Datasets:

robbd
/

epstein-index

+Trump
+A19 of 47
+Reference #
+Owned by:
+% Ownership
+100
+Name
+TRUMP INTERNATIONAL GOLF LINKS -
+DOONBEG
+Role
+Sole Member
+213 TIHC RESERVATIONS LLC (3)
+Owned by:
+% Ownership
+100
+Name
+DJT Holdings LLC
+Role
+Member
+214 TIHH MEMBER CORP (1)
+Owned by:
+Has ownership interest in:
+% Ownership
+100
+Entity Name
+Ownership
+TRUMP INTERNATIONAL HOTEL 1.00%
+HAWAII LLC
+Name
+The Donald J. Trump Revocable Trust
+Role
+Shareholder
+Title
+Managing Member
+215 TIHH MEMBER LLC (1)
+Owned by:
+⅚ Ownership
+100
+Name
+The Donald J....

extracted/summaries/house-oversight-nov/10/house-oversight-010691.txt ADDED Viewed

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+OGE Form 278c Afarch 2014)
+Instructions for Part 2
+Note: This is a public form. Trump
+Page Number
+A24 of 47
+Reference #
+99.9
+The Donald J. Trump Revocable Trust
+270 TRUMP DELMONICO LLC (1)
+Owned by:
+% Ownership
+100
+Name
+The Donald J. Trump Revocable Trust
+Has ownership interest in:
+Entity Name
+TRUMP PARK AVENUE LLC
+271 TRUMP DEVELOPMENT SERVICES LIC Y3)
+Owned by:
+% Ownershie
+Ownership
+50.00%
+Title
+Managing Member
+Name
+TRUMP DEVELOPMENT SERVICES
+MEMBER CORP
+DJT Holdings LLC
+272 TRUMP DEVELOPMENT...

extracted/summaries/house-oversight-nov/10/house-oversight-010699.txt ADDED Viewed

	@@ -0,0 +1,32 @@

+OGE Form 278e (March 2014)
+Instructions for Part 2
+Note: This is a public form. Trump
+Page Number
+A32 of 47
+Reference #
+100
+Has ownership interest in :
+Entity Name
+TRUMP MARKS PANAMALLC
+DTTM Operations Managing
+Member Corp
+Ownership
+1.00%
+Shareholder
+Title
+Managing Member
+363 TRUMP MARKS PANAMALLE
+Owned by:
+% Ownership
+Name
+TRUMP MARKS PANAMA CORP
+DTTM OPERATIONS LLC
+Role
+Managing Member
+Member
+364 TRUMP MARKS PHILADELPHIA CORP (3)
+Owned by:
+% Ownership
+100
+Name
+The Donald J. Trump Revocable...

extracted/summaries/house-oversight-nov/10/house-oversight-010701.txt ADDED Viewed

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+OGE Form 278c (Narch 2014)
+Instructions for Part 2
+Note: This is a public form. Do not include account numbers, street addresses, or family member names. Trump
+Page Number
+A34 of 47
+Reference #
+Has ownership interest in :
+Entity Name
+Ownership
+TRUMP MARKS SUNNY ISLES II LLC 1.00%
+Title
+Member
+385 TRUMP MARKS TAMPA CORP (3)
+Owned by:
+% Ownership
+100
+Has ownership interest in :
+Entity Name
+TRUMP MARKS TAMPA LLC
+Name
+DTTM Operations Managing
+Member Corp
+Ownership
+1.00%
+Role
+soareholde
+Member
+386...

extracted/summaries/house-oversight-nov/10/house-oversight-010702.txt ADDED Viewed

