amal Clooney slams Donald Trump - without even saying his name Trump was a supporter of Tyson after the conviction, saying that "to a large extent" he was "railroaded." Trump had a financial interest in the case because Tyson's fights made money for his hotels. The businessman was previously accused of sexual assault by his ex-wife Ivana Zelnickova during their divorce in 1991. EFTA01412474 The Czech-American socialite accused him of "raping" her three years previously but later clarified her comment saying it was not in "a literal or criminal sense". Trump has always denied her allegation. The allegation had appeared in a sworn deposition made by Ivana Trump reported in the 1993 book 'Lost Tycoon: The Many Lives of Donald J. Trump', by Harry Hurt III. According the author, she accused him of rape after he allegedly attacked her in a "violent assault". In the book, it is alleged he ripped off her clothes to have sex with her. The book claims she told her friends: "He raped me." A spokesman for Trump wrongly claimed "you cannot rape your spouse". However 50 states throughout the US say it is illegal. Before Lost Tycoon was printed, Trump and his lawyers provided a statement from Ivana, published beneath the allegation of rape. https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412475 Page 13 of 32 It read: "During a deposition given by me in connection with my matrimonial case, I stated that my husband had raped me. "I wish to say that on one occasion during 1989, Mr Trump and I had marital relations in which he behaved very differently toward me than he had during our marriage. "As a woman, I felt violated, as the love and tenderness which he normally exhibited toward me, was absent. I referred to this as a 'rape,' but I do not want my words to be interpreted in a literal or criminal sense. "Any contrary conclusion would be an incorrect and most unfortunate interpretation of my statement which I do not want to be interpreted in a speculative fashion and I do not want the press or media to misconstrue any of the facts set forth above. "All I wish is for this matter to be put to rest." LOAD-DATE: April 28, 2016 LANGUAGE: ENGLISH PUBLICATION-TYPE: Newspaper; Web Publication JOURNAL-CODE: WEBDMI Copyright 2016 Trinity Mirror, Plc. All Rights Reserved Return to List Note: Does not relate to money laundering or terrorist financing. FOCUS - 6 of 19 Documents The New York Times January 7, 2015 Wednesday Late Edition - Final Lawyer Denies Suit's Allegations of Sex With a Minor BYLINE: By TIMOTHY WILLIAMS SECTION: Section A; Column 0; National Desk; Pg. 13 LENGTH: 591 words A well-known criminal defense lawyer, who along with Prince Andrew has been accused of having sex with an under-age girl, has denied the allegations in a federal court filing and asked that his name be removed from the case. In court papers filed Monday in the Southern District of Florida, representatives for the lawyer, Alan M. Dershowitz, called the claims that he had sex with a minor "outrageous and impertinent." The accusations against Mr. Dershowitz, a professor emeritus at Harvard Law School, and Prince Andrew, second son of Queen Elizabeth and fifth in line to the British throne, came in a motion filed Dec. 30 as part of a broader, long-running federal lawsuit. Mr. Dershowitz and Prince Andrew are not parties to the broader lawsuit. The motion claimed that Jeffrey E. Epstein, a wealthy businessman who has previously pleaded guilty to soliciting prostitution, had forced the girl, beginning at age 15, to have sex with "politically connected and financially powerful people," including Mr. Dershowitz and Prince Andrew. Buckingham Palace has vehemently denied the allegations against the prince. The woman, who was not identified in the court document, was repeatedly sexually abused by Mr. Epstein as a minor, the filing said, EFTA01412476 and was "required" to have sex with Prince Andrew and Mr. Dershowitz several times, including in Florida, New York, New Mexico and the Virgin Islands and on private planes. https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412477 Page 14 of 32 The motion also claimed that Mr. Dershowitz had abused other minors and had been "an eyewitness to the sexual abuse of many other minors" by Mr. Epstein and others. In a statement accompanying the court filing, Mr. Dershowitz said the encounters could not have occurred for several reasons, including the one time he had visited Mr. Epstein's house in New Mexico. The house was still under construction, and Mr. Dershowitz said he had stayed for about an hour. He was accompanied, he said, by his wife and daughter and another couple. "Mr. Epstein was not there," Mr. Dershowitz said. "Nor were there any young girls visible at any time." Bradley J. Edwards, a lawyer for the woman, declined to comment Tuesday. Mr. Dershowitz's lawyers said in their motion that the allegation was "nothing more than a vehicle to impugn the reputation of Professor Dershowitz, filed with the certain result of stirring up media interest." The motion argued that Mr. Dershowitz, who has previously served as Mr. Epstein's lawyer, should be allowed to remove his name from the case given that the allegations of sexual abuse had harmed his reputation. "Few accusations, if any, can launch such an immediate sensation as well as an enduring taint, notwithstanding their utter falsity and the impeccable reputation of the accused," the motion said. Further, the motion maintained that the accusation, while "categorically false," had no relevance to the underlying lawsuit. The broader lawsuit was filed in 2008 by two women who claimed that federal prosecutors had failed to adequately take into consideration their legal claims. While the Palm Beach police said they believed they had sufficient evidence for Mr. Epstein to be charged with at least four counts of unlawful sex with minors, he was allowed to plead guilty to a single count of soliciting an underage girl for prostitution and was sentenced to 18 months in prison. Subsequently, lawyers for two other women -- including the woman who claimed to have had sex as a minor with Mr. Dershowitz and Prince Andrew -- filed a motion seeking to join the lawsuit. A decision is pending. URL: http://www.nytimes.com/2015/01/07/us/alan-dershowitz-denies-allegations- of-sex-with-minor.html LOAD-DATE: January 7, 2015 LANGUAGE: ENGLISH GRAPHIC: PHOTO: Alan M. Dershowitz, in a court filing on Monday, called the claims of a suit "categorically false." (PHOTOGRAPH BY ANDREW INNERARITY/REUTERS) PUBLICATION-TYPE: Newspaper Copyright 2015 The New York Times Company Return to List Note: Does not relate to money laundering or terrorist financing. FOCUS - 7 of 19 Documents Daily Record and Sunday Mail April 29, 2016 Friday EFTA01412478 Edition 3; National Edition TRUMP 'RAPED ME AS A TEEN AT SEX PARTY'; LAWSUIT PRESIDENTIAL HOPEFUL SUED ; Woman makes astonishing underage 'slave' claims in US court BYLINE: CHRISTOPHER BUCKTIN https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412479 Page 15 of 32 SECTION: NEWS; Pg. 13 LENGTH: 588 words A WOMAN has claimed she was raped by Donald Trump as a teenager after being lured to sex parties. She accused the 