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Filing # 37201585 E-Filed 01/29/2016 03:47:44 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE 15-000072
BRADLEY J. EDWARDS and
PAUL G. CASSELL,
Plaintiffs/Counterclaim Defendants,
vs.
ALAN M. DERSHOWITZ,
Defendant/Counterclaim Plaintiff
/
DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN DERSHOWITZ'S
MOTION FOR CLARIFICATION OF CONFIDENTIALITY ORDER OR RELIEF
FROM THAT ORDER
The transcript of the deposition of non-party Virginia Roberts Giuffre ("Roberts") is
currently under seal as a result of the January 12, 2016 Confidentiality Order in this action.
Dershowitz seeks clarification that the Confidentiality Order does not preclude him or his
counsel from submitting the transcript of the deposition to the Office of the State Attorney, the
Office of the United States Attorney, and other appropriate investigative authorities solely for
purposes of requesting that those offices consider opening perjury investigations regarding
Roberts's testimony. To the extent that the Confidentiality Order precludes such disclosure,
Dershowitz requests that the Court modify it to permit the requested disclosure in the public
interest.
Roberts has stated in an affidavit originally filed publicly in federal court in what the
parties have referred to as the CVRA Action that she was present on Jeffrey Epstein's private
island, Little St. James Island, at the same time as former President Clinton. That affidavit was
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stricken in relevant part from the record by the federal court, but Roberts's counsel filed publicly
a pleading in this case contesting Defendant's assertion that her statements in the media
regarding meeting former President Clinton were untrue. A copy of the public affidavit filed in
the CVRA Action and the excerpted portion of the pleading filed in this action are attached
hereto as composite Exhibit A.
Because former President Clinton did not leave office until January of 2001, and Roberts
has repeatedly stated in publicly filed affidavits that she "escaped" from Epstein while in
Thailand in September of 2002, the alleged meeting with former President Clinton must have
taken place between January of 2001 and September of 2002. As explained in the letter attached
as Exhibit B, former FBI Director Louis Freeh made a request pursuant to the Freedom of
Information Act for documents from the Secret Service regarding Secret Service personnel
travelling with former President Clinton to Epstein's private island and the US Virgin Islands.
Based on the response by the federal government to this request, and his knowledge of the duties,
protocols and operations of security provided to a former President, Mr. Freeh opines in the
attached letter that the absence of such records "strongly establishes that former President
Clinton was not present on Little St. James Island during the period at issue." If Mr. Freeh's
opinion is correct, then Roberts's publicly filed affidavits in which she stated that she met
President Clinton on the island during that period are obviously false. Dershowitz intends to
bring this public information to the attention of the appropriate authorities.
Separate from the public information, Dershowitz also believes that Roberts gave false
testimony at her deposition. The relevant testimony, which Dershowitz intends to provide to the
appropriate authorities, is being filed under seal contemporaneously with this motion. In an
abundance of caution, Dershowitz and his counsel do not want to disclose this non-public
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information even to the responsible public officials with a right and need to know without
obtaining confirmation from this Court that doing so would not violate the Confidentiality Order
or alternatively relief from that Confidentiality Order.
Respectfully submitted,
s/ Thomas E. Scott
Thomas E. Scott
Florida Bar No. 149100
Thomas.scott@csklegal.com
Steven R. Safi-a
Florida Bar No. 057028
Steven.safra@csklegal.com
COLE, SCOTT & KISSANE, P.A.
