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Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 10 of 32
FACTUAL AND PROCEDURAL BACKGROUND
I. MS. GIUFFRE’S ALLEGED RELATIONSHIP WITH JEFFREY EPSTEIN AND
BELATED ACCUSATIONS AGAINST PROFESSOR DERSHOWITZ
In 2006, Professor Dershowitz was retained by financier Jeffrey Epstein to join a team of
lawyers hired to defend Epstein against accusations that he had solicited sex workers and had
inappropriate sexual encounters with underage girls.! Declaration of Alan M. Dershowitz
(‘Dershowitz Decl.”) {| 6-7. In 2008, Epstein pleaded guilty to certain offenses involving sex
with minors. Jd. § 7. Ms. Giuffre has alleged that she was one of Epstein’s victims, although
Epstein was neither charged nor convicted of any conduct toward her. Jd. 8. Ms. Giuffre
claims that she was held as a “sex slave” and trafficked by Epstein, who she alleges facilitated
sexual encounters with a number of men. Jd.
In the period from 2006 through 2014, Ms. Giuffre submitted to interviews with law
enforcement, told her story to the media, drafted a tell-all memoir, and filed a lawsuit alleging
that Mr. Epstein had trafficked her to many of his prominent associates. Jd. | 10-14. During
this period, Ms. Giuffre never once claimed to have had any sexual contact with Professor
Dershowitz, much less that he had sexually abused her. /d. Then, in December 2014, Ms.
Giuffre—tepresented by attorneys Bradley Edwards and Paul Cassell—filed a motion to join an
action (the “CVRA Action’) that had been initially filed in the United States District Court for
the Southern District of Florida in 2008 by another of Mr. Epstein’s alleged victims, who was
designated as “Jane Doe.” Jane Doe #1 v. United States of America, No. 08 Civ. 80736 (S.D.
Fla.) (hereinafter, Doe v. USA); Dershowitz Decl. § 16. In late 2014 and early 2015, Ms.
Giuffre’s lawyers alleged in public court filings in the CVRA Action that Mr. Dershowitz had
had sex with Ms. Giuffre on numerous occasions while she was a minor, including in Florida, on
' Professor Dershowitz had been acquainted with Mr. Epstein through academic events for a number of years prior
to his retention as Mr. Epstein’s counsel, but had neither witnessed nor heard about allegations of sexual misconduct
by Mr. Epstein before being hired to represent him. Dershowitz Decl. 6.
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| Filename | Giuffre_Maxwell_Batch4_p00139.png |
| File Size | 340.4 KB |
| OCR Confidence | 94.0% |
| Has Readable Text | Yes |
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| Indexed | 2026-02-04 12:41:01.136874 |