69-year-old US Republican presidential hopeful and Prince Andrew's paedophile pal Jeffrey Epstein of assaulting her and using her as a sex slave. Katie Johnson, who has waived her right to anonymity as an alleged victim, lodged her claim in the Central District Court of California on Tuesday. Billionaire businessman Trump vehemently denies the allegations. Johnson also alleged she was threatened with her life if she ever spoke of the abuse claims. She said in the legal papers: "Katie Johnson was warned on more than one occasion by both defendants, Donald J Trump and Jeffrey E Epstein, that were she ever to reveal any of the details of the sexual and physical abuse she had suffered as a sex slave for defendant Trump and defendant Epstein, that plaintiff Johnson and her family would be in mortal danger. "Plaintiff Johnson was warned that this would mean certain death for herself and plaintiff Johnson's family unless she remained silent forever on the details of the depraved and perverted sexual and physical abuse she had been forced to endure from the defendants." Johnson, who is seeking £68.5million damages, accused the pair of "sexual abuse under threat of harm". She also "alleges she was enticed by promises of money and a modelling career to attend a series of underage sex parties held at the New York City residence of defendant Jeffrey E Epstein and attended by Donald J Trump". Johnson claims she was forced to perform sex acts on Trump and "engage in an unnatural lesbian sex act with her fellow minor and sex slave". The court papers add that on the "fourth and final sexual encounter" Trump "proceeded to forcibly rape the plaintiff ". She claims the acts took place from June to September 1994 and "she was subject to extreme sexual and physical abuse" from the age of 13. The allegations could derail Trump's bid to be president. But in response, he told Radar Online: "The allegations are not only categorically false but disgusting at the highest level and clearly framed to solicit media attention or, perhaps, are simply politically motivated. "There is absolutely no merit to these allegations. Period." According to the documents, Johnson is representing herself in the case. Trump has previously been accused of sexual assault by his ex-wife Ivana. During their divorce battle in 1991, the Czech-American socialite claimed he "raped" her three years previously. But she later clarified her comment saying it was not in "a literal or criminal sense". In February, as Trump's presidential run got under way, allegations resurfaced that he sexually assaulted and tried to rape a woman in EFTA01412480 the early 90s. She claimed in a federal lawsuit that he violated her "physical and mental integrity" when he touched her intimately without consent after her boyfriend went into business with him. She said it left her "emotionally devastated and distraught". The woman dropped the £90million lawsuit in Manhattan last month. Epstein, who was once a close friend of Prince Andrew, pleaded guilty to two state charges of soliciting a minor for prostitution and soliciting prostitution. He served 13 months after being sentenced in 2008. Investigators suspected the former New York financier of abusing 34 underage girls but lawyers failed to charge him or any of his "coconspirators" and instead offered him a secret plea bargain. They are false. There is absolutely no merit in these allegations. Period. DONALD TRUMP https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412481 Page 16 of 32 LOAD-DATE: April 29, 2016 LANGUAGE: ENGLISH GRAPHIC: ABUSER Epstein. Below, Ivana TrumpDENIAL Trump strongly rejects claims. Pic: Kevin Lamarque/ Reuters PUBLICATION-TYPE: Newspaper JOURNAL-CODE: DRC Copyright 2016 Scottish Daily Record & Sunday Mail Ltd All Rights Reserved Return to List Note: Does not relate to money laundering or terrorist financing. FOCUS - 8 of 19 Documents Daily News (New York) January 3, 2015 Saturday SPORTS FINAL REPLATE EDITION A ROYAL 'SEX SLAVE' Forced me to do it with him 3 times, she says Perverted N.Y. money big arranged it all A pack of lies, says spokesman for Brit family BYLINE: BY DAREH GREGORIAN and CORKY SIEMASZKO NEW YORK DAILY NEWS SECTION: NEWS; Pg. 8 LENGTH: 753 words PRINCE ANDREW has landed in a royal mess. The fifth in line to the British throne is accused of repeatedly bedding a 17-year-old "sex slave" of sleazy New York money manager Jeffrey Epstein. The blockbuster allegation - forcefully denied by Buckingham Palace - was made by a now 30-year-old woman identified as Jane Doe #3 in a Florida lawsuit. "Epstein instructed Jane Doe #3 that she was to give the Prince whatever he demanded and required Jane Doe #3 to report back to him on the details of the sexual abuse," the court papers state. The woman claims she was "forced" to have sex with the duke three times - once in a London apartment, another time in New York City, and during "an orgy with numerous other under-aged girls" on Epstein's private island in the Virgin Islands. Never happened, according to a royal mouthpiece. "This relates to long-running and ongoing civil proceedings in the U.S. to which the Duke of York is not a party," a royal spokesman said in a statement. "As such we would not comment on the detail. However, for the avoidance of doubt, any suggestion of impropriety with underage minors is categorically untrue." But in a statement to a British newspaper, Jane Doe #3 said she was being "unjustly victimized again." "These types of aggressive attacks on me are exactly the reason why sexual abuse victims typically remain silent and the reason why I did for a long time," she told The Guardian via her lawyers. "That trend should change. I'm not going to be bullied back into silence." There is no denying that Queen Elizabeth's second son and the Brooklyn-born Epstein were pals when the moneyman was convicted in 2008 for soliciting an underage girl for prostitution. https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- EFTA01412482 jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412483 Page 17 of 32 Andrew, best-known in America as the ex-husband of flame-haired Sarah (Fergie) Ferguson, even reportedly stayed at Epstein's Palm Beach mansion. In 2011, Vanity Fair reported that Andrew denied attending any of Epstein's "naked pool parties" or having sex with any of the underage girls at those bashes. Epstein, whose main residence appears to be a mansion on E. 71st St., wound up being sentenced to 18 months in prison and is now a registered sex offender. During one especially cringe-worthy deposition, Epstein was questioned about his allegedly "egg-shaped penis." He could not be reached Friday for comment. The allegations against Andrew were detailed in court papers filed this week at the Miami federal courthouse. In them, Jane Doe #3, and another woman identified as Jane Doe #4, asked to be included in a six- year-old lawsuit against Epstein brought by two other unnamed women. The women object to how the feds handled Epstein's case, and want authorities to reconsider a plea deal that allowed the money man to avoid much more serious federal charges and potentially longer prison time They claim both the prince