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This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

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New Jeffrey Epstein accuser emerges: defamation suit filed I Miami Herald 
NATION & WORLD 
New Jeffrey Epstein accuser goes public; defamation 
lawsuit targets Dershowitz 
BY 
IF: K. BROWN 
APRIL 16. 2019 04:23 PM. UPDATED APRIL 16. 2019 07:18 PM 
Palm Beach multimillionaire Jeffrey Epstein is a free man, despite sexually abusing dozens of underage girls according to 
police and prosecutors. His victims have never had a voice, until now. BY 
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New Jeffrey Epstein accuser emerges: defamation suit filed I Miami Herald 
A new victim has gone public in the Jeffrey Epstein case, filing a sworn affidavit in federal court in New 
York Tuesday, saying that she was sexually assaulted and her then-15-year-old sister molested by Epstein 
and his companion, Ghislaine Maxwell, in 1996. 
then 26, claims that she was employed by Epstein, a multimillionaire financier who lived 
in a vast mansion on New York's Upper East Side, and that she frequently saw "school-age girls" 
wearing uniforms come into the mansion and go upstairs. She was told that the girls were auditioning for 
modeling work, according to her affidavit. 
Then an art student in New York, 
said she reported her assault to New York police and the FBI in 
1996. FBI documents released April 1 make a reference to 
having been interviewed in 2006 or 
2007. However. 
now 49, said the FBI did not take any action against Epstein and Maxwell. 
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New Jeffrey Epstein accuser emerges: defamation suit filed i Miami Herald 
"To my knowledge, I was the first person to report Maxwell and Epstein to the FBI. It took a significant 
amount of bravery for me to make that call because I knew how incredibly powerful and influential both 
Epstein and Maxwell were, particularly in the art community," she wrote. 
affidavit is one of 15 exhibits attached to a defamation complaint filed in federal court in the 
Southern District of New York by 
, one of Epstein's victims, against Alan 
Dershowitz, one of Epstein's most vocal and powerful attorneys. 
claims in the lawsuit, as she has in past court filings, that Dershowitz, 80, knew about and 
participated in a sex-trafficking operation involving underage girls and run by Epstein and Maxwell, and 
that she was forced to have sex with Dershowitz and other prominent, wealthy men when she was 
underage. 
Dershowitz has railed against the allegations for years, maintaining that he has never met 
. He 
also says he has documents and other evidence that prove she is lying. 
Complaint by Anonymous OSO42TAiBF on Scribd 
Case 1 19-cv-03377 Dc 
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New Jeffrey Epstein accuser emerges: defamation suit filed Miami Herald 
Show me more about this topic 
1 
of 28 
affidavit and other documents attached to the lawsuit are meant to bolster 
case that 
Dershowitz has maliciously spread false information on behalf of Epstein in order to intimidate and 
silence her and other victims, according to the lawsuit. 
"No sensible person looks forward to litigation," 
said in a statement. "And I know that standing 
up for myself and others will cause Mr. Dershowitz and Mr. Epstein to redouble their efforts to destroy 
me and my reputation. But I can no longer sit by and not respond. As my complaint shows, my abusers 
have sought to conceal their guilt behind a curtain of lies. My complaint calls for the accounting to which 
I, and their other victims, are entitled." 
Ghislaine Maxwell was sued for slander after calling 
one of Jeffrey Epstein's accusers. a liar. 
Maxwell. a close associate of Epstein. sought to have documents from the court case remain sealed. 
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Dershowitz said he welcomed the opportunity to finally prove in court that 
is lying. 
"Virtually everything in the complaint is false, and I will be able to disprove all of this in a court of law. I 
have told the truth throughout and I'll be able to prove it. ... I never met her, I never heard of her," 
Dershowitz said. 
In recent months, Dershowitz has waged a public relations war against =, 
her lawyers and the 
Miami Herald, which published a series of articles about Epstein in November. The series, "Perversion of 
Justice," focused on how the former U.S. attorney in Miami, now Labor Secretary Alexander Acosta, 
brokered a non-prosecution deal giving Epstein federal immunity, despite overwhelming evidence that he 
had sexually assaulted dozens of girls. The series mentioned Dershowitz, who represented Epstein during 
the negotiations, including 
sex abuse allegations against the Harvard lawyer. 