	@@ -0,0 +1,20 @@

+Form 278e (March 2014)
+Instructions for Part 2
+Note: This is a public form. Do not include account numbers, street addresses, or family member names. See instructions for required information. File's Name
+Donald J. Trump
+Page Number
+A35 of 47
+Reference #
+396 TRUMP MIAMI RESORT MANAGEMENT LLO
+Owned by:
+% Ownership
+Name
+TRUMP MIAMI RESORT
+MANAGEMENT MEMBER CORP
+99
+DJT Holdings LLC
+397 TRUMP MIAMI RESORT MANAGEMENT MEMBER CORP (1)
+Owned by:
+Ownershia
+i Holdines Managing Member LIC
+Has ownership...

extracted/summaries/house-oversight-nov/10/house-oversight-010703.txt ADDED Viewed

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+Form 278e (March 2014)
+Instructions for Part 2
+Note: This is a public form. Trump
+A36 of 47
+Shareholder
+100
+Has ownership interest in :
+Entity Name
+TRUMP OCEAN MANAGING
+MEMBER LLC
+408 TRUMP OLD POST OFFICE LLC
+Owned by:
+% Ownershie
+76.725
+22.275
+409 TRUMP OLD POST OFFICE MEMBER CORP (1)
+Owned by:
+% Ownership
+77.5
+22.5
+Has ownership Interest in:
+Entity Name
+TRUMP OLD POST OFFICE LLC
+411 TRUMP ORGANIZATION LLC (3)
+Assumed Names:
+Owned by:
+412 TRUMP PAGEANTS, INC. (1)
+Owned by:
+D/B/A
+The Trump...

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+Trump Revocable Trust
+Role
+Member
+Has ownership interest in:
+Entity Name
+TRUMP PARK AVENUE LLC
+Ownership
+49,90%
+420 TRUMP PARK AVENUE LLC
+Title
+Member
+Owned by:
+% Ownership
+0.1
+49.9
+Name
+GEPT Delmonico LLC
+TRUMP PARK AVENUE ACQUISITION
+ILC
+TRUMP DELMONICO LLC
+Role
+Member
+Member
+50
+123 TRUMP PAYROLL CHICAGO L 42)
+Owned by:
+% Ownership
+Managing Member
+Name
+401 North Wabash Venture LLC
+Role
+Managing Member
+422 TRUMP PAYROLL CORP (2)
+Owned by:
+% Ownership
+100
+423 TRUMP PHOENIX DEVELOPMENT LL...

extracted/summaries/house-oversight-nov/10/house-oversight-010705.txt ADDED Viewed

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+OGE Form 278e (March 2014)
+Instructions for Part 2
+Note: This is a public form. Do not include account numbers, street addresses, or family member names. See instructions for required information. File's Name
+Page Number
+Donald J. Trump
+A38 of 47
+Reference #
+432 TRUMP RUFFIN COMMERCIAL LLC (assets & income already disclosed on Part 2 under TRUMP RUFFIN TOWER I LLC; operator of front
+desk)
+Owned by:
+% Ownership
+100
+Name
+Role
+TRUMP RUFFIN TOWER I LLC
+Managing Member
+433 TRUMP RUFFIN LLC (1)
+Owned...

extracted/summaries/house-oversight-nov/10/house-oversight-010706.txt ADDED Viewed

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+Trump
+A39 of 47
+Reference #
+Owned by:
+% Ownership
+100
+Name
+DTTM Operations Managing
+Member Corp
+Ownership
+1.00%
+Role
+Shareholder
+Has ownership interest in:
+Entity Name
+TRUMP MARKS TORONTO LP
+444 TRUMP TOWER COMMERCIAL LLC
+Owned by:
+% Ownership. The Trump-Equitable Fifth Avenue
+Company
+Role
+Managing Member
+Member
+99
+445 TRUMP TOWER MANAGING MEMBER INC. Owned by:
+% Ownership
+Name
+100
+The Donald J. Trump Revocable Trust
+Has ownership interest in:
+Entity Name
+Ownership
+TRUMP TOWER COMMERCIAL LLC...

extracted/summaries/house-oversight-nov/10/house-oversight-010707.txt ADDED Viewed