and famed lawyer Alan Dershowitz lobbied the feds to give Epstein "a more favorable plea deal," the papers state. Jane Doe #3 also claimed she was forced to have sex with Dershowitz. "It's totally false," Dershowitz told the Daily News. "I don't know this woman and never had any sexual contact with her or any other underage person." Dershowitz said his accuser is "a serial fabricator" who also accused Bill Clinton of attending the same supposed orgy cited in the court papers, even though Secret Service records showed he was not there. Other than Jean Luc Brunel, owner of a modeling agency, Jane Doe #3 did not name any of the other rich and powerful men she said she was forced to service during the three years she was Epstein's "sex slave." Epstein, she claimed, pimped her out to "many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders." Epstein's aim, she charged, was "so that he could potentially blackmail them." Jane Doe #3 said she was 15 when she was recruited in 1999 by Ghislaine Maxwell, the daughter of late newspaper baron Robert Maxwell, who briefly owned The News. She said she had sex with the prince in Maxwell's London pad. When the British newspapers first reported that Maxwell allegedly procured underage girls for Epstein, she issued in a statement in 2011 in which she denied being Epstein's madam and called the charges "abhorrent and entirely untrue." [email protected] EFTA01412484 THE REGISTERED OFFENDER NAME: Jeffrey E. Epstein DESIGNATION: Sexual offender CRIME DESCRIPTION: Procuring a person under age of 18 for prostitution STATUS: Released - subject to registration LOAD-DATE: January 3, 2015 LANGUAGE: ENGLISH GRAPHIC: Ghislaine Maxwell (r. in 2014, and far r. with Epstein in 2000) recruited Jane Doe #3 in 1999, the accuser alleges. Prince Andrew (1.) and Jeffery Epstein walk through Central Park in 2010. Epstein's photo from Florida sex offender registry (top) and in https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412485 Page 18 of 32 court in 2008 (above). Accuser says one tryst was during orgy at Epstein's Virgin Islands estate (far 1.). PHOTO BY SPLASH, PHOTO BY ALBANPIX LTD/REX/REX USA, PHOTO BY JAE DONNELLY PUBLICATION-TYPE: Newspaper Copyright 2015 Daily News, L.P. Return to List Note: Possible match- sex trafficking could relate to money laundering. FOCUS - 9 of 19 Documents International New York Times January 5, 2015 Monday British royal is named in suit alleging unlawful sex; Motion claims that minor was forced into relations with prince and others BYLINE: EMMA G. FITZSIMMONS SECTION: NEWS; Pg. 5 LENGTH: 716 words ABSTRACT A filing charges that a teenage girl was forced to have sexual relations with several men, including Prince Andrew, Queen Elizabeth's second son. FULL TEXT A court filing in a civil case in Florida last week included new allegations against Jeffrey E. Epstein, a businessman who pleaded guilty to soliciting prostitution, and two other high-profile men: a member of the British Royal family and an American lawyer. The motion filed in United States District Court in the Southern District of Florida alleges that Mr. Epstein forced a teenage girl to have sexual relations with several men, including Prince Andrew, Queen Elizabeth's second son, and Alan M. Dershowitz, a professor emeritus at Harvard Law School. Both men have denied the allegations. The motion charges that the woman, not identified in court documents, had sexual relations as a minor with Prince Andrew in London and New York and on Mr. Epstein's private island in the U.S. Virgin Islands. Mr. Epstein told the woman to give the prince "whatever he demanded" and "report back to him on the details," the motion said. Buckingham Palace took the unusual step of issuing multiple statements to rebut the accusations. "This relates to longstanding and ongoing civil proceedings in the United States, to which The Duke of York is not a party," a palace spokesman said Friday in a statement, using the prince's title. "As such we would not comment on the detail. However, for the avoidance of doubt, any suggestion of impropriety with underage minors is categorically untrue." On Sunday, Buckingham Palace released a second statement, calling the allegations "false and without any foundation," The Associated Press reported. The motion was filed as part of a civil case involving Mr. Epstein, who was sentenced to 18 months in prison in 2008. The lawyers for two alleged victims have argued that the rights of the women were violated during the negotiation of Mr. Epstein's plea deal. The motion requests to add two more alleged victims to the case, including the woman, identified as "Jane Doe No. 3," who said she had EFTA01412486 sexual relations with Prince Andrew and Mr. Dershowitz when she was underage. On Saturday, Mr. Dershowitz said he "categorically and unequivocally" denied all of the allegations. He said he would file disbarment proceedings against the lawyers who filed the motion, Bradley 3. Edwards, a lawyer in Florida, and Paul G. Cassell, a former federal judge and a law professor at the University of Utah. https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412487 Page 19 of 32 "They are lying deliberately, and I will not stop until they're disbarred," Mr. Dershowitz said in a phone interview. Mr. Dershowitz, who served on Mr. Epstein's legal team and is perhaps best known for representing 0. J. Simpson, said he would also file an affidavit denying the claims. Mr. Cassell said in a statement on Saturday that the lawyers carefully investigated all of the allegations in their pleadings before presenting them. He said the lawyers would consider any sworn testimony or documentary evidence provided by Mr. Dershowitz. Mr. Cassell included a statement from "Jane Doe No. 3," saying that she was an innocent victim and was now "being unjustly victimized again." "I'm not going to be bullied back into silence," she said in the statement. In 2011, Prince Andrew resigned as an ambassador for British businesses abroad after a series of embarrassing revelations, including his friendship with Mr. Epstein. A New York money manager with several billionaire clients, Mr. Epstein, 61, had owned a home in Palm Beach, Fla. His listing on Florida's sexual offenders website said he now lived in St. Thomas in the Virgin Islands. Federal prosecutors had threatened to bring him to trial on several charges, but he later pleaded guilty to lesser state charges. His lawyer, Jack Goldberger, called the new allegations a "total fabrication." "These are old, salacious, leftover allegations that lawyers are attempting to reheat," he said in a statement. The new court documents claim that Mr. Epstein sexually abused the woman identified as "Jane Doe No. 3" starting when she was 15 years old and kept her as a "sex slave" from about 1999 to 2002. He made her available to other men, the motion said, to ingratiate himself with them and to obtain potential blackmail information. LOAD-DATE: January 4, 2015 LANGUAGE: ENGLISH PUBLICATION-TYPE: Newspaper Copyright 2015 International Herald Tribune All Rights Reserved Return to List Note: Possible match- sex trafficking could relate to money laundering. FOCUS - 10 of 19 