EFTA00191396

company of underage females subsequently identified as victims of Mr. Epstein's criminal 
molestations. This information is derived from both sworn testimony and private interviews." 
Exhibit 14. Despite providing Dershowitz with the basis for wanting his deposition, and the 
assurance that questions regarding privileged information would not be asked, Dershowitz did 
not cooperate. 
2015 
After Jane Doe No. 3 moved to intervene in this case, Dershowitz said "what they 
[victims' counsel] have done is so under-handed . . . not giv[ing] me an opportunity to disprove 
it. That's Kafkaesque." UMAR News, 
Following public statements such as these, on January 3, 2015, attorney Jack Scarola 
immediately sent an e-mail to Dershowitz, requesting an opportunity to take his deposition: 
Dear Mr. Dershowitz: 
Statements attributed to you in the public media express a willingness, 
indeed a strong desire, to submit to questioning under oath regarding your alleged 
knowledge of Jeffrey Epstein's extensive abuse of underage females as well as 
your alleged personal participation in those activities. As I am sure you will 
recall, our efforts to arrange such a deposition previously were unsuccessful, so 
we welcome your change of heart. Perhaps a convenient time would be in 
connection with your scheduled appearance in Miami on January 19. I assume a 
subpoena will not be necessary since the deposition will be taken pursuant to your 
request, but please let us know promptly if that assumption is inaccurate.... Thank 
you for your anticipated cooperation. 
Exhibit 15. As of the date of this filing, Dershowitz has completely ignored this request, while 
simultaneously continuing to publicly protest his inability to challenge the allegations against 
him in a legal proceeding. 
14 
EFTA00191416

In light of these opportunities that have been extended to Dershowitz previously to 
answer any questions about his knowledge of (and even participation in) Epstein's sex 
trafficking, his claim that he needs a forum in this Court to defend his reputation rings hollow.9
For the sake of completeness — and to show a sinister pattern — it is also worth noting that 
each of the other four individuals Jane Doe No. 3 identified by name in her motion (Jeffrey 
Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have also all been afforded 
opportunities to explain themselves — and all four have declined to take them. 
Epstein. The Court is familiar with Jeffrey Epstein's repeated invocations of the Fifth 
Amendment when asked questions about his sexual abuse of young girls, including Jane Doe No. 
I, Jane Doe No. 2, and Jane Doe No. 3. See generally Exhibit 16 at 1-7. 
Marvell. In 2009, undersigned counsel (Brad Edwards) served Ghislaine Maxwell with 
a subpoena for a deposition in a civil case against Jeffrey Epstein. After extensive discussion 
and coordinating a convenient time and place, as well as ultimately agreeing to a confidentiality 
agreement prepared by Maxwell's attorney, at the eleventh hour Maxwell's attorney informed 
the undersigned that Maxwell's mother was very ill and that consequently Maxwell was leaving 
the country with no plans to return. The deposition was cancelled. Yet a short time later, 
Maxwell was photographed at Chelsea Clinton's wedding in Rhinebeck, New York, confirming 
the suspicion that she was indeed still in the country and willing to say anything to avoid her 
deposition. 
9 The difficulty in scheduling this deposition also fits into a pattern for Dershowitz. In around 2005 to 
2006, Dershowitz was Jeffrey Epstein's "primary" lawyer. When the Palm Beach Police Department 
tried to interview Epstein, Dershowitz pretended that Epstein was willing to answer questions. 
Dershowitz set up, then cancelled, Epstein interviews with the police "several times." See B.B. 
Epstein, 
No. 502008CA037319XXXX MB AB, Depo. of Police Chief Michael Reiter at 80 (Palm Beac Cty. Cir. 
Ct. Nov. 23, 2009). 
15 
EFTA00191417

Brunel. In 2009, undersigned counsel (Brad Edwards, representing Jane Doe) served 
Jean Luc Brunel with a subpoena for a deposition before this court in Doe'. Epstein, No. 9:08-
cv-80I19-KAM (S.D. Fla.). Brunel's attorney asked counsel for Jane Doe to postpone the 
scheduled deposition date. Jane Doe's counsel agreed, and then Brunel's attorney cancelled the 
rescheduled deposition date. Brunel's counsel represented that Brunel was outside the country 
and thus unavailable. But later sworn deposition testimony revealed that Brunel was actually 
inside the country at this time — indeed, he was hiding at Epstein's Palm Beach home. All this 
was brought to the Court's attention via a motion for sanctions. DE 483. This is just another 
example of the inner circle of Epstein's friends refusing depositions to answer questions. 
Prince Andrew. In 2011, Jack Scarola, representing Brad Edwards in the Epstein'. 
Edwards case, faced procedural impediments to obtaining a sworn deposition from a member of 
the British Royal family. Accordingly, he publicly invited the voluntary testimony of Prince 
Andrew, explaining: "We would be very keen to speak with Prince Andrew, given his 
relationship with Jeffrey Epstein. . . . We have reason to believe that Prince Andrew has been in 
the company of Mr. Epstein while Mr. Epstein has been in the company of under-aged children." 
http://effiefolkerts.blogspot.com/2011/03/convicted-paedophile-jeffrey-epstein-is.html. 
Prince 
Andrew never responded. 
Two weeks ago, after Jane Doe No. 3 and Jane Doe No. 4 moved to join in this action, a 
spokesperson for Prince Andrew denied Jane Doe No. 3's allegations, without providing any 
explanation of what the Prince was doing with this minor girl late at night in a private setting. 
Accordingly, on January 14, 2015, Jack Scarola sent Prince Andrew a certified letter requesting 
his voluntary cooperation in answering questions about his sexual interactions with Jane Doe No. 
16 
EFTA00191418