Dadeland Centre II, 14th Floor
9150 South Dadeland Boulevard
Miami, Florida 33156
Phone: (305) 350-5300
Fax: (305) 373-2294
Richard A. Simpson (pro hac vice)
rsimpson@wileyrein.com
Mary E. Borja (pro hac vice)
mborja@wileyrein.com
Ashley E. Eiler (pro hac vice)
aeiler@wileyrein.com
Nicole A. Richardson (pro hac vice)
nrichardson@wileyrein.com
WILEY REIN LLP
1776 K Street NW
Washington, DC 20006
Phone: (202) 719-7000
Fax: (202) 719-7049
Kenneth A. Sweder (pro hac vice)
ksweder@sweder-ross.com
SWEDER & ROSS
131 Oliver Street
Boston, MA 02110
Phone: (617) 646-4466
Fax: (617) 646-4470
Counsel for Alan M. Dershowitz
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been electronically filed through
the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by
electronic mail: jsx@searcylaw.com, mep@searcylaw.com, scarolateam@searcylaw.com to:
Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Plaintiff, 2139
Palm Beach Lakes Blvd., West Palm Beach, Florida 33409; jonijones@utah.gov to: Joni J.
Jones, Esq., Assistant Utah Attorney General, Counsel for Plaintiff Cassell, 160 East 300 South,
Salt Lake City, Utah 84114; brad@pathtojustice.com to: Bradley J. Edwards, Esq, Farmer, Jaffe
et al, 425 North Andrews Avenue, Suite 2, Ft. Lauderdale, FL 33301; cassellp@law.utah.edu, to:
Paul G. Cassell, Esq.,; smccawley@bsfllp.com, sperkins@bsfllp.com, ftleserve@bsfllp.com to:
Sigrid S. McCawley, Esq., Boies Schiller & Flexner, LLP, 401 E. Las Olas Blvd, Suite 1200, Ft.
Lauderdale, FL 33301, this 29th day of January, 2016.
By: s/ Thomas E. Scott
THOMAS E. SCOTT
FBN: 149100
STEVEN R. SAFRA
FBN: 057028
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EXHIBIT A
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Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 2 of 20
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-80736-CIV-MARRA
JANE DOE #1 and JANE DOE #2,
Petitioners,
VS.
UNITED STATES OF AMERICA,
Respondent.
/
DECLARATION OF
1. My name is and I was born in August, 1983.
2. I am currently 31 years old.
3. I grew up in Palm Beach, Florida. When I was little, I loved animals and wanted
to be a veterinarian. But my life took a very different turn when adults began to be interested in
having sex with me.
4. In approximately 1999, when I was 15 years old, I met Ghislaine Maxwell. She is
the daughter of Robert Maxwell, who had been a wealthy publisher in Britain. Maxwell asked
that I come with her to Jeffrey Epstein's mansion for the purposes of teaching me how to
perform "massages" and to train me professionally in that area. Soon after that I went to
Epstein's home in Palm Beach on El Brillo Way.
5. From the first time I was taken to Epstein's mansion that day, his motivations and
actions were sexual, as were Maxwell's. My father was not allowed inside. I was brought up
some stairs. There was a naked guy, Epstein, on the table in the room. Epstein and Maxwell
forced me into sexual activity with Epstein. I was 15 years old at the time. He seemed to be in
his 40s or 50s. I was paid $200. I was driven home by one of Epstein's employees.
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6. I came back for several days following and did the same sorts of sexual things for
Epstein.
7. After I did those things for Epstein, he and Maxwell said they were going to have
me travel and were going to get an education for me. They were promising me the world, that I
would travel with Epstein on his private jet and have a well-paid profession. Epstein said he
would eventually match me up with a wealthy person so that I would be "set up" for life.
8. So I started "working" exclusively for Epstein. He took me to New York on his
big, private jet. We went to his mansion in New York City. I was shown to my room, a very
luxurious room. The mansion was huge. I got scared because it was so big. Epstein brought me
to a room with a massage parlor. To me, it looked like an S&M parlor. Epstein made me engage
in sexual activities with him there.
9. You can see how young I looked in the photograph below.
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10. Epstein took me on a ferry boat on one of the trips to New York City and there he
took the picture above. I was approximately 15 or 16 years old at the time.
11. Over the next few weeks, Jeffrey Epstein and Ghislaine Maxwell trained me to do
what they wanted, including sexual activities and the use of sexual toys. The training was in
New York and Florida, at Epstein's mansions. It was basically every day and was like going to
school. I also had to have sex with Epstein many times.