Once a friend of presidents, the ultra-rich and the elite of Wall Street's bankers — plus a major benefactor to Harvard 
University — Jeffrey Epstein handled portfolios estimated to be worth over $15 billion. Then he became ensnared in a 
scandal involving the sexual abuse of underage girls. He is seen here. pre-scandal, at left, in conversation with Alan 
Dershowitz, one of America's best-known legal experts and a Harvard Law professor emeritus, at a Cambridge event. 
Dershowitz became a key member of Epstein's legal team. Rick Friedman cams 11A Gerry imAcEs 
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New Jeffrey Epstein accuser emerges: defamation suit filed Miami Herald 
lawsuit does not provide evidence of 
having sex with Dershowitz, or provide dates 
when the abuse allegedly happened. But it does provide a chapter-and-verse history of Dershowitz's 
public statements and attempts to take each statement he's made and discredit them. 
For example, Dershowitz has said that he has never seen any underage girls when he visited Epstein at 
the financier's various homes in Palm Beach, New Mexico and New York. But =, 
who now lives in 
Kentucky, claims that one of her duties working for Epstein was to staff the front door to his New York 
estate and to keep track of visitors. 
"On a number of occasions I witnessed Dershowitz at the NY mansion going upstairs at the same time 
there were young girls under the age of 18 who were present upstairs in the house," she said in the 
affidavit, asserting that Dershowitz was so comfortable he would walk into the mansion and go directly 
upstairs. 
Dershowitz said that would have been impossible because he did not meet Epstein until August 1996 on 
Martha's Vineyard. 
"I was never upstairs in Jeffrey Epstein's apartment, never ever," Dershowitz said. "This is typical of the 
complaints in this case by the [David] Boies firm, very sloppy. I would not have felt comfortable going 
upstairs because I didn't know [Epstein] very well then." 
did not say when she saw Dershowitz or if she saw him in the presence of any young girls. But 
the lawsuit points to at least one witness — former Palm Beach house manager Alfredo Rodriguez —
who has alleged he did see Dershowitz in the presence of young girls and women at Epstein's waterfront 
mansion. Rodriguez was prosecuted by the FBI for obstructing justice when he tried to sell Epstein's 
"little black book" listing the hedge fund manager's friends, business associates, celebrity guests and a 
long list of female masseuses. Rodriguez died in prison. 
Another woman, 
also submitted an affidavit with the lawsuit with new details about sex 
she claims she had with Dershowitz. 
says that she was introduced to Epstein when she was 22 years old and living in New York. She 
claims that she spent time at Epstein's mansion and was "lent out" by him to his friends for sex. Among 
those friends was Dershowitz, she said in the affidavit. She alleges she had a three-way sexual encounter 
with Dershowitz and 
, a young adult who also worked for Epstein. 
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"I recall specific, key details of his person and the sex acts and can describe them in the event it becomes 
necessary to do so," 
said in the affidavit. 
Dershowitz has publicly denounced both 
and 
accusations, saying he has been able 
to "disprove" them." It's not clear, however, whom he has provided proof to, except to Louis J. Freeh, a 
former FBI director who released a statement in 2016 saying that he had conducted an independent 
review of Dershowitz's information and concluded the Harvard law professor's evidence contradicted 
and there was no evidence to support her allegations. 
was never interviewed by the 
Freeh investigators, according to her lawyers. 
Dershowitz allowed the Herald to review some of the documents that he says he has, but he has not 
released them for the Herald to substantiate the information that he gathered, including his personal 
calendars, which he claims prove he could not have been in the same locations as 
when she was 
with Epstein, from 1999 to 2002. Following the online publication of this article, Dershowitz said he 
would provide those documents to the Herald, after redacting his clients' private information. 
The girls who were abused by Jeffrey Epstein and the cops who championed their cause remain angry over what they 
regard as a gross injustice, while Epstein's employees and those who engineered his non-prosecution agreement have 
prospered. 
By 
In recent months, Dershowitz has stepped up allegations that 
accusations against him are part of 
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New Jeffrey Epstein accuser emerges: defamation suit filed' Miami Herald 
an extortion plot to blackmail an Ohio billionaire. The billionaire is identified in the lawsuit as Les 
Wexner, the CEO of the Limited Brands, which includes Victoria's Secret, who was Epstein's top 
financial client. 