3. See Exhibit 17. The letter requested an opportunity to take a statement under oath from 
Prince Andrew. Federal Express has informed us that the letter has been refused by the recipient. 
In light of these avoided opportunities by Dershowitz — as well as Epstein, Maxwell, 
Brunel, and Prince Andrew — to answer questions under oath regarding Epstein's trafficking of 
young girls, there is no good reason that the Court should now allow a special, discretionary 
opportunity to intervene to respond to the allegations. 
C. DERSHOWITZ SHOULD NOT BE ALLOWED TO INTERVENE TO STRIKE 
ALLEGATIONS RELEVANT TO ISSUES PENDING BEFORE THE COURT. 
The Court should also deny Dershowitz's motion for intervention because it would be a 
pointless exercise. 
Citing Rule 12(0 of the Federal Rules of Civil Procedure, Dershowitz seeks to intervene 
to strike "immaterial, impertinent, or scandalous matter." DE 282 at 7. Dershowitz contends 
that Jane Doe No. 3's allegations regarding sexual contacts with him "have nothing to do with 
any relevant issues in this case." Id. at 3. Courts generally "disfavor the motion to strike . . . ." 
Moore's Federal Practice § 12.37[1] (3d ed. 2014) (internal citation omitted). "Striking 
allegations from a pleading 'is a drastic remedy to be resorted to only when required for the 
purposes of justice,' and only when the allegations to be stricken have 'no possible relation to the 
controversy.' Larise Atlantis, Inc.'. Pac. Ins. Co., No. 10.61583-CIV, 2011 WL 1584359 at •2 
(S.D. Fla. 2011) (quoting Augustus' Bd. of Pub. Instruction, 306 F.2d 862, 868 (5th Cir.1962)). 
"If there is any doubt as to whether the allegations might be an issue in the action, courts will 
deny the motion." In re 2TheMart.com. Inc. Sec. Litig., 114 F. Supp. 2d 955, 965 (C.D. Cal. 
2000) (emphasis in original). Just as with a motion to dismiss for failure to state a claim, in 
ruling on a motion to strike "the Court must view the pleadings in a light most favorable to the 
17 
EFTA00191419

pleading party." Id. Any motion to strike by Dershowitz would be meritless, because Jane Doe 
No. 3's allegations are pertinent to at least eight pending issues. 
I. The Pending Motion to Intervene. 
Of course, the first reason that Jane Doe No. 3 made her allegations was to support her 
pending motion to join this action. As the Court has seen from the chronology recounted above, 
victims' counsel engaged in months of efforts to reach a stipulated motion for joinder by Jane 
Doe No. 3 and Jane Doe No. 4 that would not have required reciting any specific factual 
allegations. The U.S. Attorney's Office refused to provide any answer to that request, until 
finally tersely objecting (without providing any rationale). Once the joinder motion became 
contested, Jane Doe No. 3 then needed to proffer allegations supporting her entry into the case. 
To join this CVRA action, Jane Doe No. 3 must first show that she is the "victim" of a 
federal crime, 18 U.S.C. § 3771(e) — and, further, that the crime is one that implicates persons 
covered by the NPA. Jane Doe No. 3 alleged that she was sexually abused by Jeffrey Epstein. 
But she also focused much of her joinder motion on the fact that she was the victim of a "sex 
trafficking scheme" organized by Epstein. DE 280 at 3. To prove site is a victim of sex 
trafficking in violation of 18 U.S.C. § 1591, Jane Doe must demonstrate that she was recruited, 
transported, or harbored while under the age of I8 and "cause(d) to engage in a commercial sex 
act." Accordingly, she briefly described the trafficking scheme, including identifying several 
persons to whom she was trafficked (i.e., Dershowitz and Andrew).1° The fact that Dershowitz 
10 In his motion, Dershowitz alleges that Jane Doe No. 3 identified these two names solely to stir up 
media attention. DE 282 at 2. But Dershowitz does not address the obvious reasons for the identification 
- i.e., that he was an attorney who helped draft the NPA and that a sex act with Prince Andrew in London 
affected "foreign commerce" — part of a jurisdictional requirement of the statute. See 18 U.S.C. § 
1591(a)(1). In addition, Jane Doe No. 3 has also alleged that she was trafficked to "many other powerful 
men, including politicians and powerful business executives." Ex. I at 1 58. The names of these persons 
could have been included in her pleading and would have created significantly more media attention than 
18 
EFTA00191420

