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Case 18-2868, Document 281, 08/09/2019, 2628234, Page4 of 66 Giuffre gratuitously included provocative and “lurid details” of her alleged sexual activities as an alleged victim of sexual trafficking. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre denies that the issues presented in here joinder motion were narrow. The issues presented by the joinder motion and related pleadings were multiple and complex, requiring numerous details about Ms. Giuffre’s sexual abuse and the perpetrators of her abuse. In a pleading explaining why the motion was filed, Ms. Giuffre’s lawyers sp ecifically listed nine separate reasons why Jane Doe 3’s allegations that Dershowitz had sexually abused her were relevant to the case and appropriately included in the relevant filings: 1. To establish that Jane Doe 3 had been sexually abused by Jeffrey Epstein and his co-conspirators (including co-conspirator Alan Dershowitz), which would make her a “victim” of a broad sex trafficking conspiracy covered by the federal Crime Victims’ Rights Act, 18 U.S.C. § 3771, and therefore entitled to participate in the case; 2. To support then-pending discovery requests that asked specifically for information related to contacts by Dershowitz with the Government on behalf of Jeffrey Epstein; 3. To support the victims’ allegation that the Government had a motive for failing to afford victims with their rights in the criminal process — specifically, pressure from Dershowitz and other members of Epstein’s legal defense team to keep the parameters of the non-prosecution agreement (NPA) secret to prevent Jane Doe 3 and other victims from objecting to and blocking judicial approval of the agreement; 4. To establish the breadth of the NPA’s provision extending immunity to “any potential co-conspirators of Epstein” and the scope of the remedy that the victims (including not only Jane Doe 3 but also other similarly-situated minor victims who had been sexually abused by Dershowitz) might be able to obtain for violations of their rights; 5. To provide part of the factual context for the scope of the “interface” between the victims, the Government, and Epstein’s defense team — an interface that was relevant under Judge Marra’s previous ruling that the Government was entitled to raise “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 . . .”;