Documents The New York Times January 4, 2015 Sunday Late Edition - Final Prince Is Named in Suit Alleging Sex With Minor BYLINE: By EMMA G. FITZSIMMONS SECTION: Section A; Column 0; National Desk; Pg. 16 LENGTH: 673 words A court filing in a civil case in Florida last week included new allegations against Jeffrey E. Epstein, a businessman who pleaded guilty to soliciting prostitution, and two other high-profile men: a member of the British Royal family and an American lawyer. The motion filed in United States District Court in the Southern District of EFTA01412488 Florida alleges that Mr. Epstein forced a teenage girl to have sexual relations with several men, including Prince Andrew, Queen Elizabeth's second son, and Alan M. Dershowitz, a professor emeritus at Harvard Law School. Both men have denied the allegations. https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412489 Page 20 of 32 The motion claimed that the woman, who was not identified in court documents, had sexual relations as a minor with Prince Andrew in London, New York and on Mr. Epstein's private island in the U.S. Virgin Islands. Mr. Epstein told the woman to give the prince "whatever he demanded" and "report back to him on the details," the motion said. Buckingham Palace took the unusual step of issuing a statement to rebut the accusations. "This relates to longstanding and ongoing civil proceedings in the United States, to which The Duke of York is not a party," a palace spokesman said in a statement, using the prince's title. "As such we would not comment on the detail. However, for the avoidance of doubt, any suggestion of impropriety with underage minors is categorically untrue." The motion was filed as part of a civil case involving Mr. Epstein, who was sentenced to 18 months in prison in 2008. The lawyers for two alleged victims have argued that the rights of the women were violated during the negotiation of Mr. Epstein's plea deal. The motion requests to add two more alleged victims to the case, including the woman, identified as "Jane Doe No. 3," who said she had sexual relations with Prince Andrew and Mr. Dershowitz when she was underage. On Saturday, Mr. Dershowitz said he "categorically and unequivocally" denied all of the allegations. He said he would file disbarment proceedings against the lawyers who filed the motion, Bradley J. Edwards, a lawyer in Florida, and Paul G. Cassell, a former federal judge and a law professor at the University of Utah. "They are lying deliberately, and I will not stop until they're disbarred," Mr. Dershowitz said in a phone interview. Mr. Dershowitz, who served on Mr. Epstein's legal team and is perhaps best known for representing O. J. Simpson, said he would also file an affidavit denying the claims. Mr. Cassell said in a statement on Saturday that the lawyers carefully investigated all of the allegations in their pleadings before presenting them. He said the lawyers would consider any sworn testimony or documentary evidence provided by Mr. Dershowitz. Mr. Cassell included a statement from "Jane Doe No. 3," saying that she was an innocent victim and was now "being unjustly victimized again." "I'm not going to be bullied back into silence," she said in the statement. In 2011, Prince Andrew resigned as an ambassador for British businesses abroad after a series of embarrassing revelations, including his friendship with Mr. Epstein. A New York money manager with several billionaire clients, Mr. Epstein, 61, had owned a home in Palm Beach, Fla. His listing on Florida's sexual offenders website said he now lived in St. Thomas in the Virgin Islands. Federal prosecutors initially threatened to bring him to trial on several charges, but he later pleaded guilty to lesser state charges. His lawyer, Jack Goldberger, called the new allegations a "total fabrication." "These are old, salacious, leftover allegations that lawyers EFTA01412490 are attempting to reheat by adding names of world leaders," he said in a statement. The new court documents claim that Mr. Epstein sexually abused the woman identified as "Jane Doe No. 3" starting when she was 15 years old and kept her as a "sex slave" from about 1999 to 2002. He made her available to other men, the motion said, to ingratiate himself with them and to obtain potential blackmail information. URL: http://www.nytimes.com/2015/01/04/us/prince-andrew-and-alan-dershowitz- are-named-in-suit-alleging-sex-with-minor.html LOAD-DATE: February 3, 2015 LANGUAGE: ENGLISH GRAPHIC: PHOTOS: Alan M. Dershowitz (PHOTOGRAPH BY VICTOR J. BLUE FOR THE NEW YORK TIMES) Prince Andrew, Duke of York (PHOTOGRAPH BY IAN GAVAN/GETTY IMAGES) In 2008, Jeffrey E. Epstein was sentenced to 18 months in prison in Florida after pleading guilty to soliciting prostitution. (PHOTOGRAPH BY UMA SANGHVI/PALM BEACH POST, VIA ASSOCIATED PRESS) PUBLICATION-TYPE: Newspaper Copyright 2015 The New York Times Company Return to List Note: Possible match- sex trafficking could relate to money laundering. https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412491 Page 21 of 32 FOCUS - 11 of 19 Documents The New York Times December 13, 2015 Sunday Late Edition - Final Dershowitz on the Defense BYLINE: By BARRY MEIER SECTION: Section BU; Column 0; Money and Business/Financial Desk; Pg. 1 LENGTH: 2607 words Last month, demonstrators at Johns Hopkins University interrupted Alan M. Dershowitz as he was giving a fiery speech defending Israel. The disruption normally would not have fazed Mr. Dershowitz, a former Harvard Law School professor who thrives on controversy and relishes taking on opponents in and out of the courtroom. The protesters, however, were not challenging his Middle East politics. Instead, they held up a sign reading, "You Are Rape Culture." Mr. Dershowitz knew what it meant. A decade ago, he had defended a friend, a money manager named Jeffrey E. Epstein, after authorities in Palm Beach, Fla., found evidence indicating that he was paying underage girls to give him sexual massages. The lawyer led a scorched-earth attack on the girls and, with a team of high-priced lawyers, cut a plea deal for Mr. Epstein that the local police said was too lenient. Over a five-decade career, Mr. Dershowitz has represented some of America's most prominent criminal defendants, including O. J. Simpson, Leona Helmsley, Mike Tyson and Claus von Bulow. Now, he finds himself on the other side, in a legal battle to clear his own name. At 77, he is struggling to absorb a bitter lesson -- that choosing the wrong client can exact its own cost. Last December, as part of a filing in an ongoing lawsuit, a woman charged that Mr. Dershowitz had sex with her when she was underage. Mr. Dershowitz called the claim an "outrageous lie" and over the last year has faced fallout from the accusation. "This is very serious," Mr. Dershowitz said last month at his apartment in Manhattan. "It involves my life, my legacy, my career, my history, my reputation." As he has defended that legacy, there has been a lawsuit, a counterclaim and even an accusation of an extortion plot against the billionaire Leslie H. Wexner, the chairman of L Brands, the retail empire that includes Victoria's Secret and Henri Bendel. It also