Dershowitz alleges that 
and David Boies, a prominent New York attorney known for representing 
Al Gore in the Supreme Court case that decided the presidency in 2000, falsely accused him in order to 
get Wexner to pay hush money so that Wexner would not be similarly tarred by 
But 
has never publicly named Wexner as among those she was forced to have sex with. And in 
the lawsuit, she said that neither she nor her lawyers have ever demanded or received money from 
Wexner, 81. The lawsuit points out that 
allegations against Dershowitz predated the time she 
was represented by Boies and his firm. 
Boies partners Joshua Schiller and Sigrid McCawley filed the lawsuit on behalf of =, 
who lives in 
Australia. 
Efforts to reach Epstein, Wexner and Maxwell for comment were not immediately successful. 
Wexner also figures into 
story. In her affidavit, 
claims that during the time she was 
employed by Epstein, the financier arranged for her to work on an art project at Wexner's Ohio mansion 
in the summer of 1996. She stayed at Wexner's $47 million 30-room estate for a time, working on the 
project, while babysitting her two younger brothers, who were also staying with her at Wexner's 
mansion, she said. 
One day, Epstein and Maxwell visited and escorted her into a bedroom and then proceeded to sexually 
assault her, she wrote. She said she fled the room and called the local sheriff's office, but did not get a 
response. When she tried to leave the property, she said Wexner's security staff refused to let her go. 
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New Jeffrey Epstein accuser emerges: defamation suit filed 1 Miami Herald 
was working at Mar-a-Lago when she was recruited to be a masseuse to Palm Beach hedge fund 
manager Jeffrey Epstein. She was lured into a life of depravity and sexual abuse. 
By 
"I was held against my will for 12 hours until I was ultimately allowed to leave with my father," she said 
in the affidavit. 
During this same time period, she said Epstein took her and her younger sister, then 15, to a movie in 
New York, where he allegedly rubbed her younger sister in a sexual manner. He then flew the 15-year-
old to his ranch in New Mexico, promising her mother that he would help with her education, 
said. 
Instead, Epstein and Maxwell directed her sister to take off all her clothes and get on a massage table, 
where they touched her inappropriately, 
said. Epstein subsequently flew the sister to Thailand to 
study, and 
did not learn until later what happened to her at the ranch. 
Afterward, she said Epstein and Maxwell called her multiple times, threatening her. "Maxwell and 
Epstein contacted my art clients and individuals in the art community in an effort to ruin my art career," 
she said, adding that they were successful in shutting down any art-related opportunities. 
Journalist Vicky Ward interviewed 
her sister and their mother in 2002 for Vanity Fair, but the 
interviews were stricken from the piece before publication. In a 2015 piece Ward wrote for the Daily 
Beast, the writer said that Epstein had pressured Vanity Fair's then-editor, Graydon Carter, not to publish 
the allegation. She said he also attacked Ward and tried to discredit the mother and her daughters, who 
were never named. 
said she finally came forward with the court filing to support 
in hopes that Epstein and 
Maxwell will be prosecuted. 
"I have struggled throughout my entire life as a direct result of Epstein and Maxwell's actions against me 
and my hope is that they will be held accountable for their crimes. While I am still afraid, I am coming 
forward because I think it is so important to do so," she said. 
The affidavit does not say what her sister was studying in Thailand, but 
Epstein to Thailand in 2002 to study massage therapy. It was then that 
and fled with him to Australia. 
was also flown by 
met her future husband 
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New Jeffrey Epstein accuser emerges: defamation suit filed 1 Miami Herald 
Sen. Ben Sasse questioned attorney general nominee William Barr about the Jeffrey Epstein case on January 15. 2019. 
getting the nominee to commit to having the Department of Justice look into the handling of that case if confirmed. 
By 
The lawsuit says that 
first told others about sex with Dershowitz at the time it allegedly 
happened, and in 2009, although the suit doesn't identify the individuals she told. In 2011, 
was 
represented by lawyers Bradley Edwards and Paul Cassell, who wrote Dershowitz to inform him that 
witnesses had placed him at various locations with Epstein while Epstein was with minors who were 
subsequently identified as victims of sexual assault, the suit says. 
The lawyers were concerned in part because Dershowitz had been a prominent lawyer for Epstein who 
had assailed some of Epstein's victims in 2006 in an attempt to impugn their credibility. Also, they found 
it curious that Epstein's deal included a blanket immunity for co-conspirators of his operation who were 
not named. 