12. I was trained to be "everything a man wanted me to be." It wasn't just sexual
training - they wanted me to be able to cater to all the needs of the men they were going to send
me to. They said that they loved that I was very compliant and knew how to keep my mouth
shut.
13. Epstein and Maxwell also told me that they wanted me to produce things for them
in addition to performing sex on the men. They told to me to pay attention to the details about
what the men wanted, so I could report back to them.
14. From very early on I was fearful of Epstein. Epstein told me he was a billionaire.
I told my mother that I was working for this rich guy, and she said "go, go far away." Epstein
had promised me a lot, and I knew if I left I would be in big trouble. I also knew that I was a
witness to a lot of illegal and very bad behavior by Epstein and his friends. If I left Epstein, he
knew all kinds of powerful people. He could have had me killed or abducted, and I always knew
he was capable of that if I did not obey him. He let me know that he knew many people in high
places. Speaking about himself, he said "I can get away" with things. I was very scared,
particularly since I was a teenager.
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15. I visited and traveled with Jeffrey Epstein from 1999 through the summer of
2002, and during that time I stayed with him, as his sex slave, at each of his houses (really more
like mansions) in locations including New York City, New York; the area of Santa Fe, New
Mexico; Palm Beach, Florida; an island in the U.S. Virgin Islands; and Paris, France. I had sex
with him often in these places and also with the various people he demanded that I have sex
with. Epstein paid me for many of these sexual encounters. In fact, my only purpose for
Epstein, Maxwell and their friends was to be used for sex.
16. To illustrate my connection to these places, I include four photographs taken of
me in New Mexico (shown below). The first one is a museum in Santa Fe, New Mexico. We
had gone sightseeing for the day. Epstein took this picture of me. I was approximately 17 at the
time, judging from the looks of it. At the end of the day we returned to Epstein's Zorro Ranch.
The second picture is me on one of Epstein's horses on the ranch in New Mexico. The following
two are from wintertime in New Mexico.
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li.
17. When I was with him, Epstein had sex with underage girls on a daily basis. His
interest in this kind of sex was obvious to the people around him. The activities were so obvious
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and bold that anyone spending any significant time at one of Epstein's residences would have
clearly been aware of what was going on.
18. Epstein's code word for sexual encounters was that it was a "massage". At times
the interaction between Epstein and the girls would start in a massage room setting, it was
always a sexual encounter and never just a massage.
19. In addition to constantly finding underage girls to satisfy their personal desires,
Epstein and Maxwell also got girls for Epstein's friends and acquaintances. Epstein specifically
told me that the reason for him doing this was so that they would "owe him," they would "be in
his pocket," and he would "have something on them." I understood him to mean that when
someone was in his pocket, they owed him favors. I also understood that Epstein thought he
could get leniency if he was ever caught doing anything illegal, or more so that he could escape
trouble altogether.
20. Ghislaine Maxwell was heavily involved in the illegal sex. I understood her to be
a very powerful person. She used Epstein's money and he used her name and connections to
gain power and prestige.
21. One way to describe Maxwell's role was as the "madame." She assumed a
position of trust for all the girls, including me. She got me to trust her and Epstein. It turned out
that Maxwell was all about sex all the time. She had sex with underage girls virtually every day
when I was around her, and she was very forceful.
22. I first had sexual activities with her when I was approximately 15 at the Palm
Beach mansion. I had many sexual activities with her over the next several years in Epstein's
various residences plus other exotic locations. I had sex with Maxwell in the Virgin Islands,
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New Mexico, New York, as well as France and many other locations. I also observed Maxwell
have sex with dozens of underage girls.
23. Maxwell took pictures of many of the underage girls. These pictures were
sexually explicit. Maxwell kept the pictures on the computers in the various houses. She also
made hard copies of these images and displayed them in the various houses. Maxwell had large
amounts of child pornography that she personally made. Many times she made me sleep with
other girls, some of whom were very young, for purposes of taking sexual pictures.
