UNITED STATES DISTRICT COURT-4.5 SOUT-5.4HERN DISTRICT OF YORK VIRGINIA GIUFFRE,-5.9 Plaintiff against GHISLAINE MAXWELL Defendant Index No Civ RW8.8S REPLY DECLARATI-6.1O-2.9N OF ALAN DERSHO-7.6W.1ITZ6.8 IN FURTHER SUPPORT OF MOTION TO INTERVENE AND ALAN 2750DERSHO-7.5W.2ITZ declares under penalty of perjury that the following is true and correct am8 personally fam8iliar with the facts set forth in this Reply Declaration,5.4 which I subm7.8it in further support of my pending motion to intervene and to unseal the Requested Docum7.9e-1.1nts as that term is defined in Paragraph of August Declaration.5.6 Introduction and Overview than offering a valid and pr-7.5oper basis for opposing my m7.7o.1tion the papers subm7.8itted on behalf of plaintiff Virginia Roberts Giuffre?particularly the lengthy declaration of Paul Cassell one of Ms Giuffre?s lawyers and a federal judge?are little more than an effort to revive and further the false and scurrilous allegations of sexual m7.8i-2.2sconduct that com7.9p.3elled to seek the Court?s assistance in the first As his declaration clear Mr C7.5a-.9ssell has crossed the line from8.1 bei7.6ng a legitim8.1ate advocate fo5r a client to being a lawyer who is seeking to justify his own conduct in the face of com8.3p.7elling evidence that his client is a thoroughgoing liar That was after all the gravam7.7e-.1n of Mr Cassell?s case against the assertion now rep5.7eated at leng5.3t-.9h this Court that Ms Giuffre?s lawyers Case Document Filed Page of had a valid basis for dissem8.2i0nating her false grot5.2esque and im8.2pertinent alleg5.6ation5.6s0 against in a public filin5.5g And it is that fig5.6ht essentiall that Mr Cassell reign5.3ites in his declaration in this To be clear this not a fig5.2h.2t that th5.2at I started and it is certainly not one that I asking this Court to referee or resolve in any way I only asking that the Court ref8.3u.3se to allow its Protective Order which was entere-6.7d0 based upon a stipulation that explicitly contem8.2plated that the Order be m8.2odified from8.2 being used to prevent from disclosing docum8ents that rev5.4eal th5.4e now again been subjected to an unfair and unwarranted false attack on credibility and reputation for personal rectitud5.5e-.8 I no choice but to respond on the m8.1e-.9rits begin by again swearing under oath that I did not sexually abuse Virginia Roberts Giuffre and that any allegation or suggestion to the contrary is categorically false I never had sexual contact with Ms Giuffre of any kind and to knowledge I never even her until her deposition in By swearing to this I deliberately exposing myself to a perjury prosecution and disbarm7.9e-1.1nt if I not telling 7the truth If Ms Giuffre were to subm7.9it an affidavit repeating her false allegations against I would welcom8e-.2 and cooperate with a crim8inal investig5.4ation by any prosecutorial office as to whether it is Ms Giuffre or I who is comm8itting perjury It is in5.4escap5.4ably clear th5.4at one of us is lying under oath I kno5.4w it is not this backdrop and the facts set forth in my August Declaration Mr Cassell on his client?s behalf has put into the reco5.3rd a declaration replete with factual inaccuracies om8issions and f8.4l-2at-out m8i-2srepresentations Am8ong other things he m8.1i-1.9sstates im8.1portant elem8.1ents of both the Victim8.1s Rights Act lawsuit filed by Ms Giuffre and others in Florida the CVRA Action and the defam)7.9a-.2tion lawsuit that he and his Case Document Filed Page of colleague Bradley Edwards brought against Edwards Dershowitz Case No CACE Cir Ct Broward Cnty Fla Moreover he elides or m)7.7i-2.3scharacterizes testim7.7ony gathered in those and other proceedings in order to them appear incu6lpatory of when in fact they are just the opposite doing so Mr Cassell seeks to ac-8.7com8.3p.5lish two5.5 goals sim8.3u.5ltaneously5.5 firs6.3t to suppress inform8.1ation?the Requested Do6.9cum8.5e-.5nts?which exculpates from8.5 the charges of sexual m7.7i-2.3sconduct while allowing Ms Giuffre and her allies to publicly dissem7.8i-2.2nate those selected facts that they believe support her allegatio9.8ns against me and second to prove that Mr Cassell?and by extension his colleague Mr Edwards and Ms Giuffre?s current lawyers at Boies Schiller Flexner LLP?have a valid factu5al basis for continuing to press Ms Giuffre?s false allegation5.6s-.2 Mr Cass4.8ell?s effort an unm8.4itigated failu5.6re as this declaration