has pitted Mr. Dershowitz against another of the nation's most famous lawyers, David Boies, who represents his accuser. The two lawyers are in an increasingly virulent war. In October, Mr. Dershowitz testified in a deposition that Mr. Boies had privately assured Mr. Dershowitz that he did not believe the claims of his client, "He said that he would not have taken this case if they had known she was going to accuse me," Mr. Dershowitz said recently. Mr. Boies responded that he never made such a statement. "The only explanation I have is that he is so emotional about this that he starts saying things without being careful," Mr. Boies said in an EFTA01412492 interview. "He has been someone whose approach in litigation is to attack the other side." In recent weeks, efforts to resolve the thicket of legal actions have begun, but Mr. Dershowitz insists that any settlement must clear him of sexual wrongdoing. The woman accusing Mr. Dershowitz has not filed a complaint with the authorities or a lawsuit against him. Instead, her allegation first emerged in a lawsuit that challenged Mr. Epstein's plea agreement. Mr. Dershowitz long taught his students that everyone, even those charged with the most heinous crimes, deserves a defense. But he now says he hesitated when Mr. Epstein called him in 2006 to ask for help because he was being investigated in connection with sex crimes. "I said, 'Look, you know Jeffrey, we're acquaintances, maybe that's not such a great idea," Mr. Dershowitz said "He said, 'No, no, no, I really need you to do this. The case, Mr. Dershowitz realized, "was right in my wheelhouse." In December 2005, a few months before he got that phone call, Mr. Dershowitz, his wife, children and grandchildren were vacationing at Mr. Epstein's Palm Beach mansion. The friendship between the men started in the mid-1990s on Martha's Vineyard. Not long after they met, Mr. Epstein invited Mr. Dershowitz to a birthday party for Mr. Wexner. Instead of accepting presents, the retail magnate had a tradition of asking friends to bring the most interesting person they had met over the last year. https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412493 Page 22 of 32 "He said, 'I'd like to bring you,"' Mr. Dershowitz said. By any measure, Mr. Dershowitz had led an interesting life. At 28, after clerking for a Supreme Court justice, Mr. Dershowitz became the youngest professor ever hired by Harvard Law School. It was outside the classroom, however, where his fame grew. He handled celebrated cases, appeared as television commentator and wrote many books, fiction and nonfiction. His account of the von Bulow case, "Reversal of Fortune," was made into a film in 1990 in which the actor Ron Silver donned a bushy mustache and aviator glasses to play Mr. Dershowitz. Along with enjoying celebrity, Mr. Dershowitz has also relished excoriating those he considers foes. He has taken on journalists, chided universities for coddling students and has been relentless in his defense of Israel, for example, accusing the writer Alice Walker of bigotry for refusing to allow an Israeli publisher to translate her novel "The Color Purple." Soon after meeting Mr. Epstein, Mr. Dershowitz became drawn into his rarefied world. Mr. Epstein was an enigmatic figure living in an Upper East Side mansion once owned by Mr. Wexner, who had reportedly been his mentor. A college dropout who once worked for Bear Stearns, Mr. Epstein said he handled investments for billionaires, though other than Mr. Wexner, he declined to identify them. Along with prominent businessmen, Mr. Epstein's friends included scientists, socialites and celebrities. He donated $30 million to finance scientific research at Harvard. President Bill Clinton and the actor Kevin Spacey flew aboard his private jet to Africa to discuss AIDS policy. Mr. Dershowitz also traveled on Mr. Epstein's plane and was invited to join his chats with Ehud Barak, the former Israeli prime minister. The men grew so close that Mr. Dershowitz solicited Mr. Epstein's feedback as he was writing books. In the interview in his Manhattan apartment, Mr. Dershowitz said Mr. Epstein was often surrounded by young women, but none struck him as underage. "I never got involved in his social life," he said. However, in late 2005, around the time when Mr. Dershowitz and his family were vacationing at Mr. Epstein's home, Palm Beach detectives were sifting through the trash outside. Acting on a tip, the authorities were investigating whether women working as assistants to Mr. Epstein were finding teenage girls to give him sexual massages. As the inquiry unfolded, detectives spoke with girls, some of whom were 15 or younger. After taking the case, Mr. Dershowitz responded, as was his way, with hardball tactics. He gathered information from the girls' postings on social media accounts, which he claimed showed they were drug users or had lied to Mr. Epstein about their age. He also helped put together a defense team that included Roy Black, the prominent trial lawyer, and Kenneth W. Starr, who led the investigation into President Bill Clinton's involvement with Monica Lewinsky. A local prosecutor, after meetings with Mr. Epstein's defense team, recommended that he be charged only with a misdemeanor. EFTA01412494 The chief of the Palm Beach police department was so outraged by the proposal that he wrote a letter to the Justice Department asking it to get involved in the case. Over time, authorities found evidence suggesting that Mr. Epstein had paid dozens of girls for sexual services. However, Mr. Dershowitz and other lawyers struck a deal in which Mr. Epstein agreed to plead guilty in a Florida court to one count of soliciting prostitution and another of procuring a person under 18 for prostitution. At the same time, federal officials agreed not to bring charges against Mr. Epstein or any of his potential co-conspirators. A Florida judge sentenced Mr. Epstein to 18 months in jail, though he was allowed to spend days working on the outside. He was released in 2009 after serving 13 months -- a shortened sentence for good behavior -- and had to register as a sex offender. For a criminal lawyer, the residue of a case can remain long after it ends. Twenty years ago, Mr. Dershowitz received death threats after he helped secure Mr. Simpson's acquittal on murder charges. And as a writer, he has imagined even worse plots. In one of his legal thrillers, "The Advocate's Devil," a lawyer discovers that a man for whom he had won an acquittal on rape charges is stalking his daughter. But Mr. Epstein's case has come back to haunt him in ways he never expected. "I have been criticized for the cases I've taken," he said, "but no one has ever criticized my personal life." The events that pulled him back into Mr. Epstein's orbit began unfolding in 2008. That year, two lawyers, Bradley J. Edwards and Paul G. Cassell, filed a lawsuit accusing the Justice Department of violating the rights of two women involved in Mr. Epstein's case by not allowing them to challenge his plea deal. Then, in201La l i tist s newseaper, The Mail on Sunday, published an article about another of Mr. stein's accusers, who was then living in