(and Prince Andrew) engaged in a "sex act" with her is simply a required element of her proof 
that she is the victim of a sex trafficking crime. 
Sexual trafficking is not the only crime that could support Jane Doc No. 3's joinder in 
this case. There are also various federal sex offenses, such as travel with intent to engage in 
illicit sexual conduct, 18 U.S.C. § 2423(b), which Jane Doe No. 3's proffer supported. And 
perhaps most obviously, Jane Doe No. 3 was the victim of a conspiracy tinder 18 U.S.C. § 371. 
Dershowitz, of course, was a co-conspirator against her — thereby directly implicating the NPA. 
In her pleading, Jane Doe No. 3 alleged only the fact that a sex act took place, not the nature of 
the sex act nor any "unnecessary detail." Begay I. Public Service Co. of New Mexico, 710 
F.Supp.2d 1161 (D. N. Mex. 2010)." 
2. The Pending Discovery Issues. 
Another reason Jane Doe No. 3 cited in her pleading for specifically naming Dershowitz 
(and Prince Andrew) is that the Court has before it a pending discovery dispute involving 
documents relating to these two people. See DE 280 at 10 (citing DE 225 at 7.8 (discussing DE 
48 at 16-18)). As the Court is aware, on December 1, 2011, Jane Doe No. 1 and Jane Doe No. 2 
propounded a Request for Admission (RFA) asking the Government to admit that it possesses 
"documents, correspondence or other information reflecting contacts with the Department 
the names that she did include. If the Court would like proof of this assertion, counsel would request 
leave to provide an ex parte, sealed submission of the names of the other immediately recognizable 
persons who either observed or participated in the trafficking of Jane Doe No. 3. 
Where sexual issues are relevant to a case, they must not be stricken. See, e.g., Zdenekl School Bd. of 
Broward County, No. 07-CV-61110, 2007 WL 4521489, at •2 (S.D. Fla. Dec. 19, 2007) ("given the 
Eleventh Circuit standards on what constitutes actionable sexual harassment, the allegations in question 
[with one exception] do not rise to the level of what is considered 'redundant, immaterial, impertinent, or 
scandalous'"); Dowel. Corr. USA, No. CIVS071790LICKEFB, 2009 WL 2591146 at *3 (E.D. Cal. Aug. 
20, 2009) ("these statements [referring to sexual contact] are made in the . . . larger context of alleging 
that the defendants' financial misconduct stemmed in pan from an intention to cover up sexual 
misconduct. As such, the court agrees that the allegations are no more scandalous than those that would 
be asserted in any cause of action relating to sexual harassment."). 
19 
EFTA00191421

between May 2007 and September 2008 on behalf of Jeffrey Epstein by . . . (b) Andrew Albert 
Christian Edward (a/Icla Prince Andrew, Duke of York); (c) Harvard Law Professor Alan 
Dershowitz." While the Government denied that it had documents reflecting contacts by Prince 
Andrew, it specifically admitted possessing documents reflecting contacts by Dershowitz. Gov't 
Answer to RFA #6. The two victims further requested the Government admit that it possessed 
"information (including telephone logs and emails) reflecting contacts between Bruce E. 
Reinhart and persons/entities affiliated with Jeffrey Epstein (including . . . Harvard Law 
Professor Alan Dershowitz). The Government admitted this fact. Gov't Answers to RFA #16. 
These RFA's tie into a major discovery battle that is currently before the Court. Related 
to the RFA's, on October 3, 2011, Jane Doe No. I and Jane Doe No. 2 propounded Request for 
Production (RFP) #8, seeking "all correspondence, documents, and other information regarding 
Epstein's lobbying efforts to persuade the Government to give him a more favorable plea 
arrangement and/or non-prosecution agreement, including efforts by 
. . Andrew Albert 
Christian Edward (a/k/a Prince Andrew, Duke of York), [and) Harvard Law Professor Alan 
Dershowitz." The two victims also propounded RFP #21, requesting all documents relating to 
the NPA, including documents in the Government's possession from "defense attorneys 
representing Epstein (including . . . Alan Dershowitz)" and from "agents acting in support of 
Epstein (including . . . Andrew Albert Christian Edward (Ala Prince Andrew Duke of York))." 
The Government responded to these (and other RFPs) by asserting privilege over 14,825 
pages of documents that it provided to the Court.'2 But contrary to the Court's specific direction, 
the Government did not provide a log that "clearly identifies each document[] by author(s), 
addressee(s), recipient(s), date, and general subject matter . . . ." DE 190 at 2. Accordingly, 
The Government has also raised relevancy objections to producing the documents, as discussed below. 
20 
EFTA00191422

there is no way to determine which of the documents that the Government has provided to the 
Court are responsive to which of the victims' discovery requests — including which documents 
relate to Dershowitz. See DE 265 at 1-2. The Govermnent then asserted a host of privileges, 
including qualified privileges, such as deliberative process privilege, investigative privilege, and 
the work product doctrine. Qualified privileges require the Court to engage in a far-ranging 
inquiry that balances competing interests. As the victims have recounted in their (currently-
pending) objections to the Government's assertion of privilege, the Court must weigh such things 
as "the 'seriousness' of the litigation" (DE 265 at 9), "the importance of the information sought 
to the plaintiff's case" (DE 265-1 at 22), and whether there is a "compelling need" for disclosure 
(DE 265 at 14). Clearly Jane Doe No. 3's allegations factor into this balancing of interests about 
production of documents relating to Dershowitz (and others). 
3. Motive 
When the Court ultimately rules on the underlying substantive issue of whether the 
Government violated the victims' rights, motive will be a central issue. The Government has 
repeatedly asserted benign motivations for not revealing the NPA to the victims, and the victims 
have strongly contested those assertions. See, e.g., DE 266 at 10 ("Motive is clearly in dispute in 
this case . . . ."). The NPA itself contains several unusual provisions that invite debate over how 
they came into existence — such as the "confidentiality" provision that illegally barred disclosure 
to the victims and the "blank check" co-conspirator immunity provision discussed immediately 
below. An important question is whether these strange provisions were crafted accidentally — or 
as part of a deliberate plan to keep the victims in the dark, as the victims are contending. See, 
e.g., DE 48 at 11 (alleging that the Govermnent and defense counsel decided that the NPA 
should be "kept from public view because of the intense public criticism that would have 
21 
EFTA00191423