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+OGE Form 278- (Narch 2014)
+Instructions for Part 2
+Reference #
+Has ownership interest in :
+Entity Name
+TRUMP VIRGINIA LOT 5 LLC
+Ownership
+1.00%
+454 TRUMP WINE MARKS LLC (3)
+Owned by:
+ Ownership
+99
+455 TRUMP WINE MARKS MEMBER CORP (3)
+Owned by:
+% Ownership
+100
+Has ownership interest in:
+Entity Name
+TRUMP WINE MARKS LLC
+456 TRUMP WORLD PRODUCTIONS LLC (4)
+Owned by:
+& Ownership
+Name
+TRUMP WINE MARKS MEMBER
+CORP
+DIT HOLDINGS LLC
+Name
+DTTM Operations Managing
+Member Corp
+Ownership
+1.00%
+Name
+TRUMP...

extracted/summaries/house-oversight-nov/10/house-oversight-010711.txt ADDED Viewed

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+OGE For 278e (March 2014)
+Instructions for Part 2
+Note: This is a public form. Do not include account numbers, street addresses, or family member names. See instructions for required information. File's Name
+Pagc Number
+Donald J. Trump
+A44 of 47
+Reference #
+DT LIDO GOLF MANAGER LLC
+1.00%
+Managing
+Member
+507 DT LIDO HOTEL MANAGER LC 4)
+Owned by:
+2 Ownership
+Name
+DT LIDO HOTEL MANAGER MEMBER
+CORP
+TITT VENTURE LLC
+508 T LIDO HOTEL MANAGER MEMBER CORP 4)
+Owned by:
+DJT Holdings Managing Member...

extracted/summaries/house-oversight-nov/10/house-oversight-010712.txt ADDED Viewed

	@@ -0,0 +1,28 @@

+OGE Form 278- (March 2014)
+Instructions for Part 2
+Note: This is a public form. Trump
+TA45 of 47
+Reference #
+Has ownership interest in :
+Entity Name
+DT TOWER I LLC
+Ownership
+1.00%
+Title
+Managing
+Member
+517 DT TOWER KOLKATALLC
+Owned by:
+4 Ownership
+99
+OTTOWER KOLKATA MANAGING
+MEMBER CORP
+DTTM OPERATIONS LLC
+518 DT TOWER KOLKATA MANAGING MEMBER CORP (1)
+Owned by:
+% Ownership
+Has ownership interest in :
+Entity Name
+DT TOWER KOLKATA LIC
+aM Operations Managing
+Member...

extracted/summaries/house-oversight-nov/10/house-oversight-010713.txt ADDED Viewed

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+Reference #
+OGE Form 278e (March 2014)
+Instructions for Part 2
+Note: This is a public form. Do not include account numbers, street addresses, or family member names. See instructions for required information. Trump
+Owned by:
+Page Number
+A46 of 47
+% ownership
+Name
+THC JEDDAH HOTEL MANAGER
+Role
+Managing Member
+MEMBER CORP
+99
+Trump, Donald J. Member
+528 THC JEDDAH HOTEL MANAGER MEMBER CORR "(4)-DISSOLED 115/18
+% Ownership
+Role
+Shareholder
+Has ownership interest in:
+Entity Name
+THC JEDDAH HOTEL...

extracted/summaries/house-oversight-nov/10/house-oversight-010714.txt ADDED Viewed

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+Reference #
+OGE Form 278c (March 2014)
+Instructions for Part 2
+Pors Main a public form. Do not include acount numbers stret adresses, or family member names. Trump
+A47 of 47
+100
+Shareholder
+DTTM Operations Managing
+Member Corp
+% Ownership
+100
+Name
+TITT VENTURE LLC
+Role
+Member
+540 4T HOLDINGS ONE LLC (3)
+Owned by :
+541 4T HOLDINGS TWO LLC (3)
+Owned by:
+542 STORAGE 106 LLC
+Owned by:
+543 T EXPRESS LLC (5)
+Owned by:
+% Ownership
+100
+MET VENTURE LIC
+Role
+Member
+% Ownership
+100
+Name
+The Donald J....

