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MARTIN G. WEINBERG, P. C.
ATTORNEY AT LAW
20 PARK PLAZA, SUITE 1000 EMAIL ADDRESSES:
BOSTON, MASSACHUSETTS 02116
FAX
NIGHT EMERGENCY:
April 24, 2015
Via Email and U.S. Mail
John Zucker
Assistant Legal Counsel
Office of Legal Counsel
77 W 66TH St, Room 1628
New York, NY 10023
Re: Good Morning America and Night Line interview with Jane Doe 3
Dear Mr. Zucker:
I represent Jeffrey Epstein. I have been informed by Producer James Hill that ABC
intends to air an interview, conducted by a Good Morning America co-host, of a woman known
in court papers as Jane Doe 3.1 I write to put you on notice that ABC's publication of Jane Doe
3's accusations is grossly negligent or worse. The accusations, many of which relate to my
client, relate to alleged conduct that occurred approximately 15 years ago. The current
accusations are simply reformatted and embellished echoes of previous allegations, which were
first made by Jane Doe 3 to tabloid publications in the United Kingdom in 2011 and which have
no independent news value. These allegations were then and remain now uncorroborated and
have been refuted or undermined by other, credible evidence. Indeed, a federal judge recently
refused to consider these allegations in pending litigation, finding them "immaterial and
impertinent", while striking the allegations and denying Jane Doe 3s Motion to Join, See Jane
Doe 1 and 2 v. United States, 08-CV-80736-KAM (S.D. Fla.), Dkt 324 at 5. In addition, in that
very same litigation, Federal Bureau of Investigation Special Agent Timothy R. Slater filed a
declaration stating that when Jane Doe 3 was interviewed by the FBI in 2007 she refused to
cooperate with the investigation of Mr. Epstein declaring she wanted nothing to do with the
matter. For ABC to air these untested allegations on national television as "news" when Jane
Doe 3 intentionally declined eight years ago to subject these same allegations to verification by
the FBI would be grossly irresponsible and severely damaging to Mr. Epstein and others.
1 Mr. Hill informed me that she was waiving whatever rights to anonymity she might assert but I will, because of
certain legal obligations, refer to her as Jane Doe 3.
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This is particularly true when ABC knows or should know that several, very specific
allegations of Jane Doe 3 have been rebutted and/or demonstrated by others to be false. For
example, I understand that she has accused distinguished Professor Alan Dershowitz of Harvard
Law School of sexual misconduct involving her. Professor Dershowitz has flatly denied that
allegation under oath in a federal court proceeding. I further understand that Professor
Dershowitz offered to play a tape recording for Mr. Hill that evidences that Jane Doe 3 has made
recent contradictory statements—that is, that she was pressured into including Professor
Dershowitz in her allegations and that she has a financial motive in making these allegations.
The Duke of York and the Royal Palace have likewise unequivocally denied Jane Doe's
similar allegations against the Duke. Surely, these unequivocal statements of denial of respected
members of society are entitled to some deference by ABC, particularly where, as here, there is
substantial evidence of bias, improper motive, and serious credibility problems of their accuser.
Moreover, additional claims of Jane Doe 3 can be refuted with objective evidence that is
readily obtainable by ABC. For example, she claims she was in the presence of both former
President Clinton (after January 20, 2001, and before the summer of 2002) and former Vice
President Gore (and his wife) at Mr. Epstein's Virgin Island home. I have been told by Mr. Hill
that she claims to be 100% sure of the facts regarding President Clinton. The claims are
completely uncorroborated and compellingly contradicted by others. Neither former President
Clinton nor former Vice-President Gore and his wife have ever been present at Mr. Epstein's
Virgin Island home. A review of United States Secret Service records, obtainable through a
Freedom of Information Request would prove the falsity of the claim. Virgin Island government
records would provide further confirmation. I also believe that Mr. Hill has been told by
individuals with percipient knowledge that former President Clinton has never been to Mr.
Epstein's Virgin Island home. Upon inquiry, I am certain that you would receive similar denials
from Mr. and Mrs. Gore either directly or by or through their counsel Mr. Boies. Jane Doe 3's
fabrication of these claims against respected former officials undermines completely the
trustworthiness of each and every one of her remaining allegations.
We would expect that, in the wake of the damning independent review of Rolling Stone's
publications of rape allegations involving students at the University of Virginia, ABC would
proceed with similar, uncorroborated allegations with extreme caution. At the very least, ABC
has an obligation to verify—with independent evidence—the truthfulness of Jane Doe 3's
claims. Merely declining to air those portions of her interview that relate to President Clinton
and Vice-President Gore is insufficient. If ABC has concerns about her credibility with respect
to any allegation, it must decline to republish all of her allegations.
In June of 2008, Mr. Epstein pleaded guilty to Florida state charges that do not relate to
Jane Doe 3. After an extensive investigation, the United States declined to prosecute Mr. Epstein
and provided him with a Non-Prosecution Agreement. Mr. Epstein fully conformed to the
responsibilities and obligations imposed on him by that agreement. Mr. Epstein is not engaged
in public activities. He is a private person who has complied and continues to comply with his
legal obligations, and he is attempting to move forward with his life in a productive way. The
allegations of Jane Doe 3 are neither credible nor news worthy. ABC should not publish them.
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Yours Truly,
/s/Martin G. Weinberg
CC James E Hill, ABC News
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