24. Harvard law professor Alan Dershowitz was around Epstein frequently.
Dershowitz was so comfortable with the sex that was going on that he would even come and chat
with Epstein while I was giving oral sex to Epstein.
25. I had sexual intercourse with Dershowitz at least six times. The first time was
when I was about 16, early on in my servitude to Epstein, and it continued until I was 19.
26. The first time we had sex took place in New York in Epstein's home. It was in
Epstein's room (not the massage room). I was approximately 16 years old at the time. I called
Dershowitz "Alan." I knew he was a famous professor.
27. The second time that I had sex with Dershowitz was at Epstein's house in Palm
Beach. During this encounter, Dershowitz instructed me to both perform oral sex and have
sexual intercourse.
28. I also had sex with Dershowitz at Epstein's Zorro Ranch in New Mexico in the
massage room off of the indoor pool area, which was still being painted.
29. We also had sex at Little Saint James Island in the U.S. Virgin Islands. I was
asked to give Dershowitz a massage on the beach. Dershowitz then asked me to take him
somewhere more private, where we proceeded to have intercourse.
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30. Another sexual encounter between me and Dershowitz happened on Epstein's
airplane. Another girl was present on the plane with us.
31. I have recently seen a former Harvard law professor identified as Alan
Dershowitz on television calling me a "liar." He is lying by denying that he had sex with me.
That man is the same man that I had sex with at least six times.
32. Epstein made me have sex with Prince Andrew several times. Prince Andrew,
Maxwell, and I are shown in the photograph below. I had sex with him three times, including
one orgy. I knew he was a member of the British Royal Family, but I just called him "Andy."
33. One day when I was in London (specifically in a townhouse that is under
Maxwell's name), I got news from Maxwell that I would be meeting a prince. Later that day,
Epstein told me I was meeting a "major prince." Epstein told me "to exceed" everything I had
been taught. He emphasized that whatever Prince Andrew wanted, I was to make sure he got.
34. Eventually Prince Andrew arrived, along with his security guards. The guards
then went out of the house and stayed out front in their car. It was just Epstein, Maxwell, and me
inside alone with Andy. I was introduced to the Prince, and we kissed formally, cheek to cheek.
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There was a lot of legal discussion about Andy and his ex-wife ("Fergie"). Then the discussion
turned to me. Maxwell said "guess how old she is." Prince Andrew guessed 17.
35. Then we all went to a Chinese restaurant for dinner and then to Club Tramp, a
fancy "members only" night club in central London. Andy arranged for alcohol to be provided
to me at the club. Eventually we left. I rode with Epstein and Maxwell back to the townhouse.
On the way there, Epstein and Maxwell informed me that the Prince wanted to see "more of me"
that night. Andy traveled in a separate car with his guards.
36. We all arrived back at the townhome and went upstairs. Epstein took a picture of
me and Andy with my own camera. The picture above is that picture, which has been widely
circulated on the internet. Andy has his left arm around my waist and is smiling. The picture was
developed on March 13, 2001, and was taken sometime shortly before I had it developed. I was
17 years old at the time.
37. I wanted a picture with the prince because I was keeping in contact with my
family. I had told my mom and my grandma that I was meeting Prince Andrew and that I'd take
a picture for them. They told me to "be careful."
38. After the picture, Epstein and Maxwell kissed me and said to "have fun." They
left Andy and me alone upstairs. We went to the bathroom and bedroom, which were just steps
away from where the picture was taken. We engaged in sexual activities there. Afterwards,
Andy left quickly with his security.
39. I chatted with Epstein about this the next day. I told him, "it went great." Epstein
said something to the effect of, "You did well. The Prince had fun." I felt like I was being
graded. It was horrible to have to recount all these events and have to try to meet all these needs
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and wants. I told Epstein about Andy's sexual interests in feet. Epstein thought it was very
funny. Epstein appeared to be collecting private information about Andy.
