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Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 8 of 31 Il. FACTUAL AND PROCEDURAL BACKGROUND A. Abundant Evidence Supports Ms. Giuffre’s Sworn Testimony That Alan Dershowitz Sexually Abused Her Dershowitz says he needs to see several documents because they will somehow “demonstrate that the allegations of sexual misconduct . . . are nothing more than a recent fabrication ... .” DE 364 at 2. To the contrary, they will in no way prove the allegations are a “fabrication,” given the mountain of evidence supporting Ms. Giuffre’s sworn testimony. Ms. Giuffre has not made vague assertions, but described in detail what Dershowitz did to her and where.’ In response to Ms. Giuffre’s sworn testimony, Dershowitz does not argue that any witnesses will be able to prove his innocence. Instead, he tries to build a circumstantial case that he could not have committed the sexual abuse. Dershowitz now claims, for example, that at the time of the abuse, he was merely “acquainted with Mr. Epstein through academic events . . ..” DE 364 at 4.* But in 2005 (before news of Epstein’s criminal prosecution broke), Dershowitz stated “I’m on my 20th book ... The only person outside of my immediate family that I send drafts to is J effrey.”” Dershowitz has also been quoted as saying that, even if Epstein went bankrupt, “I would be as interested in him as a friend if we had hamburgers on the boardwalk in Coney Island and talked about his ideas.”° Dershowitz also claims that he never saw “Epstein in the presence of underage girls.” DE 364 at 3.’ This lack of observation is remarkable given that Epstein brazenly and repeatedly * Id. at 88-91, McCawley Dec at Exhibit 4, describing Dershowitz’s abuse of her in Epstein’s New York mansion. * In earlier media statements, Dershowitz took an even more extreme position, stating that “I have never been alone with . . . Jeffrey Epstein.” UMAR News, Jan. 5, 2015. https://www.youtube.com/watch?v=K XzexsiQv7Q. And yet (among other occasions), a flight log shows Epstein and Dershowitz traveling together—alone. > The Talented Mr. Epstein, by Vicky Ward, in Vanity Fair (Jan. 2005). ° Vanity Fair Reminds Us When Jeffrey Epstein Wasn’t a Creep, by Ray Gustini, in The Wire (June 21, 2011). 7 While Dershowitz swore under oath that he never saw any naked photos at Epstein’s Palm Beach mansion, the recently released video taken by the Palm Beach Police department during its investigation, reveals naked photos in a number of the common areas of Epstein’s Palm Beach home. McCawley Dec. at Exhibit 5. 3