Australia. Ms. IIIIIII, now a 32-year-old mother of three, told the newspaper that Mr. Epstein first started paying her for sexual services when she was 15. She traveling around the world on Mr. Epstein's jet. "Basically, I was training to be a prostitute for him and shared his interest in young girls," Ms. told the newspaper. https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 also described his friends who EFTA01412495 Page 23 of 32 Soon afterward, the lawyers suing the Justice Department interviewed Ms. and asked her if any of Mr. Epstein's friends might have information about his exploitation of girls. When they mentioned Mr. Dershowitz, she replied, "Yes," according to a transcript of the 2011 call. But last December, Mr. Dershowitz was drawn into the Justice Department lawsuit in an entirely different way. In a motion filed that month, Ms. claimed that she and Mr. Dershowitz had sex when she was a minor aboard Mr. Epstein's plane and at the money manager's homes in New York, New Mexico and the Virgin Islands. She also asserted that Mr. Epstein had "sexually trafficked" her to other powerful friends, including Prince Andrew, the Duke of York. Buckingham Palace rejected the claims against the prince. The judge later struck Ms. motion from the court filing, but by then, the accusations were being widely reported and broadcast. Mr. Dershowitz's phone was ringing with calls from reporters seekin comment. At every opportunity, he called Ms. claims "outrageous falsehoods" and called the lawyers who had made the filing, Mr. Edwards and Mr. Cassell, "villains" who helped fabricate the claims against him. Mr. Dershowitz said he would seek to have them disbarred, adding he had diary records and other information to show he was not at locations where Ms. claimed they had met. "They're prepared to lie, cheat and steal," Mr. Dershowitz said in an interview on CNN in January. The two lawyers, who declined to be interviewed for this article, filed a defamation lawsuit against Mr. Dershowitz, who responded with his own counterclaim. Mr. Boies's firm soon entered the fray. In late 2014, !1.!vyer at the firm, Boies, Schiller and Flexner, agreed to represent Ms. 1111111 in legal matters not directly related to the Justice Department lawsuit. When Mr. Dershowitz's name surfaced in that lawsuit, another lawyer at the firm agreed to represent him before realizing that Ms. was already a client. After the lawyer withdrew, Mr. Dershowitz expressed anger, saying that he had already told the firm his legal strategy before he was made aware of the conflict. Mr. Boies called the claim frivolous. "This idea of going to the press and asserting there is a conflict when you are not willing to make that claim in court is irresponsible," said the lawyer, who is perhaps best known for representing the Democratic presidential candidate Al Gore against George W. Bush in his challenge to the 2000 election results. That incident, however, was only the start of an escalating battle in which each man has accused the other of twisting words and spewing falsehoods. In October, during a deposition in the defamation case against him, Mr. Dershowitz testified that he had received a confidential phone call from a female friend of Ms. , who provided him with troubling information. According to Mr. Dershowitz's testimony, the woman said that Ms. had told her that she had been pressured to level sexual charges at Mr. Dershowitz. She also described a plan to accuse Mr. Wexner of EFTA01412496 having sex with Ms. when she was underage. "Virginia and her lawyers hoped to get $1 billion, B-I-L-L-I-O-N, $1 billion or half of his net worth," Mr. Dershowitz testified he was told, calling the plan an "extortion" attempt. A lawyer for Mr. Wexner, John W. Zeiger, did not respond to telephone calls. But a person briefed on the matter but who was not authorized to speak publicly about it said that Mr. Wexner had never met Ms. and no extortion attempt was made. Mr. Dershowitz says he wants nothing more than for Ms. to publicly retract her claims. He insists that Mr. Boies privately told him that he believed Mr. Dershowitz was innocent and that Ms. , while believing the allegations, was mistaken or confused. Mr. Boies says Mr. Dershowitz's claims are ludicrous. "I never said to him that I concluded that my clients' assertions were incorrect," he said. "I didn't say that. I didn't say anything like that." On Friday, Mr. Dershowitz filed an affidavit in a Florida state court, containing notes of his conversations with Mr. Boies that he says support his account. In it, he described Mr. Boies as telling him that if his client refused to withdraw her claim, "he could not ethically continue to represent her." Hours later, Mr. Boies's firm asked the Florida judge to seal Mr. Dershowitz's affidavit, and in a related filing, Mr. Boies described some of Mr. Dershowitz's assertions as "misleading" or "flatly untrue." In this intensifying game of legal chicken, it is not clear who will flinch first. Ms. 1111111 seems unwilling to yield and used a recent court filing to fire back at Mr. Dershowitz. "He is lying by denying that he had sex with me," said Ms. , who declined to be interviewed for this article. Mr. Dershowitz says he is no longer friendly with Mr. Epstein, who lives once again in his lavish Upper East side mansion. Still, like it or not, the lawyer remains tethered to him. Having defended Mr. Epstein, he said that he could not express his feelings about him. Several well-known criminal defense lawyers said that personal attacks were an occupational hazard. "Alan has never shied away from a fight in his life," said Abbe D. Lowell, a lawyer in Washington whose clients have included the lobbyist Jack Abramoff, who was convicted of corruption in 2006. "He has been that kind of lightning rod." https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412497 Page 24 of 32 For a man who has never lacked for self-confidence, Mr. Dershowitz now finds himself saddled with regret. Two clients, he said, have backed away from him because of his accuser's claims, and he worries whether universities like Johns Hopkins will invite him to give speeches or present him with awards. He now says he thinks that he should have said no when Mr. Epstein called. "I think I do regret having taken the case in light of everything that has happened since," he said. "If I could give back the money I made in this case and have this episode of my life erased, I'd do it." URL: http://www.nytimes.com/2015/12/13/business/alan-dershowitz-on-the- defense-his-own.html LOAD-DATE: December 13, 2015 LANGUAGE: ENGLISH GRAPHIC: PHOTOS: "This is very serious," said Alan Dershowitz, top, who defended Jeffrey Epstein, above, in a sexual misconduct case. "It involves my life, my legacy, my career, my history, my reputation." (PHOTOGRAPHS BY TODD HEISLER/THE NEW YORK TIMES RICK FRIEDMAN/CORBIS) (BU1) Mr. Dershowitz, above, last month in Manhattan, and below, in 1995 at the murder trial of O.J. Simpson in Los Angeles. Mr. Dershowitz, who has never lacked for self-confidence, now says he regrets taking his friend Jeffrey Epstein's case. (PHOTOGRAPH BY TODD HEISLER/THE NEW YORK TIMES REED SAXON) Over his