resulted from allowing a politically-connected billionaire who had sexually abused more than 30 
identified minor girls to escape from federal prosecution with only a county court jail sentence"). 
The fact that an important attorney on the defense team had strong personal reasons for resolving 
the case without a public trial bears directly on this question, by showing motivation to reach a 
secret deal. Dershowitz's need to keep his abuse secret, and his direct personal knowledge of 
Epstein's abuse, also goes to issues revolving around whether the defense team engaged in a 
"yearlong assault on the prosecution and prosecutors," as alleged by former U.S. Attorney 
Alexander Acosta. See DE 266 at 12.13
Issues pertaining to motive can always be pursued, particularly when a case is in an early 
discovery phase. See, e.g., Gelabertl. Stare, 407 So. 2d 1007, 1010 (Fla. 5th DCA 1981). And 
"motive is always relevant in a criminal case, even if it is not an element of the crime." United 
Stalest. Hill, 643 F.3d 807, 843 (11th Cir. 2011) (internal quotation omitted). 
When speaking not to the Court but rather to the media, Dershowitz has clearly admitted 
the relevance of Jane Doe No. 3's allegations about him to issues of motive. Speaking on CNN, 
for example, Dershowitz stated that he was being "targeted" precisely because his involvement 
in Epstein's sexual trafficking would help "blow up" the plea agreement: 
13 In his Supplement to his Motion for Limited Intervention, Dershowitz claims that only infonnation 
relevant to this case is information known by the Government before September 24, 2007 — the latest date 
on which, according to Dershowitz, the Government made the decision not to pursue federal criminal 
charges against Epstein. DE 285 at 1. Dershowitz appears to be unaware that the Government told the 
victims well after that date that the Government was still "investigating" the case. DE 48 at 16. In 
addition, what knowledge the Government had of Epstein's trafficking crimes before September 24, 2007, 
is very much a disputed issue. For example, the victims believe that among the 14,825 pages of discovery 
currently before the Court in camera are many documents proving the Government's had knowledge 
while it was negotiating the NPA that Epstein was trafficking underage girls for sex to Dershowitz and 
others. Indeed, it is likely that documents pertaining to the trafficking of Jane Doe No. 3 herself are found 
in those pages, and she would ask the Court to pay particular attention to such documents as part of its in 
camera review. This evidence provides a further reason the Government wanted to conceal the NPA 
from the victims — and the public: to avoid the outcry that would have arisen if it was known that 
prosecutors were giving such a lenient deal to an international sex trafficker. 
22 
EFTA00191424

[The victims] want to be able to challenge the plea agreement. I was one of the 
lawyers who organized the plea agreement. I got the very good deal for Jeffrey 
Epstein. . . . And if they [i.e., victims' counsel] could find a lawyer who helped 
draft the agreement who also was a criminal, having sex — wow — that could help 
them blow up the agreement. So they sat down together, the three of them - these 
two sleazy, unprofessional, disbarrable lawyers, Paul Cassell, a former federal 
judge [and] current professor, and another sleazy lawyer from Florida, Brad 
Edwards — . .. and said who would fit into this description: A lawyer, who knows 
Epstein, who helped draft ...? Ha, Dershowitz! So they and the woman got 
together and contrived and made this up." 
Similarly, on the Meredith Vieira Show, Dershowitz alleged that allegations against him "fit the 
profile" of what it could take to vacate the plea:5 Of course, Jane Doe No. 3 (and her attorneys) 
are prepared to show they did not "contrive' the allegations. Dershowitz's name was not drawn 
from a hat. Rather, he was added to the pleading because Jane Doe No. 3 identified him as one 
of her abusers. And once she proves the truth of her sworn allegations, then — as Dershowitz 
himself colorfully puts it — the victims have additional relevant evidence that will help them to 
"blow up" the plea. 
4. 
The NPA 's "Blank Check - Co-Conspirator Immunity Provision and the Scope of 
the Remedy that the Victims Might Obtain. 
Jane Doe No. 3 explained in her motion to intervene that Dershowitz helped negotiate a 
NPA that contained a sweeping provision that provided immunity in the Southern District of 
Florida not only to Epstein, but also to "any potential co-conspirators of Epstein." DE 280 at 4 
(quoting NPA at 5).16 This provision is very unusual — a proverbial "blank check" blocking 
federal criminal prosecution of people who are not specifically identified — raising an inference 
14 http://www.enn.com/2015/01/06/us/dershowitz-sex-allegation/ (Jan. 6, 2015) (emphasis added). 
17 http://meredithvieirashow.corn/videos/alan-dershowitz-defends-himself/ (Jan. 8, 2015). 
16 In his "supplemental" response, Dershowitz asserts that other defense attorneys negotiated that 
provision. DE 285 at 4. Jane Doe No. 3 disputes this claim and requests discovery on it, as it seems far-
fetched to believe that Dershowitz did not see that NPA that his client ultimately signed. 
23 
EFTA00191425

