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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 Government 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 Caine 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 Government and defense counsel decided that the NM 
should be "kept from public view because of the intense public criticism that would have 
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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." 
Issues pertaining to motive can always be pursued. particularly when a case is in an early 
discovery phase. See. e.g.. Gelahert I. Slate. 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 
States'. 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 information 
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 I. 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 NM 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. 
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[The victims] want to be able to challenge the plea agreement. I was one of the 
lawyers who organized the plea ageement. 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, Dershowitzl So they and the woman got 
together and contrived and made this up.I4
Similarly, on the Meredith Vieira Show, Dershowitz alleged that allegations against him "fit the 
profile" of what it could take to vacate the plea. m3 Of course, Jane Doe No. 3 (and her attorneys) 
are prepared to show they did not "contrive" the allegations. Dershowitis 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.cnn.c 
/1 
usidershowitz-sex-allegation/ (Jan. 6, 2015) (emphasis added). 
IS http://meredithvie 
adeos/abn-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. 
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that the defense team may have had ulterior or unidentified motives for pressing for the 
provision. 
More broadly, knowledge of the persons who arc 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 pan 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-Cllent Privilege and Other Privileges. 
Jane Doe No. I and Jane Doc No. 2 have specifically raised the argument that a 
crime/fraud/misconduct exception applies to the Government's assertion of attorney-client 
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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 Jury 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 seem 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. I 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 
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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.I7
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'. 
Nobu 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 1,18 repeating tinder oath the allegations that her 
" 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
to raise an equitable estoppel argument — that the statute was tolled while she 
was in hiding in 
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. 
18 In paragraph 52 of Exhibit I, 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 
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attorneys proffered in her earlier motion — i.e., that Epstein sexually trafficked Jane Doc No. 3 to 
numerous persons, including Dcrshowitz. 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)" 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).11 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 Warn 't a Creep. by 
Ray Gustini, in The Wire (June 21, 2011). 
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-I 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. 
2° CI The Last Word with 
O'Donnell — MSNBC (Jan. 8, 2015), http://www.msnbc.com/the-
last-word/watchialan-dershowitz-o n-a I legal ions—tota Ily-fa Ise-38194285 I 573 (Dershow kz: "Right now. 
they have accused me of these . . . things without a single affidavit, without a single piece of evidence."). 
More 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 panics with a large number 
of most) 
scientists, most! 
men, dinner parties, intellectual gatherings." 
UMAR News, 
=KXzcxsipv7Q (Jan. 4, 2015). 
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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. I, 
2, 
and 4. as well a 
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 1 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.22
In 2009, one of Epstein's household employees, Juan Alessi, was deposed about the 
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. 3 33 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. 21 Epstein, No. 9:08-cv-801 19-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 sealed transmission would be necessary. 
22 In the deposition, Jane Doe No. 3 is identified by initials. 
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Dershowitz" Id. at 709-25. 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 7322-25. 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 74:14. 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; 385:1-6) and that Dershowitz was present alone at 
the home ofJeffery 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.dailyma il.co.ukinews/anick-2897939/Housetnan-cleaned. 
pedoph i le-Jeffrey- Epstein-s-sex-toys-feared-billiona ire-make-d isa ppear-takes-secrets-gra ve.htm I (Jan. 6. 
2015). 
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Florida. New York, New Mexico, and the U.S. Virgin Islands. An FBI undercover employee 
(UCE) set up 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. 9:1 0-cr-
800I5-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
 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, he 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 IMM, 
and 
. Extensive investigation demonstrated that 
participated in several of the sex acts with underage girls (including Jane Doe I) and 
that 
and 
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 Itpstein'sl 
home." DE 3 at 7. 
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implicated Dershowitz by invoking their Fifth Amendment right against self-incrimination 26
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. 
=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 mansion???
=IM 
Depo. at 211:16-18, 317:5, 436-37:25-1, 437:9-10; 437:18-19, 437-38: 25-1, Jane 
Doe No. 2' Epstein, No. 8:09-cv-801 I 9-KAM (Mar. 24, 2010) (emphasis added) (excerpts 
attached as Exhibit 21). 
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 
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.. 
Wiwi I United Stairs, 107 F.3d 110, 124 (2d Cir. 1997). 