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+Russell
+and Spike Jones
+Peggy Siegal and
+Catherine Martin
+his was the year absolutely no one could predict Best
+•Picture for the 86th Academy Awards: not even me, the
+Oscar witch. This made directors Steve McQueen,
+Alfonso Cuaron and David O. After
+months of screenings, press conferences, lunches, and
+parties, publicists and bloggers had to look these three wise
+men in the eye and say, "We don't have a clue."
+Then came the slogan, "It's time." That was
+Samsung with the world's most famous...

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+True Detective collectively earned him Best
+Actor by December. No one will forget her
+Best Supporting Actress acceptance speech
+when she said, "It doesn't escape me for one
+moment that so much joy in my life is thanks
+to so much pain in someone else's."
+TUESDAY, FEBRUARY 25
+I flew to L.A. with some indefinable eye
+infection that made Olympics reporter Bob
+Costas' reaction to Botox look attractive. I managed to grope my way through Oscar
+week in couture Ralph Rucci gowns and furs
+and pretend...

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+Leonardi
+DiCaprio
+Sienna
+Miller
+Barry Diller
+and Diane von
+Furstenberg
+Portia de
+Rossi and Ellen
+DeGeneres
+Matthew
+McConaughey and
+Camila Alves
+Amy Adams and
+Darren Le Gallo
+Lady
+Gaga
+Bono
+Michael Fassbender
+up Chinatown producer Robert Evans. THURSDAY, FEBRUARY 27
+Oprah Winfrey slipped into Essence's "Black
+Women in Hollywood" lunch at the Beverly Hills
+Hotel where Cheryl Boone Isaacs, the first black
+female president of the Academy, was honored
+with a Trailblazer Award. President Bill...

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+Al Pacino and David Mamet were huddled on
+a couch as Spike Lee and Meredith Vieira sat
+nearby listening. At Warner Bros. fancy private dinner for its
+nominees at the Bel Air Hotel, Nicky and I were
+greeted by David Heyman. Executives Sue Kroll
+and Juli Goodwin brought us over to Sandra
+Bullock and CEO Kevin Tsujihara. Don't worry about Blue Jasmine
+fellow nominee Woody Allen; he was tap dancing
+with Susan Stroman on Broadway, rehearsing
+Bullets Over Broadway. The Wolf
+of Wall Street's Marty...

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+Harvey Weinstein and
+Georgina Chapman
+Naomi
+Watts
+Graydon Carter and
+Anna Scott Carter
+Andre Balazs
+Sandra Bullock
+Terry Richardson
+I never tire of the overwhelming
+excitement, throngs of eager press,
+and screaming fans. Philomena
+producers
+Gaby Tana and
+Tracey Seaward invited me to Steve Coogan's
+home where music man Alexandre Desplat
+and Jon Hamm were having beers. Past and present
+Oscar nominees and winners including
+Ben Affleck, Matt Damon, Oprah Winfrey,
+Charlize Theron, Sean Penn,...

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+This year, Cate Blanchett's husband theater
+impresario Andrew Upton bought me free
+drinks. I hung out with Cate, her CAA agent
+Hylda Queally, the adorable skinny Sally
+Hawkins in a heavily beaded Valentino gown,
+Julia Roberts, and Tom Bernard and Michael
+Barker who have 140 career nominations and
+32 wins. While I was at the Oscar broadcast, 160
+VIPs at Graydon Carter's annual Oscar
+viewing dinner were getting ready for the
+rush of a thousand more party guests. Those
+who watched the awards from...