that the defense team may have had ulterior or unidentified motives for pressing for the 
provision. 
More broadly, knowledge of the persons who are covered by this provision is directly 
relevant to the scope of the remedy that the victims may be able to obtain from the Court if they 
prevail on the merits of their claim. The Court has already received briefing from the victims 
and the Government on the remedy issue — and has prospectively allowed Epstein to intervene on 
any issue involving rescission of the NPA. DE 246. The victims all intend to seek rescission of 
the co-conspirator provision as part of any relief in this case. The fact that several of Jane Doe 
No. 3's sexual abusers — i.e., Dershowitz, Maxwell, Brunel, and Prince Andrew — are currently 
covered by the provision will thus be relevant to the scope of the remedy that the victims can 
obtain and the persons that they can seek to have prosecuted. 
5. Interface Issues. 
The Court has previously ruled that the victims' CVRA claim "implicates a fact-sensitive 
equitable defense which must be considered in the factual context of the entire interface between 
Epstein, the relevant prosecutorial authorities and the federal offense victims ...." DE 189 at 12 
n.6. Part of that "entire interface" is Epstein's defense team — which included Dershowitz. And 
Jane Doe No. 3 is one of the victims — indeed, an international sex trafficking victim. Her 
important factual allegations about extremely serious international trafficking crimes being swept 
under the rug in a dubious and secret non-prosecution agreement provide a critical piece of the 
"factual context" that the Court must consider. 
6. The "Crime/Fraud" Exception to the Attorney-Client Privilege and Other Privileges. 
Jane Doe No. 1 and Jane Doe No. 2 have specifically raised the argument that a 
crime/fraud/misconduct exception applies to the Government's assertion of attorney-client 
24 
EFTA00191426

privilege over various documents. DE 265 at 5-6. Based on Jane Doe No. 3's allegations, 
communications between the Epstein defense team and the Government appear to furthered a 
crime — i.e., Dershowitz's conspiracy with Epstein to engage in, and conceal, sex trafficking. 
And Government prosecutors' internal discussions may have unwittingly furthered that crime. 
See In re Grand July Investigation, 445 F.3d 266, 275-76 (3rd Cir. 2006) (attorney's lack of 
knowledge of the crime being furthered not relevant to crime-fraud exception). 
7. Right to be "Treated with Fairness" Issues. 
In his "supplemental" pleading, Dershowitz seems to assume that the victims are raising 
only a claim about their right to "confer" with prosecutors. DE 285 at 1-2. But Jane Doe No. 1 
and Jane Doe No. 2 also have a much broader, over-arching claim of a violation of their right "to 
be treated with fairness" under 18 U.S.C. § 3771(a)(8). See DE 48 at 36. Jane Doe No. 3 was 
known to the United States Attorney's Office at the time of the Epstein investigation, as 
evidenced by her inclusion in the NPA's attachment identifying known victims. The fact that 
Jane Doe No. 3 — a victim of international sex trafficking — was kept in the dark about the plea 
deal will provide further evidence of a violation of the right to be treated with fairness. The 
scope of her abuse — and the fact that the prosecution of crimes against her in the Southern 
District of Florida is now blocked by an agreement negotiated by one of her abusers — also all go 
to violations of the fairness right. 
8. Jane Doe No. 3 Will Be a Witness for Jane Doe No. I and Jane Doe No. 2 at Trial. 
Finally, the record in this case should reflect that Jane Doe No. 1 and Jane Doe No. 2 
intend to call Jane Doe No. 3 as a witness in any hearing or trial that the Court may schedule in 
this matter. The Government's violation of her rights is clearly evidence of a common scheme 
25 
EFTA00191427

or plan to keep crime victims in the dark, made admissible in any hearing by virtue of Fed. R. 
Evid. 404(b). 
For each of these eight reasons, Jane Doe No. 3's allegations against Dershowitz are 
plainly relevant to this case and therefore his attempt to intervene to strike them is futile." 
D. 
DESHOWITZ SHOULD NOT BE ALLOWED TO INTEVENE TO 
STRIKE JANE DOE NO. 3'S ALLEGATIONS BECAUSE SHE HAS 
SWORN TO THEIR TRUTH AND THEY ARE ALL 
SUPPORTED 
BY 
STRONG CORROBORATING EVIDENCE. 
Dershowitz finally claims that he should be allowed to intervene because Jane Doe No. 
3's allegations against him are false. In support of this position, he attaches a carefully-crafted, 
self-serving declaration. But a litigant's mere claim that contrary allegations are false provides 
no legal basis for striking them. See Moore's Federal Practice § 12.37[3A] (3d ed. 2014) ("Rule 
12 does not provide any authority to strike pleadings on the basis of falsity' because doing so 
would "effectively [be] a resolution on the merits, which is not appropriate at the pleading 
stage."). At early stages of litigation, "[t]he court accepts all well-pleaded allegations as true" 
and views factual allegations "in the light most favorable to the non-moving party." Johnson!. 
Nob:, Associates South Beach, LP, No. 9:10-cv-21691-KAM, 2011 WL 780028 at *2 (S.D. Fla. 
2011). In any event, to rebut Dershowitz's false claims directly, Jane Doe No. 3 now provides 
her own sworn affidavit, attached as Exhibit 1," repeating under oath the allegations that her 
17 A ninth reason now also exists that the allegations are relevant, given that the Government recently-
raised the argument that the Jane Doe No. 3 has failed to meet a six-year statute of limitations specified in 
18 U.S.C. § 2401. DE 290. Jane Doe No. 3 will contest whether that statute of limitations even applies. 
But Jane Doe also intends to raise an equitable estoppel argument — that the statute was tolled while she 
was in hiding in Australia due to the danger posed by Epstein and his powerful friends. Her factual 
allegations — including the specific identities of those powerful persons - are clearly relevant to 
demonstrating the factual underpinnings for her estoppel argument. 
" In paragraph 52 of Exhibit 1, the name of a sexual participant and eye-witness was redacted out of an 
abundance of caution, because while she was not a minor at the relevant time she is believed to have 
26 
EFTA00191428