The lawsuit claims that Dershowitz masterminded the deal in order to give himself immunity, an 
allegation that Dershowitz expressly denies. 
sexual allegations against Dershowitz became public in 2014 as part of a court filing by 
Edwards and Cassell. Dershowitz publicly called for the disbarment of the two lawyers, leading them to 
file a defamation suit against Dershowitz which was subsequently settled, with Dershowitz paying the 
two lawyers a substantial amount of money, the suit says. Dershowitz falsely claimed that he was 
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exonerated, when in fact, the settlement was reached in Edwards' and Cassell's favor, according to the 
new lawsuit. 
Additionally, Dershowitz tried and failed to get 
to issue a statement that she had been mistaken, 
the lawsuit asserts. 
In December 2015, Dershowitz wrote an email to Boies, who began representing 
of the email, attached to the lawsuit, shows that Dershowitz suggested that 
saying that she had possibly erred when she identified Dershowitz. 
in 2015. A copy 
submit a statement 
"We should be aiming at a short simple statement such as: `the events at issue occurred approximately 15 
years ago when I was a teenager. Although I believed then and continued to believe that [Dershowitz] 
was the person with whom I had sex, recent developments raise the possibility that this may be a case of 
mistaken identification'," Dershowitz suggested in the email. 
During that same time period, November and December 2015, Dershowitz also engaged in several 
conversations with Boies, as part of an attempt to settle the defamation claim brought by Cassell and 
Edwards. Dershowitz recorded some of those calls, and played excerpts for the Herald. 
The recordings are difficult to decipher, with static that seems to blur the context of some of the 
conversations. But a transcript supplied by Dershowitz appears to show Boies conceding that 
was 
mistaken in identifying Dershowitz. Boies says Dershowitz taped him without his permission and that he 
took his comments out of context. 
"He conflated the conversations, and they are not in the order that they happened," Boies said, stating 
that he was merely assuring Dershowitz that, if they found evidence that 
recollections were 
mistaken, they would have come to an agreement to issue the statement he wanted. 
Ultimately, Boies said, they found her to be truthful, and she passed a lie detector test. 
"Dershowitz ... played and described excerpts from those tapes out of context to reporters to try to make 
it appear that Ms. 
' lawyer's hypothetical comments, and characterizations of Dershowitz's 
assertions, represented that lawyer's conclusions," the suit says. 
To further rebut Dershowitz's recordings, a sworn affidavit is included from another attorney who said 
that he was present when Dershowitz misconstrued what Boies was saying. One of the suggestions that 
Dershowitz proffered was that 
had confused the Harvard professor with another academic —
Dershowitz names him — claiming that the professor looked like him. 
however, was shown a 
photo of that other professor and was adamant that she had not confused him with Dershowitz, the 
lawsuit says. 
"Mr. Dershowitz expressed to me that he believed he was making progress in convincing Mr. Boies that 
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[=] 
was mistaken in identifying Mr. Dershowitz with someone with whom she had sex. I told Mr. 
Dershowitz that I thought he was overly optimistic and reading things into what Mr. Boies was saying 
and hearing what he wanted to hear," wrote the lawyer, David S. Stone, a senior managing partner of 
Boies' firm who previously worked with Dershowitz on the Claus von Bulow attempted murder case, 
involving a socialite accused of giving his wife an overdose of insulin. 
The suit also said 
had accused Epstein and Maxwell of trafficking her for sex to 
Dershowitz and others, and that Dershowitz also tried to discredit 
similarly to how he had 
"After Dershowitz's claimed proof of evidence collapsed, and the evidence of his guilt grew, 
lawyers told Dershowitz in writing that they `had discovered evidence inconsistent with some of [your] 
representations,' noting that some of his travel records were incomplete, and therefore were not adequate 
to show he could not have been in the same place as 
during the time she was working for Epstein, 
the lawsuit said. 
claims that Dershowitz is still working on behalf of Epstein, who is using Dershowitz to 
intimidate victims to deter them from coming forward, fearing a new federal investigation, the suit says. 
In February, a federal judge ruled that the non-prosecution agreement Epstein received was illegally 
brokered by Acosta and other prosecutors in violation of the Crime Victims' Rights Act. As a result, the 
deal is being reviewed by the Justice Department, which has also opened a probe into Acosta's handling 
of the Epstein case. 
Under a broader deal, Epstein pleaded guilty to two prostitution charges in state court and was sentenced 
to 18 months in the county jail. He served 13 months, but spent most of his sentence in work release, 
which allowed him to leave the Palm Beach jail for up to 12 hours a day, six days a week, to go to his 
office in West Palm Beach. 
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