five-decade career, Alan Dershowitz has defended celebrities such as, from left, Claus von Bulow, trailed by reporters in 1985 Leona Helmsley, with her husband, Harry, in 1991 Mike Tyson, in 1994 and O.J. Simpson, in 1995. (PHOTOGRAPHS BY DAVE TENENBAUM/ASSOCIATED PRESS MARIA BASTONE/AGENCE FRANCE-PRESSE -- GETTY IMAGES TOM RUSSO/ASSOCIATED PRESS SAM MIRCOVICH/REUTERS) (BU9) PUBLICATION-TYPE: Newspaper Copyright 2015 The New York Times Company Return to List Note: Possible match- sex trafficking could relate to money laundering. FOCUS - 12 of 19 Documents The New York Times February 18, 2017 Saturday Late Edition - Final Labor Pick's Role in Sex Case May Cloud Bid BYLINE: By BARRY MEIER SECTION: Section A; Column 0; National Desk; Pg. 14 LENGTH: 536 words For R. Alexander Acosta, President Trump's new pick for labor secretary, renewed attention on a salacious lawsuit may not come at a great time. A decade ago, Mr. Acosta, the United States attorney in Miami at the time, played a role in what critics said was a lenient plea deal EFTA01412498 given to a wealthy New Yorker, Jeffrey E. Epstein, who was accused of paying underage girls for sexual massages. https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064&dnldFil... 4/30/2018 EFTA01412499 Page 25 of 32 Now, as senators consider Mr. Acosta's nomination for a cabinet position, the sordid details of Mr. Epstein's case are set to receive another public airing. The setting will be a federal courtroom in Manhattan, where a trial is expected to start in the spring in a defamation lawsuit brought against one of Mr. Epstein's associates, Ghislaine Maxwell, daughter of the British publishing mogul Robert Maxwell. The lawsuit was filed in 2015 b , who said she was one of Mr. Epstein's victims. Ms. has accused Ms. Maxwell of helping to procure under2221Els to engage in sexual activities with Mr. Epstein. In the suit, Ms. 1111111 contends that Ms. Maxwell has defamed her by calling those accusations "untrue" and "obvious lies." Ms. Maxwell, in turn, ar ues that she had the right to publicly defend herself against Ms. accusations. The trial, if it proceeds, will probably produce a stream of headlines about sex-trafficking, and could renew scrutiny of Mr. Acosta's role in Mr. Epstein's plea deal. The matter goes back to 2005, when Mr. Acosta was the top federal prosecutor in Miami. Police detectives in Palm Beach, Fla., where Mr. Epstein had a home, discovered that women working for him were finding teenage girls to give him sexual massages. Some of the girls were 15 or younger, the authorities said. Mr. Epstein hired a top-tier defense team that included Alan M. Dershowitz. After meeting with the defense lawyers, a state prosecutor recommended that Mr. Epstein be charged only with a misdemeanor. The Palm Beach police chief was so angry about the proposal that he wrote a letter to the Justice Department asking that it get involved in the case. Mr. Epstein's lawyers eventually struck a deal under which he agreed to plead guilty in a Florida court to one count of soliciting prostitution and another of procuring a person under 18 for prostitution. As part of the agreement, Mr. Acosta's office agreed not to bring federal charges against Mr. Epstein or any of his potential coconspirators, court papers show. The deal has since been denounced by critics as an example of the way that prosecutors buckle to pressure brought by highpowered lawyers on behalf of a wealthy client. Mr. Acosta has defended the agreement as the toughest one prosecutors could get based on the evidence they had at the time. As a cabinet nominee, Mr. Acosta may soon face questions about that decision. And Ms. and her lawyers have not shied away from publicitiiiiiii In 2014, Ms. , whose maiden name was , accused Mr. Dershowitz, the lawyer, of having sex with her when she was a teenager, an allegation he adamantly denied. The accusation led to a series of legal actions between Mr. Dershowitz and Ms. lawyers that were settled last year. URL: http://www.nytimes.com/2017/02/17/business/alexander-acosta-jeffrey- epstein-case.html EFTA01412500 LOAD-DATE: February 18, 2017 LANGUAGE: ENGLISH PUBLICATION-TYPE: Newspaper Copyright 2017 The New York Times Company Return to List Note: Does not relate to money laundering or terrorist financing. FOCUS - 13 of 19 Documents The New York Times https://www.lexisnexis.com/dd/delivery/PrntDoc.do?- jobHandle=1825:640721064UnldFil... 4/30/2018 EFTA01412501 Page 26 of 32 January 17, 2015 Saturday Late Edition - Final Prince, Back in News, Faces Curse of the 'Spare' BYLINE: By STEVEN ERLANGER SECTION: Section A; Column 0; Foreign Desk; Pg. 4 LENGTH: 1191 words LONDON -- It's not easy being the spare, the second son trained for little except hanging around waiting for your older brother to die, or to have children who then outrank you. Being Prince Andrew, the Duke of York, is a lot like being the vice president of the United States -- only for life. As he has aged, and fallen further down the line of succession (at 54, he is now fifth in line to the throne), Prince Andrew has faced the problem of what to do with himself -- being public but not prominent and has not always made the best choices, even he has admitted. To be a spare means to have a vague but unclear purpose in life, said Peter York, a social commentator. "There are lots of things by definition you cannot do, that are potential embarrassments. And there are lots of things you cannot do because you're not trained for them." Prince Andrew is back in the news with the resurgence of old allegations that he had sex with a minor provided by an old, wealthy friend of his, Jeffrey E. Epstein, who was jailed in 2008 and served 13 months of an 18-month sentence for soliciting a minor for prostitution. In 2011, when the allegations against Prince Andrew surfaced, and again this month, when they re-emerged in a filing in a Florida court, Buckingham Palace issued explicit denials, saying that Andrew did not have sex with the woman bringing the complaint or, for that matter, with any minor. The allegations by the woman, whom the palace named as , now 30, married and with three children, were well ventilated in 2011 by the British press and in the magazine Vanity Fair. The controversy over Prince Andrew's continuing friendship with Mr. Epstein caused the prince to resign that year after a decade as Britain's special representative for international trade and investment. The main difference now appears to be a direct allegation by Ms. Roberts through her lawyers of specifically sexual contact with Prince Andrew and other public figures, like the lawyer Alan Dershowitz, who has said he intends to countersue to put Ms. Roberts under oath. The new attention to old allegations has brought renewed embarrassment to the monarchy, which had been basking in friendly British news coverage of Prince William and his wife, the former Kate Middleton, and their young son, and of the dutiful Queen Elizabeth II. The Prince Andrew furor erupted just days after another controversy over a postponed BBC documentary about how Prince Charles, Andrew's elder brother, tried to rebuild his own damaged public reputation EFTA01412502