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+Starr
+Kirkland & Ellis LLP
+777 South Figueroa Street
+Los Angeles, CA 90017-5800
+•950 F Street, NU
+Vashington, DC 20004-140
+May 19, 2008
+VIA FACSIMILE
+Honorable Mark Filip
+Office of the Deputy Attorney General
+United States Department of Justice
+950 Pennsylvania Avenue, N.W. Washington, D.C. 20530
+Dear Judge Filip:
+In his confirmation hearings last fall, Judge Mukasey admirably lifted up the finest
+traditions of the Department of Justice in assuring the United States Senate, and the...

extracted/summaries/house-oversight-nov/10/house-oversight-010724.txt ADDED Viewed

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+Honorable Mark Filip
+May 19, 2008
+Page 2
+By way of background, we were informed by Mr. Acosta that, at his request, CEOS
+would be conducting a review to determine whether federal prosecution was both appropriate
+and, in his words, "fair." That is not what occurred. Instead, CEOS has now acknowledged that
+we had raised "many compelling arguments" against the USAO's suggested "novel application"
+of federal law in this matter. Attorney "would not be abusing his prosecutorial discretion should he...

extracted/summaries/house-oversight-nov/10/house-oversight-010725.txt ADDED Viewed

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+Honorable Mark Filip
+May 19, 2008
+Page 3
+private practice in South Florida with personal relationships to some of the prosecutors involved. Federal prosecutors then leaked highly sensitive information about the case to a New York
+Times reporter.! The immediate result of this confluence of extraordinary circumstances is an
+onslaught of civil lawsuits, all save one brought by the First Assistant's former boutique law firm
+in Miami. The State Attorney's Office in Palm Beach County had conducted a...

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+Honorable Mark Filip
+May 19, 2008
+Page 4
+These statutes are intended to target crimes of a truly national and international scope:
+Specifically, § 1591 was enacted to combat human trafficking, § 2422 is aimed at sexual
+predation of minors through the Internet, and § 2423 deals with sex tourism. There
+have likewise been no cases under § 2422(b)—a crime of communication-where there was no
+use of the Internet, and where the content of phone communications did not contain any inducing
+or enticing...

extracted/summaries/house-oversight-nov/10/house-oversight-010727.txt ADDED Viewed

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+Honorable Mark Filip
+May 19, 2008
+Page 5
+In fact, recent testimony of several alleged "victims" contradicts claims made by federal
+prosecutors during the negotiations of a deferred prosecution agreement. The consistent
+representations of key Government witnesses (such as
+,and
+) confirm the following critical points: First, there was no
+communication, telephonic or otherwise, that meets the requirements of § 2422(b). Epstein never emailed, text-messaged, or used any facility of
+interstate...

extracted/summaries/house-oversight-nov/10/house-oversight-010728.txt ADDED Viewed

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+Honorable Mark Filip
+May 19, 2008
+Page 6
+• Federal prosecutors made the unprecedented demand that Mr. Even then, though demanding payment to the women, the
+USAO eventually asserted that it could not vouch for the veracity of any of the
+claims that these women might make.
+• Federal prosecutors made the highly unusual demand that Mr. Epstein pay the fees
+of a civil attorney chosen by the prosecutors to represent these alleged "victims"
+should they choose to bring any civil litigation against him....

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	@@ -0,0 +1,9 @@

+Honorable Mark Filip
+May 19, 2008
+Page 7
+Government's confidential "list of victims." Most of these lawsuits seek $50
+million in money damages. 4
+• Assistant U.S. Attorney David Weinstein spoke about the case in great detail to
+Landon Thomas, a reporter with the New York Times, and revealed confidential
+information about the Government's allegations against Mr. Attorney also revealed the substance of confidential plea negotiations.
+• When counsel for Mr. Epstein complained about the media...

extracted/summaries/house-oversight-nov/10/house-oversight-010730.txt ADDED Viewed