dem7.8onstrates of the Cassell Declaration goes far beyond what is reasonably required to respond to the instant and while it surely has the distinct air of protesting too m7.8u1ch I cannot stan6d m7.8u1te in th6e face of this continu5.1i-2.1ng5.1 assault on my character As this declaration and the acco5.8mpanying reply brief will dem8.6onstrate the charge4.7s agains5t-.4 are baseless and unsealing the Requested Docum7.7e-1.3nt is6 the only proper response to Ms G7.3i-2.1uffre?s efforts to smear through the legal process its effort to block the unsealing of the Requested Docum7.8e-1.1nts and to justify Ms Giuffre?s lawyers decision to represent her the Cassell Declaration cites five sources Case Document Filed Page of I will address each of these in detail in turn As will imm8.6 ediately becom8.6 clear the inform8.4 ation presented by Mr Cassell in no way substantiates Ms Giuffre 2s claim8 To contrary much of the evidence ntrad5.8 cts Ms Giuffre 2s version of events In addition I offer a few final points about tters that dem8.2 onstrate clearly that Ms Giuffr-9.5 is not a cred5.5 ible witness.5.5 The Cassell Declaration cites as Mr Cassell conceded in his deposition in the Edwards defa-7 tion case nam7.8 does not even app6 ear in Palm8 Beach Police Departm8 nt10 Report uch less5.2 does the Report contain an allegation that I sexually abused som7.8 one See Ex at Deposition Transcript of Paul Cassell October First I was not present in that hom7.7 on Mr Epstein 2s private island or at his New Mexico ranch or on Case Document Filed Page of his airplane?during the tim7.8e Ms Giuffre was associated with Dershowitz Decl Nothing abo5.2u.2t Ms Giuffre?s relation5.2ship with Mr Epstein or her age could have been obvious because I never her S9.7econ5.5d there is simply no evidence that Mr Epstein5.5?s alleged abuse of victim8.1s at hi6s in Palm Beach was obvious known to any vis5itin5.6g guests that the abuse took is alleged to have taken in a sep5.6a-.7rate part of the house nam8.1e-.9ly Mr Epstein?s private bedroom8.1 Giuffre and her counsel have alleged that she was not the only young girl that I had sexual contact with i.e that there were others Of course no such persons have ever presented them7.8selves to corroborate this accusation Nonetheless Mr Cassell latched on to this allegation as a basis for his filing in th7.9e CRVA Action which as a serial abuser 11.-4749.6Dem8onstrating how little Mr Cassell really had go on in this regard I ask the Court to consider Mr Cassell?s respon9.6se to a question put to him7.8 in deposition concerning who other than his client he had 5.5reason to believe was abused by All Mr Cassell could m7.9u.3ster was this 41CASSELL I have in m8i-2nd as possible sexual abuse victim8.7s that Dershowitz may or not have abused And I have not been able pinp5.6oint ex5.6actly5.6 what happ5.6ened becau5.6se the people who would be the po5.6sition5.6 to help sort out what the were sp7ecifically Jeffrey Epstein am7.9ong others have refused to cooperate and give those emphasis added Ex at very idea that Mr C7.5a-.9ssell coul-6.5d claim8.1 that without a list of alleged victim8.2s that he believes that I may or may not have abused would provide a basis for publicly accusing of heinous crim7.8es well illustrates Mr Cassell?s m7.8i-2.2ndset Citations to 6De6.9cl refe6.9r m11.6oving dec6.9l2.6aration.4.9 E6.3x3.4hibits thr4.1o3.4ugh 6X attached this5.8 Reply Declara6.2tion Case Document Filed Page of As the reco5.8 rd dem8.6 onstrates I cou5.8 not have abused Virginia Roberts Giuffre because as the records tab6.1 lish I was e2 ver in Epstein5.9 2s Palm8.7 Beach hom8.7 private island ranch or airplane during the two years that she was associated with Mr Epstein neither co5 rroborates Ms Giuffre 2s false accu6 sation no5 supports the decision by Mr Cassell Mr Edwards and the other lawyers for Ms Giuffre to publicly accuse of such pedophila In his Declaration Mr Cassell suggests that This allegation and the string of inferences necessary to ake it 223work is patently absurd In his deposition in the defa-5.7 tion case against Mr Cassell acknowledged that nam7.9 did not appear in the aircraft flight logs during the tim8.5 period in which Ms Giuffre was associated ith Mr Epstein CASSELL The face o6 f4 the flight logs for the relevan5.4 period of tim7.9 we call it the hot period of tim7.9 or whatever you want did not reveal the presence of Mr Dershowitz on those