Technical Artifacts (12)

View in Artifacts Browser

Email addresses, URLs, phone numbers, and other technical indicators extracted from this document.

Domainmirror.co.uk
Domainwww.dia.org
Phone313-833-4005
SWIFT/BICCORRECTIONS
SWIFT/BICENFORCEMENT
URLhttp://www.nytimes.com/2015/01/04/us/prince-andrew-and-alan-dershowitz
URLhttp://www.nytimes.com/2015/01/07/us/alan-dershowitz-denies-allegations
URLhttp://www.nytimes.com/2015/12/13/business/alan-dershowitz-on-the
URLhttp://www.nytimes.com/2017/02/17/business/alexander-acosta-jeffrey
URLhttps://www.lexisnexis.com/dd/delivery/PrntDoc.do

Link to Specific Page

Share a direct link to a specific page in this document:

https://epsteinexposed.com/documents/sd-10-EFTA01412453?page=[page_number]

Related Documents (6)

DOJ Data Set 10CorrespondenceUnknown

EFTA Document EFTA01412453

0p
DOJ Data Set 10OtherUnknown

EFTA01412453

63p
Court UnsealedNov 8, 2019

Alan Dershowitz Extended Rebuttal to [REDACTED - Survivor] Allegations

Case 1:19-cv-03377-LAP Document 90 Filed 11/07/19 Page 1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA L. GIUFFRE, Plaintiff, Civil Action No. 19-cv-03377-LAP v. ALAN DERSHOWITZ, Defendant. ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTERCLAIMS Defendant Alan Dershowitz (“Dershowitz”) hereby answers the Complaint of Plaintiff [REDACTED - Survivor] (“Giuffre”) and asserts Affirmative Defenses and Counterclaims as follows: ANSWER NATURE OF THE ACTION 1. This paragrap

274p
Court UnsealedNov 12, 2025

Epstein _ 001

yl . on on TRI ILITYUIY & JOHN CONNOLLY WITH Tim MALLOY A POWERFUL BILLIDNAIRE. THE SEX SEANDAL THAT UNDID HIM. AND ALL § THE JUSTIGE THAT MONEY CAN BUY: : | THE SHOCKING TRUE STORY OF JEFFREY EPSTEIN ‘ de HOUSE_OVERSIGHT_010477 5 ~ I] i A { doit see what it adds to the Rf ¥ ? Bl pois atm Desc . rely . BY crn nal ” CRE! hat © MO — Ju, a that time, no criminal L : 2 a irs had been lnuached. And In fa od he curaors of Fpstein's dealings [5 > a 110 be just that — Tumors. a J ie lawyers, his ed

1935p
House OversightFinancial RecordNov 11, 2025

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

The complaint provides a dense web of alleged connections between Alan Dershowitz, Jeffrey Epstein, former U.S. Attorney Alexander Acosta, and the 2008 non‑prosecution agreement (NPA). It cites specif Roberts alleges she was trafficked by Epstein from 2000‑2002 and forced to have sex with Dershowitz. Dershowitz is accused of helping draft and pressure the government into the 2008 NPA that shielded

87p
Court UnsealedNov 8, 2019

Epstein Exhibits

Case 18-2868, Document 278, 08/09/2019, 2628230, Page1 of 648 EXHIBIT A Case 18-2868, Document 278, 08/09/2019, 2628230, Page2 of 648 6114:2016 Prince Andrew and girl, 17, who sex o?er?er friend flew to Britain to meet him Daily Mail Ontine Daily ail .com Home I U.K. Sports Showbiz [Australia [Femail [Health [Science [Money [Video [Travel [Columnists tr am .22: ,t Latest wisestii?tr?e Prince Andrew and the 17-year-old girl his 1 sex offender friend flew to Britain to

648p

Forum Discussions

This document was digitized, indexed, and cross-referenced with 1,400+ persons in the Epstein files. 100% free, ad-free, and independent.

Annotations powered by Hypothesis. Select any text on this page to annotate or highlight it.