Giuffre_Maxwell_Batch1_p00457.png
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Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 10 of 40
On December 30, 2014, Cassell and Edwards filed a Motion Pursuant to Rule 21 for
Joinder in the Action on behalf two additional victims: Jane Doe 3 and Jane Doe 4. (Jane Doe 3,
Virginia Giuffre, subsequently decided to reveal her name). The joinder motion argued that Jane
Does 3 and 4 should be allowed to join the two existing plaintiffs in the action because they had
suffered the same violations of their rights under the CVRA. McCawley Decl., Exhibit 2, Jane
Does’ 3 and 4 Joinder Motion.” To establish that they were “victims” of Epstein’s sex crimes
with standing to join the suit, Jane Does 3 and 4 alleged that they had suffered sexual abuse from
Epstein. For example, Jane Doe 3 alleged that she had been forced by Epstein to have sexual
relations with various persons, including Alan Dershowitz — who had been one of Epstein’s
defense attorneys negotiating the non-prosecution deal and arranging to keep it secret from the
victims. McCawley Decl., Exhibit 2 at 4. Jane Doe 3 also alleged that Defendant (i.e., Ghislaine
Maxwell) had participated in the sexual abuse of Jane Doe 3. Id. at 4-5.
After Dershowitz also filed a motion to intervene to contest the allegations (DE 282),
Jane Doe 3 filed a response to Dershowitz’s intervention motion. McCawley Decl., Exhibit 3,
Response to Motion to Intervene.* The response explained that the allegations against
Dershowitz were relevant to at least eight separate issues in the CVRA case. Jd. at 18-26. The
response also explained some of the evidence supporting the allegations against Dershowitz,
including:
e sworn testimony from one of Epstein’s household employees (Juan Alessi) that
Dershowitz came “pretty often” to Epstein’s Florida mansion and got massages
while he was there;
> The Joinder Motion attached as an exhibit is a “corrected” motion, filed on January 2, 2015. As discussed below,
several paragraphs in this motion were later stricken by Judge Marra.
> This document is currently restricted/under seal in the CVRA case, although an order sealing it is not found in the
Court record so far as can be determined. In light of the sealing of the document, we have marked aspects of this
pleading dealing with the document as confidential.
Extracted Information
Document Details
| Filename | Giuffre_Maxwell_Batch1_p00457.png |
| File Size | 317.3 KB |
| OCR Confidence | 94.9% |
| Has Readable Text | Yes |
| Text Length | 2,286 characters |
| Indexed | 2026-02-04 12:34:04.624685 |