27 Interestingly, defending the deposition of 
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 De howitz is also somebody that you also know to have been at the house 
when 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 
Dershowirz being a guest in the house? 
Depo. at 56:22-25; 57:1-25, 58: 1-10, Jane Doe 
Epstein. No. 9:08-cv-
80893-KAM (April 13, 2010) (excerpts attached as Exhibit 22). And 
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? 
took 
Have you ever flown on the airplane [privately owned by Jeffrey Epstein] with 
Alan Dershowitz before? 
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 Isr• 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 
28 Mucinska also took the Fifth when asked about the involvement of Prince Andrew, Ghislaine Maxwell. 
and Jcan Luc Brunel. Id. at 37:3, 85:12, 85:13. 
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professor at Harvard. 
Epstein, No. 502008CA03731XXXXMB, 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." This "[sJilence is . . . evidence of the most 
persuasive character." United States ex rd. Bilokumsky 'Tod, 263 U.S. 149, 153-54 (1923) 
(Brandeis, J.). quoted in Baxter 1 Palmigiano, 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. 1 at 1 17. 
Additional credibility to Jane Doe No. 3's sworn statement is provided by clear evidence 
of a common scheme or plan, admissible wider 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 Doe 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. 
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3 has also made strong, credible claims against Jean Luc Brunel — corroborated allegations that 
parallel those made by others. See Exhibit 16 at 22. 
In contrast to this interlocking web of corroborating evidence, the Court should examine 
what Dershowitz says in his affidavit — and, more important, fails to say. The Court will notice 
that Dcrshowitz devotes only a single sentence in his affidavit to his activities at Epstein's Palm 
Beach and New York mansions. See DE 282-I at 3 ("As to Mr. Epstein's homes in New York 
City and Palm Beach, I categorically state that I never had any sexual contact with Jane Doe 
#3."). The Court nay immediately wonder about the following questions: How long did 
Dershowitz spend at these homes? Was he with his wife and family, as he has suggested in 
television interviews? Flow many times was he there overnight? Did Dershowitz ever see any of 
the dozens and dozens of young girls whom Epstein was sexually abusing? Did Dershowitz ever 
get a "massage" from one of these young girls? 
The Court may also wish to contrast Dershowitz's very narrow affidavit with his more 
sweeping statements to the media. On popular television programs, Dershowitz has emphatically 
denounced Jane Doe No. 3 as a liar and said he can prove "conclusively" that he has never even 
met her.10 Yet in his sworn affidavit, Dcrshowitz does not repeat that broad claim.3I Nor does 
Dershowitz ever address his knowledge of other young girls, in addition to Jane Doe No. 3, 
abused by Epstein in those houses. 
14 See. e.g.. http://www.cnn.com/2015/0 I /05/eu rope/prince-and rew-sex-abuse-alkgat ions/ index.htm I ("Q: 
"Have you ever met this woman named pane Doe No. 3]?" A: "No. Absolutely not, I don't know who 
she is."); CNN News Day 
http://www.cn 
ideos/tv/2015/01/05/bts-newday-alan-ders how itz-pr ince-a nd rew-sex-sean dal-
alkgat ions.cnn (Jan. 5, 2015) ("I never met this woman. I never touched her. I was never massaged by 
her. There was no contact, no contact whatsoever — and I will prove it conclusively."). 
31 In the media, Dershowitz has also offered to execute a waiver of the statute of limitations to enable 
Jane Doe No. 3 to file charges against him. Shortly after Dershowitz first made that offer, Jack Scarola. 
Esq., provided Dershowitz with a waiver form for him to sign. Dershowitz declined to sign the fonn and 
later advised. through his counsel, that he was "considering" whether to waive the statute of limitations. 
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In his affidavit, Dershowitz also cagily states that he sent a letter to an attorney who was 
seeking a deposition. recounting that in that letter he (Dershowitz) said he was "not a witness to 
any alleged crimes." DE 282-I at 3. But Dershowitz does not repeat under oath the broad claim 
that he never witnessed any alleged crimes — presumably because he is aware of certain child 
abuse reporting obligations that might be at issue if he did so. 