flights yes Okay So during the period actually there 2s no flight log that shows Virginia Roberts and Professor Dershowitz on the sam7.8 airp6 lane co6 rrect A That 2s understanding yes Ex at Case Document Filed Page of to draw connecti7.5on between and young girls on the airplane Mr Cassell also states that During my deposition in the Edwards case I was asked about and shown photos of Tatiana I said6.4 that I thought she appeared to about years old It turned out that estim8.8ate was correct T6.8h1is exchang6e-.2 followed DERSHOW8.8I-7TZ I m7.8u0st say during the recess my wife-6.2 Googled Tatiana and found out that she was in fact years old in sic at the tim7.7e she flew on th6.8at airplane So that my characterization of her as about years old is abso5.7lutely5.7 correct And the im8.6plication that you sought to draw by showing those pictures was not only demonstrably false but you could have easily discovered that the im8plication you were drawing was dem7.3onstrably false by simply taking one second and Googling her as wife did Ex at Deposition Transcript of Alan Dershowitz October fact,5 I4 m11.8eant the year 6Acc6.8o-3r4d-3ing Ms 6K4.3o3.1vylina was born on See 7.8w1.2iki/Tatiana_Kovylina Case Document Filed Page of Cassell was present at October dep5.9o.9sition in th5.9e Edwards case and he is aware of Tatiana Kov4.9y-.1lina?s actual age Yet That is false Josefsbe5.3rg-filed civil com8.7p.7laint did not Cassell was not relieved of his professional obligation to investigate the bona fides of Ms Giuffre?s claim8.8s because th5.9e Josefberg-drafted cas5.3e does not me as an abuser Moreover Mr Josefsberg has continued to m8a-1intain a personal and prof8essional relationship with som7.7e-1.3thing he would not have done if he believed I had abused his client?a fact that Mr Cassell and the other lawyers could have readily ascertained was it reasonable to accuse of pedophila based on Case Document Filed Page of As Mr Cassell is well aware Jeffrey Epstein was heavily involved in funding acad5.5 ic research at Harvard5.1 and kept an office there and he was consequently friendly with ny academ7.8 ics including David5 Gergen Marvin Min5 sky5 Larry Summ7.9 ers Stephen Kosslyn Henry Rosovsky Howa-7.1 rd Gardner and Stephen Jay Gould ong others ccording to workers at Mr Epstein 2s Palm7.9 Beach nsion he received visits from7.9 riends from7.7 rvard and her ery important people Ex at Deposition Transcripts of Alfredo Rodriguez July and August All f3 the 223evidence that Ms Giuffre and her lawyers claim7.8 icates me is equally applicable to dozens of other academ8.1 ics and public figures who were associated with Mr Epstein 227including Larry Summ8.4 ers Stephen Hawking Henry Rosovsky Nathan Myhrvold Steven Pinker Martin owak Daniel Dennett David Gergen George Church Richard Dawkins Gerard Hooft David Gross Frank ilzek Howard Gardner Stephen Jay Gould and ny hers Of course Ms Giuffre 2s credibility on these atters is nil cite exam7.6 ple rvard Professor is ne of the 223academ7.8 icians Ms Giuffre has accused In the th6 at I trying to uns5 eal My relationship with Jeffrey Epst12.3 ein prior whe6.5 he was5.9 accuse6.5 I becam11 one of his lawyers was academ10.8 ic and tellectual in nature Along with any prominent academ10.9 ics I attende5.9 seminars other e6 ts y2 at his office in Cam9.8 ridge I did send him9.8 my anuscripts t7 review and I acknowledged his int7 ellectual input in knowledgm11.7 ents to ral of my books6 ny her acade6.9 ics were quaintanc6.9 es of Mr stein They4.3 inter4.3 acted with on a what gula6.4 basis uding duri8.4 ng the period in ich allegedly abusing uffre6.2 yet to knowledge ey no idea that8.9 have6.9 enga7 ged in acts with nors,5.1 because he kept his private5.9 life letely eparate from10.9 his academ10.6 ic life I ve neve6.6 see Mr stein with unde7.6 rage7.6 girl.5.8 Case Document Filed Page of Dershowitz Decl Ex at Dershowitz Decl Ex at Case Document Filed Page Giuffre has also claim7.8ed to have had sex with such prominent individuals as form7.7er Case Document Filed Page of To summ7.7 arize before choosing to file the Motion for Joinder in the CVRA lawsuit at publicly accu5.7 sed of pedophilia Mr Cassell and Mr Edwards were aware or should have been aware of Moreo5.9 er they were aware or should have been aware of glaring problem7.8 in Ms Giuffre 2s credibility Yet Ms Giuffre 2s lawyers decided to treat her as a credible witness and to accuse of a