40. When I got back from my trip, Epstein paid me more than he had paid me to be
with anyone else — approximately $15,000. That money was for what I had done and to keep my
mouth shut about "working" with the Prince.
41. The second time I had sex with Prince Andrew was in Epstein's New York
mansion in spring 2001. I was 17 at time. Epstein called me down to his office. When I got
there, Epstein was there, along with Maxwell, Johanna Sjoberg, and Andy. I was very surprised
to see him again. Epstein and Maxwell were making lewd jokes about "Randy Andy".
42. I had the impression that Andy had come there to see Epstein and to have sex me
with. There was no other apparent purpose for Andy to be there.
43. I was told to go upstairs with Andy and to go to the room I thought of as the
"dungeon" (the massage room, but it is really scary looking). I had sex with Andy there. I was
only paid $400 from Epstein for servicing Andy that time.
44. The third time I had sex with Andy was in an orgy on Epstein's private island in
the U.S. Virgin Islands. I was around 18 at the time. Epstein, Andy, approximately eight other
young girls, and I had sex together. The other girls all seemed and appeared to be under the age
of 18 and didn't really speak English. Epstein laughed about the fact they couldn't really
communicate, saying that they are the "easiest" girls to get along with. My assumption was that
Jean Luc Brunel got the girls from Eastern Europe (as he procured many young foreign girls for
Epstein). They were young and European looking and sounding.
45. Afterwards we all had dinner by the cabanas. The other girls were chatting away
among themselves, and Epstein and the Prince chatted together. I felt disgusted, and went
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quickly to my own cabana that night and went to sleep. Prince Andrew must have flown out
early the next morning, as I did not see him when I got up.
46. I have seen Buckingham Palace's recent "emphatic" denial that Prince Andrew
had sexual contact with me. That denial is false and hurtful to me. I did have sexual contact
with him as I have described here — under oath. Given what he knows and has seen, I was
hoping that he would simply voluntarily tell the truth about everything. I hope my attorneys can
interview Prince Andrew under oath about the contacts and that he will tell the truth.
47. I also had sexual intercourse with Jean Luc Brunel many times when I was 16
through 19 years old. He was another of Epstein's powerful friends who had many contacts with
young girls throughout the world. In fact, his only similarity with Epstein and the only link to
their friendship appeared to be that Brunel could get dozens of underage girls and feed Epstein's
(and Maxwell's) strong appetite for sex with minors.
48. Brunel ran some kind of modeling agency and appeared to have an arrangement
with the U.S. Government where he could get passports or other travel documents for young
girls. He would then bring these young girls (girls ranging in age from 12 to 24) to the United
States for sexual purposes and farm them out to his friends, including Epstein.
49. Brunel would offer the girls "modeling" jobs. A lot of the girls came from poor
countries or poor backgrounds, and he lured them in with a promise of making good money.
50. I had to have sex with Brunel at Little St. James (orgies), Palm Beach, New York
City, New Mexico, Paris, the south of France, and California. He did not care about
conversation, just sex.
51. Jeffrey Epstein has told me that he has slept with over 1,000 of Brunel's girls, and
everything that I have seen confirms this claim. Epstein, Brunel, and Maxwell loved orgies with
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kids — that is, having sexual interactions with many young teenagers at the same time.
Sometimes as many as ten underage girls would participate in a single orgy with them. I
personally observed dozens of these orgies. The orgies happened on Epstein's island in the U.S.
Virgin Islands, in New Mexico, Palm Beach, and many other places. Most of the girls did not
speak English. It was my understanding that the girls had been persuaded to come by Brunel
offering them illegal drugs or a career in modeling. Brunel was one of the main procurers of
girls.
52. In addition to Ghislaine Maxwell,
, and were also
involved in the orgies. At this stage, I am hopeful that these other women will come forward and
tell the truth about everything because that will help prevent future similar abuse.