Against this mounting evidence of guilt, Dershowitz suggests in his affidavit that aircraft 
flight manifests will exonerate him. DE 282-1 ("I was on that plane on several occasion as the 
manifests will show, but never under circumstances where it would have been possible to have 
sex with Jane Doe #3."). In media statements. Dershowitz has repeatedly brought up the 
manifests as proof of innocence.32 Coincidentally and remarkably, it was Dershowitz himself. 
acting as Epstein's attorney, who personally collected and then provided flight manifests to the 
Palm Beach Police Department. See. e.g., Police Detective Joe Recarey Depo. at 281, Jane Doe 
No. 2. Epstein, No. 9:08-cv-80119-KAM (Mar. 19, 2010). (excerpts attached as Exhibit 29) 
Dershowitz provided manifests covering just the 10 months: January I. 2005, through October 
17, 2005, During civil litigation, believing that these flight manifests were grossly incomplete. 
counsel subpoenaed Epstein for complete flight logs. Epstein failed to provide any information 
at all. Counsel were then forced to request flight logs from Epstein's various private pilots. 
One of Epstci n's pilots. David Rogers, provided certain flight logs covering some flights 
from a much broader time frame: 1997-2005. 
This production confirmed that the flight 
12 See, e.g., The Today Show, Jan. 5, 2015 ("She claims I had sex with her in the airplanes, manifests of 
the flights will show I was never on the airplanes with her."); Hula Gorani —CNN Live, Jan. 5, 2015 ("As 
far as the planes are concerned, there are flight manifests. They will prove I was never on any private 
airplane with any young women."). 
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information Dershowitz provided to police was incomplete. 
A comparison of the flight 
manifests and logs confirms that the flight logs provided by Rogers were also incomplete. A 
cursory review of both logs reveals that together the logs produced cover only a small fraction of 
the flights taken and the passengers on board. While this is obvious for multiple reasons, a few 
examples may help to make this point. For instance, the flight records provided by Dershowitz 
for a February 3, 2005, flight from CMH (Columbus, Ohio) to PBI (Palm Beach, Florida), 
indicate that in addition to Jeffrey Epstein, 
and Jean Luc 
Brunel, on board were three "females." The existence of these three "females" is conspicuously 
absent from the Rogers' logs. Compare Composite Exhibit 25 with Composite Exhibit 26 
(Rodgers Logs). Other flights, such as the March 18, 2005 flight from New York to Florida, 
taken by Maxwell, Epstein and 
are missing altogether from the Rogers logs. 
Likewise, flights that appear on the Rogers logs are missing from the logs produced by 
Dershowitz. 
Multiple examples lead to the clear conclusion that all produced logs are 
incomplete and may well have been heavily sanitized. For example, on February 9, 1998, 
Dershowitz flew on Epstein's private plane from Palm Beach, Florida, to Teterboro, New Jersey. 
One of the passengers is listed as "1 female." Exhibit 27. Who is that "female" — and what is 
her age? Similarly, Jane Doe No. 3 appears on a July 16. 2001, flight from Santa Fe, New 
Mexico to Teterboro, New Jersey. along with Epstein, Maxwell and 
Yet there is 
no earlier flight that would have landed Jane Doe No. 3 in New Mexico. According to the logs, 
the next flight is from Palm Beach to the U.S. Virgin Islands on July 23, 2001, although Jane 
Doe No. 3 does not appear. The impression is that she remained in the New Jersey area. 
However, on July 28, 2001, Jane Doe No. 3 is on a flight with Epstein from the Virgin Islands 
back to Palm Beach. See Exhibit 26. How did she get to the Virgin Islands? 
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The flight logs provide evidence of some of the individuals who were on some of the 
flights - nothing more. Accordingly. it would not be surprising to find that some of these flight 
logs do not mention Dershowitz, because they were likely designed to hide evidence of criminal 
activity — or perhaps later cleansed of such evidence. With that said. some interesting things do 
appear in the flight logs. Unlike any other of Epstein's numerous criminal defense attorneys. 
Dershowitz appears in the flight logs for flights on Epstein's private planes produced by pilot 
Rogers on numerous occasions. Dershowitz also appears on flights with various females, 
including Epstein's known procurer of underage girls,. 
And, in contrast to recent 
media suggestions by Dershowitz, his family does not appear on any of the flights with him. 
Jane Doe No. 3 is listed on the logs as a passenger at a time when she is under age 18. 