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+Honorable Mark Filip
+May 19, 2008
+Page 8
+prosecution is fair and appropriate has been placed, once again, in U.S. In light of the foregoing, we respectfully ask that you review this matter and discontinue
+all federal involvement so that the State can appropriately bring this matter to closure. Such a meeting would provide the Department with an opportunity to review the paramount
+issues of federalism and the appearance of selectivity that are generated by the unprecedented
+attempts to broaden...

extracted/summaries/house-oversight-nov/10/house-oversight-010731.txt ADDED Viewed

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+05/19/08 MON 13:26 FAX 1 213 680 8500
+KIRKLAND&ELLIS LLP
+TX REPORT
+4001
+TRANSMISSION OK
+TX/RX NO
+CONNECTION TEL
+SUBADDRESS
+CONNECTION ID
+ST. RESULT
+1855
+05/19 13:21
+04'56
+g
+OK
+KIRKLAND & ELLIS LLP
+Fax Transmittal
+777 South Figueroa Street
+Los Angeles, California 90017
+Please notify us immediately if any pages are not received. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR,
+PLEASE NOTIFY US IMMEDIATELY AT:
+(213) 680-8400. To:
+Honorable Mark Filip
+From:
+Kenneth W....

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+Starr
+Kirkland & Ellis LLP
+777 South Figueroa Street
+Los Angeles, CA 90017-5800
+Joe D. Whitley
+Alston & Bird LLP
+The Atlantic Building
+950 F Street, NW
+Washington, DC 20004-1404
+May 27, 2008
+VIA FACSIMILE
+Honorable Mark Filip
+Office of the Deputy Attorney General
+United States Department of Justice
+950 Pennsylvania Avenue, N. Washington, D.C. 20530
+Dear Judge Filip:
+This letter briefly supplements our prior submission to you dated May 19, 2008. The dual reasons for our request that
+you review...

extracted/summaries/house-oversight-nov/10/house-oversight-010733.txt ADDED Viewed

	@@ -0,0 +1,7 @@

+Honorable Mark Filip
+May 27, 2008
+Page 2
+to a charge that the State Attorney has not, despite a two year investigation, determined to be
+appropriate. Epstein's counsel must also successfully expedite a plea of guilty to this charge
+on a date prior to July 8, 2008, which is the date presently set by the state court Judge. Further, the unnecessary deadline is even more problematic because Mr. Epstein's effort
+to reconcile the state charge and sentence with the terms of the Agreement requires an...

extracted/summaries/house-oversight-nov/10/house-oversight-010734.txt ADDED Viewed

	@@ -0,0 +1,36 @@

+05/27/2008 12:18 FAX
+L 001
+TX REPORT
+TRANSMISSION OK
+TX/RX NO
+RECIPIENT ADDRESS
+DESTINATION ID
+ST. TIME
+TIME USE
+PAGES SENT
+RESULT
+0439
+05/27 12:18
+00'34
+3
+OK
+KIRKLAND & ELLIS LLP
+Fax Transmittal
+777 South Figueroa Street
+Los Angeles. California 90017
+Please notify us immediately if any pages are not received. To:
+Honorable Mark Filip
+From:
+Kenneth W. Starr
+Message:
+Company:
+Office of the Deputy Attorney Gencral
+United States Doparument of Justice
+Date:
+Pages w/cover:
+May 27.2008
+3
+Fax...

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+Case 9:08-Cv-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 1 of 19
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-CIV-MARRA/JOHNSON
+JANE DOE #1 AND JANE DOE #2,
+Plaintiffs,
+VS. Dershowitz hereby replies in support of his Motion for Limited Intervention (DE
+282). In its response (DE 290), the government compellingly set
+forth the many
+reasons why Jane Does #3 and #4's request, filed over 6 years after the
+commencement of the CVRA case, should be...