attorneys proffered in her earlier motion — i.e., that Epstein sexually trafficked Jane Doe No. 3 to 
numerous persons, including Dershowitz. If the Court believes it would be useful, Jane Doe No. 
3 requests an evidentiary hearing to prove she is telling the truth 19 and directs the Court's 
attention the following substantial information supporting her sworn statement 20 To be clear, 
what follows is just part of the compelling information supporting Jane Doe No. 3's allegations. 
Any assessment of Jane Doe No. 3's sworn statement (and Dershowitz's protestations of 
innocence) must begin with two incontestable facts: First, Dershowitz is an extremely close 
personal friend of Epstein's. In fact, in 2005 (before the scandal of the criminal prosecution 
broke) Dershowitz stated "I'm on my 20th book. . . . The only person outside of my immediate 
family that I send drafts to is Jeffrey." The Talented Mr. Epstein, by Vicky Ward, in Vanity Fair 
(Jan. 2005)21 Dershowitz has also been quoted as saying that, even if Epstein went bankrupt, "I 
would be as interested in him as a friend if we had hamburgers on the boardwalk in Coney Island 
and talked about his ideas." Vanity Fair Reminds Us When Jeffrey Epstein Wasn't a Creep, by 
Ray Gustini, in The Wire (June 21, 201 I). 
Second, Jeffrey Epstein brazenly abused numerous girls in his Florida mansion, his New 
York mansion, and several other places that Dershowitz apparently admits he visited. See DE 
282-1 at 1-3 (Dershowitz affidavit discussing visits to Epstein). Proof of the notorious abuse 
originally been a victim of Epstein's sexual abuse while a minor. She is now a well-known actress whose 
identity we have unilaterally protected in this context. 
19 Jane Doe No. 3 asks that the evidentiary hearing be held after discovery phase in this case is completed, 
because she believes that the Government possesses significant information that, if disclosed, would fully 
support her allegations. S 
• the Government acknowledge this fact in any response it files. 
20 Cf.The Last Word with 
O'Donnell — MSNBC (Jan. 8, 2015), http://www.msnbc.com/the-
last-word/watch/alan-dcrshowitz-on-allegations--totally-false-381942851573 (Dershowitz: "Right now, 
they have accused me of these ... things without a single affidavit, without a single piece of evidence."). 
21 Morc recently, Dershowitz has disclaimed knowing Epstein well, stating that during the relevant time 
he was a mere "social acquaintance" and that "I was at [Epstein's] home for parties with a large number 
of most) 
scientists 
most) 
men 
dinner 
arties, intellectual gatherings." 
UMAR News, 
(Jan. 4, 2015). 
27 
EFTA00191429