heinous crim7.8 on the basis of her inconsistent and incoherent testim8 ony alone I beli6.9 that I was accused by her becau5.7 se my nam8.7 along with that of Prince Andrew 227was certain to garner international publicity Case Document Filed Page In the first ace en a second-ye6.8 ar law studen6 knows that adverse inferences can only be drawn against a party who either invokes the Fift Am8 endm8 ent-7 in a civil case him7.9 or herself or controls the witness who does so as in an ployer-em7.9 loyee relationship See LiButti United States F.3d 2d Cir Obviously I have never refused to answer questions about Ms Giuffre 2s absurd and false all egations against have repeatedly denied them7.8 outright der oath 227and I exercise no control over any of Mr Epstein 2s associates who invoked their Fifth endm8.5 privilege fact is the thre9.5 women 227Sarah Kellen Adriana Mucinska and Nadia Marcinkova 227all asserted their Fifth endm8.5 ent privileges when answering every sing6.1 le question pos5.2 ed to them8.8 in their depo6 sition6 not o1 lely in resp5.8 onse to ques5 tions abou5.8 For exam7.5 ple here is this exchange from7.9 he deposition of Ms Kellen Did you ever eet Bill Clin6 ton6 A Kellen On the instruction of my lawyer I st invoke Fifth endm8.8 ent right Did you ever fly with these three gentlem7.7 en and Jeffrey Epstein to Africa on Jeffrey Epstein 2s airplane A At the instruction of lawyer I st invoke Fifth endm9.8 right.7 Case Document Filed Page Ex at Deposition Transcript of Sarah Kellen March As Mr Cassell well knows witnesses risk waving their Fifth endm8.3 privilege by invoking it only selectively This is why defense attorney generally advise their clien5.6 ts to claim8.4 the Fifth as to all questions these individuals been asked if they knew whether I had assassinated ohn Kennedy they would have taken the Fifth In truth I sincerely wish that Mr Epstein 2s associates had not invoked the Fifth endm7.6 ent with regard questions about me Had they testified fully and truthfully I would have been shown to have done nothing wrong kewise Kellen Ms Mucinska and Ms Marc inkova asserted their Fift endment pri8.3 vilege when que6.4 stione6.4 bout a ber of celebrities incl8.4 udi8.4 ng vid ppe6.7 rfield vin Spacey and Les e7 xner ong othe6.6 rs O4 of the prosec6.6 uting attorneys,4.8 frustrated by is ctic observed:8.1 I think it 2s absolutely absurd that she 2s objecting to for ese questions or taking the6.1 fth of these questions I ean I nt to sic to ask ow if is I 2s ing Fift5.7 at est5.7 as well at Case Document Filed Page This effort fails under even cursory scrutiny Case Document Filed Page fact Mr Alessi has since provided an affidavit flatly denying that he saw both Ms Giuffre and I at the Palm Beach m8.1a-5.9nsion at the I was never asked by any attorney6.5s-.5 if Virginia Roberts cam8.1e to the house w8.2h0en Mr Dershowitz was there If I had been asked I would have answered that I never saw Virginia Roberts at the house when Mr Dershowitz was there Ex at Affidavit of Juan Alessi January Indeed in his affidavit Mr Alessi goes on to say I never saw Mr Dershowitz do anything im7.8proper or be present while anyone else was being im7.8proper Id Alessi?s affidavit also confirm7.9s that Mr Cassell and Edwards failed5.4 to interview him7.7 as part of their supposed investigation into Ms Giuffre?s claim8s and consequently grossly m7.9i-2.1srepresented the st5.6atem7.7ents he in his deposition The following statem7.9ent by Virginia Roberts?s atto6.1rney6.1s.3 and their own attorney in a f8.8iling5.8 on Decem8.2ber is not accurate and is a m7.9i-2.1srepresentation of what I said5.7 in deposition Aless4.9i-.5 was able to identify a photograph of Ms Giuffr-6.9e as som7.9e-1.1one who was at the m7.8a-1.2nsion as sic the tim7.8e as Dershowitz.6 As far as I can recall since I gave my deposition in I have never been asked by Brad Edwards or Paul Cassell about knowledge regarding Virginia Roberts or Alan Dershowitz or about deposition testim7.8ony Id at in an affidavit Mr Alessi states that Case Document Filed Page of The following statem7.9ent by Virginia Roberts?s attorneys in a filing on January not accurate and is a m8.6i-1.4srepresentation of what I said in deposition the private upstairs roo5.9m where Dershowitz his m8.7assages was that contained a lot of vibrators?Maxw8.3e0ll had a laundry basket full-7.1 of those toys in that room I did not state or im8.3ply that vibrators