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+Case 9:08-Cv-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 2 of 19
+joinder of Jane Doe 3 and her untimely allegations to the underlying CVRA case. If the Court
+rejects the pending motion for joinder (DE 279), then the Court should strike the scurrilous
+allegations against Dershowitz, or, alternatively, determine the possible mootness of his Motion
+for Limited Intervention. Of course, if the Court strikes the allegations against him sua sponte,
+Prof. However, if the Court...

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	@@ -0,0 +1,5 @@

+Case 9:08-Cv-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 3 of 19
+At bottom, Jane Doe #3's Response is nothing but a paper-thin pastiche of conspiracy
+theory and outright misrepresentation that crumbles upon examination. Invocations of the Fifth
+Amendment by nonparty witnesses in response to innocuous questions about Prof. Dershowitz, as Epstein's former legal counsel, is one of hundreds of people listed in an address
+book purloined by Jeffrey Epstein's criminal butler; yet...

extracted/summaries/house-oversight-nov/10/house-oversight-010738.txt ADDED Viewed

	@@ -0,0 +1,5 @@

+Case 9:08-Cv-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 4 of 19
+I. Jane Doe #3's Continued Smears of Prof. Dershowitz
+Demonstrate His Need to Intervene
+Jane Doe #3 and her counsel's actions over the past month have confirmed that Prof. What has become further
+apparent is that if Jane Doe #3's Motion for Joinder is granted and Prof. While Jane Doe #3 asks to "prove" her allegations against Prof.

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+Case 9:08-Cv-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 5 of 19
+In an effort to cite contrary law to the Court, Jane Doe #3's Response takes remarkable
+liberties in describing what is claimed to be the law to Court. For example, the Response quotes
+Calloway v. Jane Doe #3's Lies About Prof. Dershowitz
+Are Wholly Irrelevant to This Action
+Meanwhile, Jane Doe #3 fails to come up with a single credible reason for naming Prof. Yet,
+in her Joinder Motion, she states that "[t]he...

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+Case 9:08-Cv-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 6 of 19
+Second, Jane Doe #3 claims that she needed to defame Prof. Dershowitz and others in the
+Joinder Motion because of discovery disputes between the government and Jane Doe #1 and Jane
+Doe #2. Jane Doe #3's right to join in this
+case has nothing to do with Jane Doe #1 and Jane Doe #2's entitlement to documents in
+discovery. In fact, the discovery requests that Jane Doe #3 cites to in her Response as purported
+cover...

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+Case 9:08-Cv-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 7 of 19
+into the NPA entered into between the government and Mr. The inclusion of certain provisions in the agreement simply
+has nothing to do with whether the government complied with its obligations under the Crime
+Victims' Rights Act ("CVRA"). Moreover, because the
+first time Jane Doe #3 made these contemptible allegations against Prof. Dershowitz was in her
+Motion for Joinder in December 2014, those allegations are...

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+Case 9:08-Cv-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 8 of 19
+Moreover, if the government had any reason to believe that Prof. Fourth, Jane Doe #3 then makes the facially absurd and libelous claim that somehow
+Prof. Dershowitz's Supplement
+to his Motion for Limited Intervention, this "co-conspirator" provision "was intended to apply to
+four alleged co-conspirators, who were named in the original NPA and later redacted at their
+request..... Alan Dershowitz was never alleged...

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+Case 9:08-Cv-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 9 of 19
+Fifth, Jane Doe #3 claims that she needed to include Prof. Dershowitz in her filing
+because her CVRA claim of "unfair" treatment "implicates a fact-sensitive equitable defense
+which must be considered in the factual context of the entire interface between Epstein, the
+relevant prosecutorial authorities and the federal offense victims." The "facts" to which this
+"defense" is sensitive, even if Jane Doe #3 is...

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+Case 9:08-cV-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 10 of 19
+detail about her fictional meeting with former President Clinton, providing an elaborate
+description about how Mr. Clinton and his secret service detail somehow allowed Ghislaine
+Maxwell, then a novice helicopter pilot, to fly all of them to Jeffrey's Epstein's private island on
+Epstein's black helicopter, as well as details about the specific place at the dinner table at which
+she and Mr. Jane Doe #3 also gave...