starts with the NPA, under which Epstein agreed to register as a sex offender and provide 
compensation to approximately forty girls who he had sexually abused. Additional girls who he 
abused (such as movant Jane Doe No. 4) were not included in the NPA. Combined with the 
sworn testimony in the underlying civil cases, the NPA demonstrates persuasively that Epstein 
committed hundreds and hundreds of acts of sexual abuse against young girls — ostensibly 
"massage therapists" — during the relevant time period. 
See Exhibit 16 at 2 (collecting 
testimony). A small sample of the girls that Epstein sexually abused includes Jane Does Nos. 1, 
2, 3, and 4, as well as S.G., A.D., ■., N.R., J.S., 
J.A., J.E., M.L., M.D., D.D, and D.N. — 
all girls between the ages of 13 and 17. Id. at 7-8. 
Given the astonishing number of victims, and the detailed descriptions from many of 
them, Epstein's abuse of young girls clearly occurred on a "daily" basis. See Ex. I at ¶ 17. 
Indeed, according to his scheduled appointments, evidenced by the message pads retrieved by 
the Palm Beach Police Department, on some days Epstein engaged in sex with multiple girls.'-' 
In 2009, one of Epstein's household employees, Juan Alessi, was deposed about 11w 
parade of young "massage therapists" entering Epstein's Palm Beach mansion. He started 
working for Epstein in about January 1999. He testified that Jane Doe No. 323 was one of the 
girls who came to Epstein's mansion regularly when she was in the age range of 15 to 19. Juan 
Alessi Depo. at 46:21- 47:4, 48:18-25, Jane Doe No. 11 Epstein, No. 9:08-ev-80119-cv-KAM 
(S.D. Fla. Sept. 8, 2009) (excerpts attached as Exhibit 18). 
Alessi also saw many celebrities came to the Florida mansion, including not only Prince 
Andrew and his wife Sarah but also "a very famous lawyer that I'm sure you know, Alan 
22 Upon request, victims counsel could provide the Court with these materials for review. The materials 
contain the names of minor victims of sexual assault, so scaled transmission would be necessary. 
2% In the deposition, Janc Doe No. 3 is identified by initials. 
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Dershowitz." Id. at 70:9.25. Alessi testified that Dershowitz came to the mansion "pretty often . 
. . at least four or five times a year" and would stay "two [or) three days." Id. at 73:22-25. Jane 
Doe No. 3 came to the house when Dershowitz was there. Id. at 73:18-20. And — importantly — 
Dershowitz got massages while he was visiting Epstein's home. Alessi answered "yes" when 
asked whether Dershowitz "had massages sometimes when he was there," and explained that 
"[a] massage was like a treat for everybody." Id. at 74:1-4. The private, upstairs room where 
Dershowitz got his "massages" was one that contained a lot of vibrators — Maxwell had "a 
laundry basket . .. full of those toys" in that room. Id. at 76:11-15. 
In 2009, one of Epstein's most trusted employees was also deposed: Alfredo Rodriguez, 
the butler at Epstein's Palm Beach mansion. Rodriguez testified under oath that Dershowitz was 
at Epstein's mansion when underage girls were there to give massages. Alfredo Rodriguez 
Depo. at 278:13-25, 279:9-280:2, Jane Doe No. 21 Epstein (excerpts attached as Exhibit 19).24
Rodriguez also testified that Dershowitz stayed at the house in his role as Epstein's friend, as 
opposed to being his lawyer (id. at 279:5-8; 385:I-6) and that Dershowitz was present alone at 
the home of Jeffery Epstein, without his family, in the presence of young girls. Id. at 199:12-13, 
279:9-12, 426:16-25, 427:1. In fact, Rodriguez described that when the underage girls would 
come over, Dershowitz would drink wine and read books on the couch. Id. at 426:16-25; 427:1. 
As is familiar to this Court, after Rodriguez's deposition, he attempted to sell a 97-page 
document that he appropriated from Epstein's computer. The document contained Epstein's 
telephone directory — as well as a list of apparent young girls in various locations, including 
24 According to press reports, Rodriguez recently passed away. See "Houseman who cleaned pedophile 
Jeffrey Epstein's sex toys and feared he would make him 'disappear' takes billionaire's secrets to the 
grave after he died just law week," http://www.dailymail.co.uk(news/article-2897939/Houseman-cleaned-
pedophile-Jeffrey-Epstein-s-sex-toys-feared-billionaire-tnake-disappear-takes-secrets-grave.html (Jan. 6, 
2015). 
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Florida, New York, New Mexico, and the U.S. Virgin Islands. An FBI undercover employee 
(UCE) set tip a meeting with Rodriguez to exchange $50,000 in "buy money" for the document. 
Following the exchange, the FBI arrested Rodriguez for obstruction of justice related to the 
attempted sale of this document (which Rodriguez called "the Holy Grail"). According to an FBI 
agent's ensuing report, Rodriguez "discussed in detail the information contained within the book, 
and identified important information to the UCE." See United States'. Rodriguez, No. 9:10-cr-
80015-KAM, DE 3 at 5 (S.D. Fla. Dec. 9, 2009). While all of the details of the verbal 
information explained by Rodriguez to that agent have not been disclosed,25 the documents have 
been. While there are hundreds of names, addresses, and phone numbers in the document, 
Rodriguez apparently circled only a select few entries. For instance, lie circled each of the 
sections listing the girls that provided "massages" for Epstein in various locations. This includes 
the various confirmed under-age Florida victims. Additionally, a few other individuals in the 
book were circled. The logical presumption is that Rodriguez circled specific individuals, 
identifying them as persons who were involved in the illicit activities. One of the few people 
Rodriguez circled was Alan Dershowitz. See Exhibit 20. 
Moving up from household help to the next echelon in Epstein's criminal conspiracy, 
three individuals the NPA lists by name as Jeffrey Epstein's co-conspirators are Sarah Kellen, 
Nadia Marcinkova, and Adrianna Mucinska. Extensive investigation demonstrated that Nadia 
Marcinkova participated in several of the sex acts with underage girls (including Jane Doe I) and 
that Sarah Kellen and Adrianna Mucinska were heavily involved in procuring underage girls for 
Epstein to sexually abuse. See, e.g., Exhibit 16 at 12, 20. Of particular relevance here, all three 
25 It has been disclosed that Rodriguez said that "he had witnessed nude girls whom he believed were 