53. I have seen reports saying or implying that I had sex with former President Bill
Clinton on Little Saint James Island. Former President Bill Clinton was present on the Island at
a time when I was also present on the Island, but I have never had sexual relations with Clinton,
nor have I ever claimed to have had such relations. I have never seen him have sexual relations
with anyone.
54. I now understand that Epstein reached a non-prosecution agreement with the
federal government in 2007 and pled guilty to two state crimes in June 2008. I now know that I
was identified by the federal government as one of Epstein's and his co-conspirator's sexually
abused victims. However, no one told me about those events until after they happened.
55. On September 3, 2008, the FBI sent a victim notification letter to me. This was
the first written communication I had received from the FBI. The letter is attached as Exhibit 1.
The letter describes an agreement in which compensation would be made victims of Epstein's
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sexual abuse. The letter also said that the federal government was going to "defer federal
prosecution." No one had told me about deferring federal prosecution before this.
56. In 2011, two FBI agents, called me in Australia and then came to meet me. They
met me at the U.S. Consulate in Sidney. They seemed to be very professional and hard working.
I thought to myself, "Wow, these people will do the right thing against the bad guys and protect
me."
57. The agents were mainly focused on Epstein but while there I provided them some
information about others who were involved in illegal acts as well. I was aware that a false
statement to these law enforcement officers was a crime and I told the truth — giving them the
information that I could recall about the individuals they inquired about.
58. Epstein also trafficked me for sexual purposes to many other powerful men,
including politicians and powerful business executives. Epstein required me to describe the
sexual events that I had with these men presumably so that he could potentially blackmail them.
I am still very fearful of these men today.
59. I will continue to cooperate fully in the investigation and prosecution of Epstein,
Maxwell, or any of their friends who participated in the sexual abuse of minors. I also hope that
this information is treated in a way that will keep me safe from Epstein and others criminals
identified here so as to encourage more victims of similar crimes to come forward. If these
crimes are not prosecuted, despite my volunteering this information and cooperation, then it may
deter other similar victims from coming forward.
60. In this affidavit, I have tried to focus on how I was trafficked for sexual purposes.
I have not described all of the details of the sexual activities Epstein forced me to have. Also, I
have not described all of the details of the other events discussed here. If a judge wants me to
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present my information in more detail, including more specific descriptions of the sexual
activities with the men Epstein sent me to, I could do so.
61. I have directed my attorneys, Bradley J. Edwards and Paul G. Cassell, to pursue
all reasonable and legitimate means to have criminal charges brought against these powerful
people for the crimes they have committed against me and other girls. They are representing me
in this case pro bono.
62. Since I filed my motion in this case, my credibility has been attacked. I am telling
the truth and will not let these attacks prevent me from exposing the truth of how I was trafficked
for sex to many powerful people. These powerful people seem to think that they don't have to
follow the same rules as everyone else. That is wrong. I hope that by coming forward, I can
help expose the problem of sex trafficking and prevent the same sort of abuse and degradation
that happened to me from happening to other girls.
63. I declare under penalty of peijury that the foregoing is true and correct.
Executed this
day of January, 2015.
(Location of signature left undisclosed for security reasons)
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Filing # 33754151 E-Filed 10/27/2015 06:33:15 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIVIL DIVISION
BRADLEY J. EDWARDS, and
PAUL G. CAS SELL,
Plaintiffs,
V.
ALAN DERSHOWITZ,
Defendant.
CASE NO. CACE 15-000072
CONSOLIDATED REPLY IN SUPPORT OF NON-PARTY JANE DOE NO. 31 AND
BOIES, SCHILLER & FLEXNER LLP's MOTIONS TO QUASH OR FOR
PROTECTIVE ORDERS REGARDING SUBPOENA SERVED ON THE NON-PARTIES
Defendant served virtually identical subpoenas on non-party Giuffre, and her counsel
Boies, Schiller & Flexner LLP ("BSF"). In an effort to conserve judicial resources, the non-
parties are submitting a consolidated reply requesting that this Court quash the unreasonable and
oppressive subpoenas pursuant to Florida Rules of Civil Procedure 1.410(c)(1), or alternatively,
issue protective orders sharply limiting the scope of the abusive subpoenas pursuant to Florida
Rules of Civil Procedure 1.280(c).