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+Case 9:08-cV-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 11 of 19
+that evidence will show that former president Clinton, former vice president Al Gore, and Tipper
+Gore never set foot on Epstein's private island, and that in all events Jane Doe #3's detailed
+accounts are not merely preposterous on their face but in fact entirely false and her sworn
+statement to this court is perjurious. Indeed, while the points raised above show a complete lack of investigation into...

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+Case 9:08-cV-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 12 of 19
+IN. Dershowitz Immediately Responded to Jane Doe #3's Allegations
+Against Him by Asking to Defend his Reputation
+Jane Doe #3 also argues that Prof. It is without question that the Motion for Joinder filed by Jane Doe #3 on
+December 30, 2014 (DE 279) was the first time anyone has ever alleged that Prof. Dershowitz has had to defend his reputation related to "his involvement in Epstein's offenses."
+In fact, just...

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+Case 9:08-cV-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 13 of 19
+Q. And did you have any knowledge of why [Dershowitz] was visiting there? And do you have any idea whether or not Mr. Dershowitz was also receiving
+massages? As to whether any of those women were ever associated with Mr.

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+Case 9:08-cV-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 14 of 19
+"Alessi Depo. Tr.") Alessi testified that he saw "many celebrities" at the house... [including] a
+very famous lawyer[] that I'm sure you know, Alan Dershowitz, who spend [sic] at the house a
+couple times." (Alessi Depo. Tr. 70, 71.) However, Alessi made no allegations of improprieties
+against any of these individuals. Jane Doe #3 asks the Court to infer that because Prof. Dershowitz visited Epstein's home...

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+Case 9:08-cV-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 15 of 19
+Next, Jane Doe #3 claims that Prof. Epstein lawsuit (Case no. 502009-CA-040800) in Palm Beach County Circuit Court.
+(Opp. to Mtn. to Intervene at 13.) In support of this allegation, Jane Doe #3 argues that her
+attorney in the instant matter, Bradley Edwards (through his attorney Jack Scarola) contacted
+Prof. Dershowitz's client, Jeffrey Epstein's conduct. Dershowitz responded by letter stating
+As you may know, I...

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+Case 9:08-cV-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 16 of 19
+adversaries, Jane Doe #3 argues that Prof. In fact, just six
+days after Jane Doe #3 filed her Motion for Joinder, which included vicious allegations against
+him, Prof. Dershowitz filed his Motion for Limited Intervention. (DE 282.) Accordingly, Prof. Jane Doe #3's Reliance on Other's Invocation of the
+Fifth Amendment is Improper and Wholly Unpersuasive
+Without a shred of physical evidence or witness...

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+Case 9:08-cV-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 17 of 19
+where inference is "trustworthy under all of the circumstances" including relationship, shared
+interest and control); Kontos v. Kontos, 968 F.Supp. 400, 407-408 (1997) (no adverse inference
+allowed from invocation of Fifth Amendment by sister of civil defendant in absence of "identity
+of interests'); Sebastian v. Similarly, any other witnesses taking the Fifth Amendment and remaining silent to
+protect themselves...

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+Case 9:08-cV-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 18 of 19
+Benjamin H. Bar No. 73748
+bbrodsky@coffeyburlington.com
+COFFEY BURLINGTON, P.L.
+2601 South Bayshore Drive, PH1
+Miami, Florida 33133
+Telephone: (305) 858-2900
+Facsimile: (305) 858-5261
+-
+and -
+Thomas Scott, Fla. Bar No. 149100
+thomas.scott@,csklegal.com
+COLE, SCOTT & KISSANE, P.A. Dadeland Centre II
+9150 South Dadeland Boulevard, Suite 1400
+Miami, Florida 33156
+Telephone:
+(305) 350-5300
+Facsimile:
+(305)...