underage at the pool area of [Epstein's] home, knew that [Epstein) was engaging in sexual contact with 
underage girls, and had viewed pornographic images of underage girls on computers in [Epstein's) 
home." DE 3 at 7. 
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implicated Dershowitz by invoking their Fifth Amendment right against self-incrimination26
when asked questions about Dershowitz's connection to Epstein's abuse — including a specific 
question about whether Dershowitz had been involved with massages by young girls. Sarah 
Kellen took the Fifth when asked: 
Have you seen a gentleman by the name of Alan Dershowitz at the home of 
Jeffrey Epstein before? 
Do you know Alan Dershowitz? 
Are you aware of friendship between [Alan] Dershowitz and Jeffrey Epstein? 
When [Alan] Dershowitz comes to Palm Beach, he stays at the El Brillo mansion, 
doesn't he? 
[H]as [Alan] Dershowitz ever been there when young ladies came to give 
massages? 
Has [Alan] Dershowitz ever been the beneficiary of those massages [given by 
young ladies at Epstein's mansionfri
Sarah Kellen Depo. at 211:16-18, 317:5, 436-37:25-1, 437:9-10; 437:18-19, 437-38: 25-1, Jane 
Doe No. 21 Epstein, No. 8:09-cv-801 19-KAM (Mar. 24, 2010) (emphasis added) (excerpts 
attached as Exhibit 21). Nadia Marcinkova pled the Fifth when asked: 
Do you know what Jeffrey Epstein's relationship is with Alan Dershowitz? 
That's somebody [i.e., Dershowitz] who you know to have stayed at Jeffery 
Epstein's house on many occasions, correct? 
And also somebody who you know to have been at the house when E.W. was in 
Jeffrey Epstein's bedroom getting sexually abused, correct? 
26 Of course, in a proceeding such as this one, the victims are entitled to an inference in their favor when a 
witness takes the Fifth Amendment rather than answer a relevant question where that witness is 
associated with the other side of the case or otherwise in an adverse position to the victims. See, e.g., 
LiBuiti I. United States, 107 F.3d 110, 124 (2d Cir. 1997). 
27 Interestingly, defending the deposition of Sarah Kellen was Bruce Reinhart, a former prosecutor in the 
U.S. Attorney's Office when the Epstein NPA was negotiated. Reinhart had confidential, non-public 
information about the prosecution's case against Epstein. See note 7, supra. 
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Alan Dershowitz is also somebody that you also know to have been at the house 
when L.M. was being sexually abused in Jeffrey Epstein's bedroom, correct? 
Generally, Alan Dershowitz is familiar with Jeffrey Epstein's habit of engaging in 
sexual acts with minors on a daily basis, correct? 
When Alan Dershowitz was in town, Jeffrey Epstein did not break his schedule 
for Alan Dershowitz, meaning he continued to sexually abuse minors despite Alan 
Dershowitz being a guest in the house? 
Nadia Marcinkova Depo. at 56:22-25; 57:1-25, 58: 1-10, Jane Doe'. Epstein, No. 9:08-cv-
80893-1CAM (April 13, 2010) (excerpts attached as Exhibit 22). And Adrianna Mucinska took 
the Fifth when asked: 
Have you ever met Alan Dershowitz? 
When Alan Dershowitz stays at Jeffrey Epstein's house, isn't it true that he has 
been at the house when underage minor females have been in the bedroom with 
Jeffrey Epstein? 
Have you ever flown on the airplane [privately owned by Jeffrey Epstein] with 
Alan Dershowitz before? 
Adrianna Mucinska Depo. at 37:6, 37:8, 81:25, Jane Doe. Epstein, No. 9:08-cv-80893-KAM 
(Mar. 15, 2010) (excerpts attached as Exhibit 23).28
Finally, moving to the top of the conspiracy, Epstein himself has been questioned 
repeatedly, taking the Fifth when asked about Dershowitz's awareness of underage girls. For 
example, when Epstein took the Fifth when asked during his deposition "[h]ave you ever 
socialized with Alan Dershowitz in the presence of females under the age of 18?" Jeffrey 
Epstein Depo. at 90, Epstein'. Edwards, No. 502009CA040800XXXXMB (Palm. Beach Cty. 
Cir. Ct. Mar. 17, 2010) (excerpts attached as Exhibit 24). Indeed, going a step further, on 
October 8, 2009, Epstein took the Fifth when asked whether he even knew Dershowitz was a 
38 Mucinska also took the Fifth when asked about the involvement of Prince Andrew, Ghislaine Maxwell, 
and Jean Luc Brunel. id. at 37:3, 85:12, 85:13. 
32 
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professor at Harvard. 
Epstein, No. 502008CA0373 I XXXXMB, Epstein Depo. Tr. at 122 
(Palm Beach Cty. Cir. Ct. Oct. 8, 2009). 
In short, all the key conspirators in Epstein's sexual trafficking ring who could be asked 
about Derhowitz's involvement took the Fifth.29 This Isjilence is . . . evidence of the most 
persuasive character." United States ex rd. Biloktanskyl. Tod. 263 U.S. 149, 153-54 (1923) 
(Brandeis, J.), quoted in Baxter". Pahnigiano, 425 U.S 308, 319 (1976). And that silence takes 
on an even more sinister cast when combined with the fact that Epstein's sexual interest in young 
girls would have been obvious to someone like Dershowitz, Epstein's close personal friend who 
was present at the very locations when abuse was taking place. See Ex. I at ¶ 17. 
Additional credibility to Jane Doe No. 3's sworn statement is provided by clear evidence 
of a common scheme or plan, admissible under Fed. R. Evid. 404(b). As is clear from the 
evidence recounted above, Jane Doe No. 3's allegations against Jeffrey Epstein are 
overwhelmingly corroborated by numerous other girls and Epstein's private flight logs 
demonstrating Jane Doe No. 3's travel with him while under 18 years old. In addition, her 
allegations against Prince Andrew are strongly corroborated. For example, while Buckingham 
Palace has recently denied that Prince Andrew had sexual contact with Jane Doc No. 3, it has not 
attempted to explain what led to the Prince having his picture taken with his arm around a 17-
year-old American girl at night in London in an intimate setting in a private residence. Nor has 
the Palace explained what Ghislaine Maxwell is doing there and who took that picture — while 
Jane Doe No. 3 has provided a sworn affidavit that the photographer was Prince Andrew's close 
friend (as well as sex trafficker and now-registered sex offender): Jeffrey Epstein. Jane Doe No. 
29 As noted earlier, two other key conspirators — Ghislaine Maxwell and Jean Luc Brunel — evaded 
depositions to avoid answering any questions under oath. 
33 
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