While the logs do not show Dershowitz on the same flight with her. it is abundantly clear that the 
logs do not contain evidence of all of the flights that she was on and that they are grossly 
incomplete. The flight logs do confirm that she was transported by Epstein to Florida, New York. 
London, New Mexico, and the U.S. Virgin Islands — locations where she states under oath that 
Epstein forced her to have sex with various individuals, including Dershowitz. 
Finally. in Dershowitz's vociferous attacks on Jane Doe No. 3. the Court will see an eerie 
parallel to the Jeffrey Epstein criminal investigation. Back in 2005, when the Palm Beach Police 
Department was first investigating Epstein's sexual abuse, it interviewed more than a dozen 
minor girls. These girls all provided information about abuse similar to the abuse that Jane Doe 
No. 3 says she suffered in Florida. The Department accumulated overwhelming evidence 
placing underage girls at Epstein's residence with no obvious legal purpose. The logical 
explanation was that these young girls were being truthful when they told law enforcement that 
Epstein (and others) were sexually abusing them. 
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Rather than acknowledge sexual abuse of these girls, Dershowitz blustered down to 
Florida to meet with the State Attorney and to viciously attack the credibility of these victims — 
to call them liars, defame them as prostitutes, and convince the State Attorney that these girls 
could not even believably establish that they had ever even gone to Epstein's mansion. See, e.g., 
Depo. of Police Chief Michael Reiter at 53-55, 102-06, 8.4. Epstein, No. 502008CA037319 
XXXX-MB-AB (Palm Beach Cty. Cir. CL Nov. 23, 2009) (excerpts attached as Exhibit 28); see 
also Depo. of Police Detective Joe Recarey at 301-302 and 309-10, Jane Doe No. 21. Epstein, 
No. 9:08-cv-80119-KAM (S.D. Fla. Mar. 19, 2010) (excerpts attached as Exhibit 29) Later, 
Dershowitz would write to tell the Justice Department that " 
Letter from Gerald Lefcourt & Alan Dershowitz, July 6, 2007 to U.S. Atty.'s Office for the S.D. 
Fla (attached as Exhibit 30). Now, nearly a decade later, there should be no doubt in anyone's 
mind that the minor girls who cooperated with the authorities told the truth about their sexual 
abuse inside Epstein's home -- and that Dershowitz's attack on their credibility was duplicitous. 
In fact, according to credible eyewitness testimony recounted above, Dershowitz was clearly 
present in the home while some of these girls were being abused. The Court should not allow 
Dcrshowitz's similar bullying tactics to succeed in this case?' 
CONCLUSION 
Dershowitz's motion for intervention (DE 282) should be denied. 
33 In the media, Dershowitz has said that he will prove that ISNo. 
3 is lying "beyond any doubt by 
physical and documentary evidence." The Last Word with 
O'Donnell — MSNBC (Jan. 8, 2015) 
http://www.msnbc.com/the- last-worcl/watch/alan-deishow itz.-on-a Begat ions--totally-false-
381942851573. The Court should compare this media assertion with the materials that Dershowitz files 
along with his reply brief. 
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DATED: January 21, 2015 
Respectfully Submitted, 
Bradley J. Edwards 
FARMER, JAFFE, WEiSS1NO, 
EDWARDS, F1STOS & LEHRMAN, P.L. 
and 
Paul G. Cassell 
Pro Hac Vice 
S.J. Quinney College of Law at the 
University of Utah.
Attorneys for Jane Doe #1 and Jane Doe #2 
• This daytime business address is provided for identification and correspondence purposes only and is 
not intended to imply institutional endorsement by the University of Utah 
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CERTIFICATE OF SERVICE 
I certify that the foregoing document was served on January 21, 2015, on the following 
using the Court's CM/ECF system: 
500 S. Australian Ave., Suite 400 
sis
s
West Palm Reach, FL 33401 
Attorneys for the Government 
Thomas Scott 
thomas.secitt®csklegal.com 
ar
COLE. SCOTT & KISSANE, P.A. 
-and-
Kendall Coffe 
Gabriel Groisman 
Benjamin H. Brodsk 
COFFEY BURLINGTON. P.L. 
Attorneys for Alan Dershowitz 
/s/ Bradley J. Edwards 
40 
EFTA00188787