or sex toys were found after m7.8a-1.2ssages in other rooms used by guests because that was not the case Guests having m7.8a-1.2ssages did not have m7.8a-1.2ssages in Mr Epstein?s private bedroom7.8 suite This area was priv5.2ate and off lim7.7its g5.9u.9ests which I to the lawyers during my deposition Id at Alessi underm7.8ines num7.8erous other elem7.8ents of Ms Giuffre?s account as well For exam7.6ple Mr Alessi did not see any photographs of Virginia Roberts in Mr Epstein?s house??partially naked or otherwise Id at And contrary to Ms Giuffre?s description m7.5a-1.5ssages were not a code word for sexual encounters Many guests at the Epstein m7.8a-1.2nsion received m7.8a-1.2ssages from7.8 profe5.4ssional m7.8a-1.2sseuses?and all of whom were as Mr Alessi testified overage to m7.9aybe m7.9i-2.1d-forties Id at Indeed despite working for Jeffrey Epstein for years Mr Alessi was unaware of any m7.6a-1.4sseuses being under the age of Id be clear the only m7.8a-1.2ssage I recall receiving at the Epstein hom8.2e was conducted by a professional m7.6a-1.4sseuse?a in her in her or This occurred well outside the tim8.4efram8.4e-.6 when Ms Giu5.6ffre was a7ssociated with Mr Epstein and I acknowledged this in num7.6erous interviews shortly after Ms Giuffre accused In addition there were never See for exam10.5ple Bob 6Norman Alan De rshowitz 6?Sex Slave Accuser 6is Serial Liar Prostitute 6Local News January av7.9ailable7.9 at Case Document Filed Page of any sex toys in any room7.6 I ever stayed in nor were there any visible pictures of naked young My children and grandchild5.5ren stay5.5ed the room8.3s in question at Mr Epstein?s hom8e during Christm7.8a-1.2s of I would never have allowed to stay in a hom7.8e with such item7.7s nor would I have stayed in such a hom7.7e But Mr Rodriguez was clear that he did not know whether I received a m8a-1.2ssage and did not know if I was aware that there were young girls present in the house Okay When Alan Dershowitz was at the house I understood you to say that these local Palm8.7 Be-5.9ach girls would com8e-1 over to the house while he was there but you?re not sure if he had m7.8a-1.2ssage from any of those girls A Exactly.6 And wha-6t-2 would he do while those girls were at the house A He will read a book with a glass of wine by the pool stay6.1 inside.6.1 Did he ever talk to any of the girls A I don?t know sir Certainly he knew that they were there prostitute I ne7.5ver 6de7.5nied 6ha7.5ving one pr ofessional m10.8a.9ssage I 6did trut7.8hfully state that it was a lie to claim10.8 6that I sexual m11.9a.9ssages in room11.9 full of se7x 6Kellen in 6her late and knowle6.5dge6.5 6was legitim11.6a.7te em5.6ployee 6of 6Epstein.4.8 6M4a.6rcinkova was knowledge an adult friend 6of Mr Epstein Case Document Filed Page of A I don?t know sir Ex at Rodriguez?s testim7.7ony contained nothing inculpatory of and inasm7.6u.8ch as it concerned the period and later,6.5 it has absolutely no bearing on Ms Giuffre?s allegations about since Ms Giuffre left Mr E5.8p0stein?s orbit in Donald Trum8p was a friend of Jeffrey Epstein is that not correct A I really don6.2t understandin11.8g.1 is yes but I I don?t have a lot of information about Trum7.8p It?s true also is it no5.6t that Mr Trum8.3p was a frequent visitor to Mr Epstein?s resid5e-1.2nce A I I know that he visited frequent I I don?t have a lot of inform7.8ation about Trump And his is circled in this book is it not Including Pete6.6r Soros J6o-3.2seph and Fl7.6ori7.6na 6Pinto 6Veira Cotri7.9n 6Evan 6Ande5.9rson 6Michelle 6Eric 6Gany Cindy Lopez Tim11.1othy Newcom11.1be Do uglas 6Schoettle Caroline St ark Larry 6Visoski and Pat Sawyers 6Lynn 6Fontanella Christophe Gaie Bill Ma6.3ro net Mike Pazul7.8o-3 6Alan Stopek and B8ruce Ki7.8ng Case Document Filed Page of A I believe it is.6 Based on him7.8 assum7.8i-2.2ng he?s a frequent visitor to Mr Epstein5.9?s hom8.7e and that he?s a fr-5.5iend of Mr Epstein?s and that his is circled in this book do you infer that he was engaged in crim8.9inal sexual abuse of A No Ex at A7.3g.1ain these assertions are false or m7.3i-2.2sleading and absurd in equal m7.8easure r-7e-1.2presentation of Jeffrey Epstein I was a of an extensive legal team7.3 which co5.1llectively decided how Epstein should interact with law enforcem7.9ent during their investigation Together with other mem8.1b.3ers of the legal team7.9 I am7.7ong others communicated with the Palm7.7 Beac-6.1h State Attorney?s