INTRODUCTION
After publicly stating that his main goal in seeking discovery from Giuffre is to put her in
"jail"2, Defendant served this non-party with a subpoena containing twenty five (25)
unreasonable and oppressive requests. It is without question that Giuffre was sexually abused as
1
Jane Doe No. 3 is Virginia Roberts Giuffre, and will hereinafter be referred to as "Giuffre."
2 See Exhibit 1, CNN International, New Day, January 6, 2015. See also Exhibit 2, Australian Broadcasting System
(ABC), January 6, 2015. "My goal is to bring charges against the client and require her to speak in court."
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Jeffrey Epstein. Defendant spends over five (5) pages discussing the federal action and eleven
(11) of his subpoena Requests (Jane Doe Subpoena 1, 5, 6, 7, 8, 9, 12, 13, 14, 22 and 24; BSF
Subpoena 3, 6, 7, 8, 9, 10, 12, 13, 14, 19 and 22) relate to the federal action or Jeffrey Epstein.
For example, Request 24 seeks "All documents concerning, relating or referring to your
assertion that you met former President Bill Clinton, former Vice President Al Gore and/or Mary
Elizabeth "Tipper" Gore on Little Saint James Island in the U.S. Virgin Islands." Defendant
claims that this discovery would go to the issue of whether or not Giuffre is telling the truth
about Defendant — but that effort at impeachment is clearly collateral at best and fails to address
the central issue in this case. That issue is whether the Defendant had any basis to support his
media assault against two lawyers claiming that they fabricated and then publicly filed false
charges of criminal conduct on the part of the Defendant. It is the Defendant's credibility and
not the credibility of Giuffre that is the focus of this defamation action. Defendant suggests that
Giuffre must be a liar because it would be unheard of for one of Epstein's young girls to have
met President Clinton. Quite the opposite is true. There are a number of accounts documenting
Clinton's regular visits with Epstein. For example, Chauntae Davies recently showed pictures on
The Inside Edition program of her travels with other young women in the company of Bill
Clinton and Jeffrey Epstein on Epstein's plane. See Exhibit 4, Tolita Express ' Masseuse
Reveals Lurid Details from Jeffrey Epstein's Private Plane For the Rich, Inside Edition, April
27, 2015. The Epstein flight logs also demonstrate that former President Bill Clinton traveled
with Jeffrey Epstein and other young women. See Exhibit 5, The Gauker, January 22, 2015. All
of that information, while no doubt interesting, is irrelevant to the defamation issue before this
Court except to the extent it casts doubt on the Defendant's own credibility.
7
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EXHIBIT B
HOUSE OVERSIGHT 010908
Professor Alan Dershowitz
Harvard Law School
1575 Massachusetts Avenue
Hauser Hall 518
Cambridge, MA 02138
Hon. Louis J. Freeh
Mobile: 202.215.8321
January 22, 2016
RE: FOIA Request
Dear Professor Dershowitz:
As you know, on April 6, 2015, a request was made to the United States Secret Service under the federal
Freedom of Information Act (FOIA; 5 U.S.C. Sec. 552), relating to the period 1/01/01 to 1/1/03, for "any
and all shift logs, travel records, itineraries, reports and other records for USSS personnel traveling with
former President Bill Clinton to Little St. James Island and the US Virgin Islands" (Attachment A).
The basis of the above-described FOIA request was a claim by Virginia Roberts, in court papers filed in
early 2015 in Florida federal court, that she and former President Clinton were on Little St. James Island
at the same time during the 1/01/01 to 1/1/03 period.