Office?including scheduling m7.5eetings to depose Epstein?at the behest of the clien5.4t This behavior does not constitute instead it 4.3reflects a leg5.9al strategy dev5.4i-1.8sed by a team of defense law8.3yers aim7.9ing to secure the best possible result for their client Case Document Filed Page of Although a legal assistant for Bradle9.4 Edwards one of Ms Giuffre 2s lawyers once claim7.9 ed that I was served with a subpoena in this was not true I was ever served with a subpoena and contem7.7 poraneous docum8 entary evidence proves as m8 uc-6 In August another attorney representing Ms Giuffre Jack Scarola called to ask that I provide inform7.8 ation on Mr Epstein 2s alleged abuse of nors and particularly young women I responded on August th in writing that,5.7 if Mr Scaro5.7 a were to provide with a re detailed request I would try to provide any relevant non-privileged inform8.9 ation See Ex at SCAROLFA Scarola Correspondence August-Septem7.7 ber Mr Scarola wrote back to on August rd stating that have reason to believe that you have personally observed Jeffrey Epstein in the presenc of underage fe-6 m8 les and we would like the opportunity to question you under oath about those observations Id at SCAROLA I replied that you in fact have such testim8.3 ony it is perjurious I have never seen Epstein in the presence of an underage le Id.6 at SCAROLA Despite this unam7.5 biguous answer-11 Mr Edwards and Mr Scarola attem7.8 pted to subpoena me in his tim7.8 they left a subpoena with an10 assistant to another faculty mber at Harvard Law School proper form8.4 of service I again de it clear to them7.8 that I had no relevant non-privileged information to provide and that I had been instructed by client not to volunteer any inform7.7 ation There was no follow up by Mr Scarola and no attem8.8 pt to serve properly Case Document Filed Page no point did Mr Edwards Mr Scarol-6.5a any5.4 of their ass4.8o.4ciates tell that Ms Giuffre had accused of sexual ab5.4use because at that poin5.4t-2 she had no5.4t Had I been accused at that time I would provid5.3e3.9d records d5.3e3.9monstrating the falsity of any such Other Facts That Show that Ms Giuffre Lacks Credibility as Mr Cassell is inviting this Court to accept Virgin5.4ia Roberts Giuffre?s assertions about other exam8.2ples her lack of credib5.6ility6.4 are relevant the first Ms Giuffre has been dem7.9onstrated to up wildly im7.9plausible tales for financial gain for example Ms Giuffre was interviewed by Sharon Churcher at Daily Ma6.3il and provided detailed accounts of an alleged encounter with Bill Clinton on Jeffrey Epstein5.4?s4.8 private is9.6land in the Caribbean In exchange for that interview Ms Giuffre was paid Ms Giuffre?s account of m7.8e-6.1eting Clinto5.2n is both com8.2p.6letely unbeliev5.6able on its face and dem8.2onstrably For exam8.2ple she claims that Ghislaine Maxwell went to pick Bill Clinto5.5n in a huge black helico5.4pter that Jeffrey had bought her She?d always wanted to fly and Jeffrey paid for her to take lessons and I rem7.7e-6.2mber she was very excited because she got her license 5.7around the first year we I used to get frightened flying with her but Bill had the Secr9.1et Service with him7.9 and I rem7.9e-6.1mber him talking about what a good job she did Ex at Daily Mail Article March Ms Giuffre then described in detail a dinner with President 11.3Clinton Jeffrey Epstein and others on Little St Jam8e-1s Island which Mr Epstein ow7.8ned Furthe6.5r 6dem11.2onstrating 6her ability to weave a vi8.2vid yet utt7.4e-.3rly false tale 6Ms Gi7.4uffre also 6recounts that7.4 all dine6d toget7.7h-3.5er 6that night Jeffrey was at the 6head of ta ble Bill was at 6his left I sat across from10.7 him Tayler Ghislaine?s bl8onde B8.1r3.5itish assistant sat at right 7.3Ghislaine was 6at Bill?s left and at the left 6of 6Ghislaine there 6were two olive-ski8.1nne6.4d 6brune ttes who?d 5.3flown in with us New 6York Jeffrey thought they would entertain Bill but I saw 6no ce 6that he 6was int7.4e4.3rested them He and Jeffrey and Ghislaine seem10.6ed to have6.3 a 6very 6good relationshi8p Bill was 6ve6.4ry funny Ex 6at Case Document Filed Page of Giuffre entire accou5.5n.5t is fabricated out of whole clo5.5th Clinton was never on th5.4e island the relevant period A FOIA request subm8itted by FBI Directo5.3r Lo5.3uis Freeh for all shift lo5.3gs travel records itineraries reports and other records for US personnel travelling with form8er President Bill Clinton to Little St Jam8e-1s Island and the US Virgin Islands5 revealed that Bill Clin5.5ton did not in fact travel to nor was he present on Little St Jam8e-1s Island betw6.9een January and January See Dershowitz Decl Ex I Moreover the notion th-5.8at the Secret Service wo5.2uld allow a form7.8er presiden5.4t-.5 to be flown by an am8ateur pilot is ridiculous on its face that sam8e-1 Daily Mail article Ms Giuffre claim8ed that Mr Clinton5.4?-1.6s vice-president Al Gore and his wife Tipper were also guests of Epstein on his island on a different occasion Ex at Ms G7.6i-2.2uffre purported to provide specific details of this encounter I had no clue that anything was up The Gores seem7.9ed like a beautiful couple when I them7.8 All I knew was that Mr Gore was a friend of Jeffrey?s and Ghislaine?s Jeffrey didn?t ask me to give him a m7.9a-1.1ssage There have been a couple of other girls there on that trip but I could never have im7.9agined this 6.7guy would do anything wrong I was planning to vote for him7.9 I turned I thought he was awesom7.9e Id at story too was m8a-1de up a fiction peddled for m8oney By all available accounts Mr 9.4Gore and his wife never set foo6t on Mr Epstein?s private island nor even Mr Epstein Ms Giuffre lawyers who included David Boies could easily have ascertain5.4ed as m8u.4ch Vi-7ce Presid5.4ent Gore had been Mr Boies?s clien5.4t and Mr Boies could have sim7.8p.2ly asked him7.8 whether he had ever visi-7.6ted Mr Epstein?s island in the Caribbean Had he done so Mr Boies w7.6ould have learned th5.2at Ms Giuffre?s account was false Case Document Filed Page of 57.-4749.4Critically Ms Giuffre also lied abo5.6u.6t her ag5.6e?5.6specifically the age sh5.6e was during the tim7.9e period in which she was asso9.5ciated with Jeffrey Epstein Contrary to previous statem7.8ents that she was fifteen when she was traffick5.2ed by Mr E5.8pstein Ms Giuffre could not have even until th5.6e year sh5.6e tu5.6rned seven5.6t-1.8een There is5 docum8entary evidence recen5.4tly discovered and undisputed that Ms Giu5.4ffre father?who arranged her em8.2ploym8.2ent at The Mar-A-Lago Club in Palm8.2 Beach?did not begin w8o.6rking there until April Ms Giuffre has rep6.7eatedly stated that she first Ghislaine Maxwell at the Mar-A-L6.2ago where s5h.6e had a su5.6mmer job as a changing room8.1 assistant?indeed it is one of the few aspects of her story th7.2at has rem7.9a-1.1ined consistent from the outset Ms Giuffre turned seventeen in the sum8m8e-1r of By the tim8e Mr Epstein is alleged to have begun trafficking her to his acquaintances?six to nine m7.7onths after their first encoun5.5ter or in at least one telling two years later Ms Giuffre have been over eighteen issue of Ms Giuffre?s age at the tim13.4e of certain events is important as a legal m7.9a-1.1tter?and her lack of cred6.1ibility about it is telling The age of consent in New York is seventeen As to the other locations with vary6.9ing ages of consent?in Florida it is eighteen it is im8.1possible to know whether Giuffre is claim8.1ing to have been a because she has never specified?presum7.9a-.2bly even to her own lawyers when the alleged acts were supposed to have occurred She has not even provided the year in which she claim8.2s specific even5.6ts occurred So it cannot be presum8e-.3d?by her lawyers or by 10.1anyone else?that she was a m8i-2nor when she See 6for Zacha6.3r-2.5y Da6.3vies Bore6.3n Vir5.9g-3.2inia 6Who is the6.3 woman 6at the7.1 cent8.8re of Andrew sex allegations av6.9aila3.4ble at See for 6at Telephone Interview with Virgi7.5n-3.7ia 6Rober ts 6April See Princ6.1e.1 Andrew 6.5and the Girl His5.7 Sex6.1 6.5Offende6.1r Frie6.1nd Flew to Britain to 6.5Meet Him DailyMail.com10.1 Mar After 6about two years started to 6ask to entertain 6his 6friends Available at rticle-1361039/Pri7.5nce-An drew-girl-17-sex-o ffender-frien d-flew feeds-newsxm11.5l2.5 Case Document Filed Page of claim7.6s that Mr Epstein trafficked her It is m7.8u0ch m7.8ore likely in of when she actually Jeffrey Epstein and when she says she began to have sex with his acquaintances that she was not a she to have had sex with any such people Ms Giuffre has perjured herself by claim7.8ing that she was when she met Ms Max5.9w3.1ell and Mr Epstein notab5.9ly by subm8.7itting an untru5.9th5.9ful declaration in the Edwards lawsuit On Ms Giuffre executed an affidavit in which she alleged that In approxim7.8ately