As set forth in a January 16, 2016 letter from Kim E. Campbell, United States Secret service Special
Agent In Charge, Freedom of Information Act and Privacy Act Officer, the "USSS has conducted a
reasonable search for responsive records. It appears, from a review of USSS main indices, that there are
no records pertaining to your request that are referenced in these indices" (Attachment B).
I therefore conclude from this response that former President Clinton did not in fact travel to, nor was he
present on, Little St. James Island between January 1, 2001 and January 1, 2003.
Based upon my experience and knowledge of the duties, protocols and operations of USSS Protective
Details, the Special Agents accompany and escort former President Clinton 24 hours per day, and would
have certainly went with him to Little St. James Island during the period at issue. If the Agents had
accompanied the former President to that location, they would had been required to make and file shift
logs, travel vouchers and related documentation relating to the visit.
The total absence of any such records and documentation, in my opinion, strongly establishes that former
President Clinton was not present on Little St. James Island during the period at issue.
Best Regards,
Louie Freeh
HOUSE OVERSIGHT 010909
DEPARTMENT OF HOMELAND SECURITY
UNITED STATES SECRET SERVICE
WASHINGTON, D.C. 20223
Freedom of Information Act and Privacy Act Branch
Communications Center
245 Murray Lane, SW, Building T-5
Washington, D.C. 20223
Date:
Patti Bescript
3711 Kennett Pike, Suite 130
Wilmington, DE 19807
File Number: 20150826
Dear Requester:
This is the final response to your Freedom of Information Act/Privacy Acts (FOIA/PA) request
originally received by the United States Secret Service (USSS) on April 16, 2015, for information
pertaining to any and all shift logs, travel records, itineraries, reports, and other records for USSS
personnel traveling with former President Bill Clinton to Little St. James Island and the US Virgin
Islands.
In response to your request, the USSS has conducted a reasonable search for responsive records. It
appears, from a review of USSS main indices, that there are no records pertaining to your request
that are referenced in these indices. Enclosed is a copy of your original request.
Alternatively, if you deem our decision an adverse determination, you may exercise your appeal
rights. Should you wish to file an administrative appeal, your appeal should be made in writing and
received within sixty (60) days of the date of this letter, by writing to: Freedom of Information
Appeal, Deputy Director, U.S. Secret Service, Communications Center, 245 Murray Lane, S.W.,
Building T-5, Washington, D.C. 20223. If you choose to file an administrative appeal, please
explain the basis of your appeal and reference the case number listed above.
If you have any questions or would like to discuss this matter, please contact this office at
(202) 406-6370. FOIA File No. 20150826 is assigned to your request. Please refer to this file
number in all future communication with this office.
Enclosure: Copy of Original Request
S Campbell
botalL--
raI Agent In Charge
1171(
Freedom of Information Act & Privacy Act Officer
HOUSE OVERSIGHT 010910
Patti Bescript
3711 Kennett Pike
Suite 130
Wilmington, DE 19807
302 824 7144
April 6, 2015
Delores Barber
Deputy Chief FOIA Officer, Director, Disclosure & FOIA, The Privacy Office
Department of Homeland Security
Headquarters & Privacy Office
Building 410 - STOP-0655
245 Murray Drive, SW
Washington, DC 20528-0655
FOIA REQUEST
Dear FOIA Officer:
Pursuant to the federal Freedom of Information Act, 5 U.S.C. § 552, I request access to
and copies of For the period 1/1/01 to 1/1/03, any and all shill logs, travel records,
itineraries, reports, and other records for USSS personnel traveling with former President
Bill Clinton to Little St James Island and the US Virgin Islands.
I agree to pay reasonable duplication fees for the processing of this request.
If my request is denied in whole or part, I ask that you justify all deletions by reference to
specific exemptions of the act. I will also expect you to release all segregable portions of
otherwise exempt material. I, of course, reserve the right to appeal your decision to
withhold any information or to deny a waiver of fees.
I look forward to your reply within 20 business days, as the statute requires.
Than you for your assistance.
SiqcdreIY.
Patti Bescript
HOUSE OVERSIGHT 010911