when I was years old I Ghislain6e M5.2a-1.2xwell S7.2oon after that I went to Epstein6?s in Beach on El Brillo Way From8.3 the first tim8.3e I was taken to Epstein?7.3s m8a-1nsion that day his m8o1.2tivations and actions were sexual as were Maxwell?s E5.7p-.1stein and Maxwell forced into sexual activ5.5ity with Epstein I was years old at the tim7.9e Ex at Declaration of Virginia Roberts January also asserted that w8h.8en she was approxim7.9a-1.1tely or years old when Mr Epstein and Ms Maxwell began trafficking her to 5.1Epstein5.7?s acquaintan5.7ces.5.7 These statem8.8ents are disp6roven6 by docum8.8entary ev6idence Conclusion his Declaration before this Court Paul Cassell has provided an accounting of the evid5.8ence th5.8at claim8.6s supports th5.3e truth of Virginia Roberts Giuffre?s accusations against It is 9a woefully in6adequate presenta10.3tion as the preceding paragraphs dem7.8onstrate The irony of course is that Mr Cassell?s accounting is in service to his and his client?s goal of keeping sealed far m7.8ore com7.8p0elling evidence?nam7.8e-1.2ly the Requested Docum7.9e-1.1nts?that undercuts the accusations against and shows them7.8 to be a recent Case Document Filed Page of fabrication This is part of an overarching plan by Ms Giuffre?s lawyers to cherry-pick the evidence they want to pu6.5blica6.5lly reveal while using this Court?s powers to suppress evidence dam7.9a-1.1ging to them7.9 There is a further irony as well which is that the entire basis of Ms Giuffre?s participation in the CVRA Action was a com8.1p.5laint that the Governm8.1ent unlawfully kept secret the details her alleged victim7.8ization at Mr Epstein?s hands Yet it is now Ms Giuffre and her lawyers who are seeking to keep9.9 secret the w7.7hole truth about Ms Giuffre?s story believe that the law and basic no9.6tion of fairness should perm8it to prove the w7.9hole truth nam8.1e-.9ly that Ms Giuffre never accused m8.1i-6.9sconduct until and that her belated com8.2p.6laint again5.6st me is as I always said a fabrication from8.2 start to finish The Requested Docum7.7e-1.3nts help prove those critical points Court ought not allow itself to be a tool of secrecy used by Ms Giuffre and her lawyers to ke7.9ep the whole truth from7.8 out As 6desc7.6ribe7.6d openi9.3ng 6Declaration le6.5gal assault on conducte6.5d t8.2h3rough he6.5r lawy9ers at Boies Schiller Flexne6.2r LLP 9.3BSF continue)6.2s in the form11.4 of a sanctions state 6court that I violat8.6ed a 6orde6.9r in the 6defam11.3a.6tion 6lawsuit 6by testifying trut8.3hfully in a deposition about discussi7.9ons that I had had 6with 6Davi8.1d Prior to my my lawyers submit-4.3ted an affida7.2vit to the Fl8.9ori8.9da 6descri8.9bing the7.2s.8e 6disc the Florid-4.3a sealed affi6.9davit He did 6not di8.3rect that re6.6frain 6testifying about m11.3a.6tter nor4.4 di8.9d 6he sa7.2nction for4.4 6disclosing the7.2 di8.9scussion an 6a7.4ffida7.4vit 6as7 6Ms Giuf4.6fr4.6e?s lawyers reques7ted 6whet9.3her4.8 a 6rul9.3ing 6on the7.6 BSF6.6 sanctions 6rega6.6rding the6.6 conte6.6n-2.9t of affida6.6vit Ly nch 6replied just sealing the6.6s.2e t8.3he a6.6f-2.2fidavit because I think they sealed.?6.7 6X at T21.7ra6.7ns6.2cript 6of 6Em11.4ergency Motion Seal 6Decem11.4ber Thus c6.7o3.2ntrary 6to the later 6for 6sanctions wa13s 6no order 6placed when the a6.7ffi8.4da6.7vit was subm10.8itted nor 6did 6I 6violate any court 6order by truthfully an sweri7.7ng a 6questi7.7o-3.5n put to by the opposing 6lawyer and of4.4feri8.9ng to seal8.9 answe7.2r BSF6.2 s6.8a1.2nctions 6was s6.5u3.4bseque6.9ntly dism11.6issed lack 6of4 jurisdiction standi8.5ng is now4.1 a6.8p3.3pealed 6by Case Document Filed Page of Case Document Filed Page Dated September New York New York a I a i i i i i i i I a I A I a I i I I A i A A a I 3C 3N 3i 3z 8J 8W 8e 8v b0 T1 I1 A1 a m2 P4 F4 A D6 DA DN Dm h6 X7 L8 C8 I I K2 LI LW Kh I I I I A I T7 TD TR Tc Tw I _1 VD KC CB A 2B k6 kE kV jj i QH HH AF 7G a zN yb yy NM GL 0O a MQ AS 4U FY a 1i 7q i a a a i i a a a a i i a I a I I I I A a I A A A A a I a i A A 2B 2N 2l A 8J 8X 8h P1 D2 A F5 FA FO F_ Fs X4 K5 A5 OJ OZ Nm S9 G9 Y6 YD YT Xg A fM ew a IB AA i v5 uF tY to FF 5F FK i 2U a i a i i i a I a I A a I A A A I A A i a A i I 2B 2O 2_ 2r 9K 8n i A J4 IB IQ Id J3 A TK St E7 A b4 aE A a pO oe i a 3E 8K 1U a i i I I I A i I a a I I I a I I I i a i 3C 3R 3e A D9 DH Cq A A O4 OC OU Nj I I A I m4 mF ju I A I 1D a I a i a i a a I I a A A i A i I a A I 6E 5W 5m A A
