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Extracted Text (OCR)
her as a “victim” of federal sex offenses. Unsurprisingly, her deposition contains highly sensitive
information about her experiences as a minor child, including detail descriptions of sexual crimes
committed against her.
ARGUMENT
1. Non-Party Virginia Giuffre Agrees That Her Deposition Should Be Provided
Confidentially To Law Enforcement to Investigate All The Crimes Committed
Against Her
Defendant Dershowitz seeks to have the Court grant an exception to the confidential nature
of the deposition so that it can be provided to the Office of the State Attorney and the Office of the
United States Attorney for investigative purposes. Specifically, Defendant Dershowitz states in
his motion that he is hoping to have law enforcement investigate whether Ms. Giuffre committed
perjury by stating in her previously filed affidavit that it is her recollection that she witnessed
former President Bill Clinton on Jeffrey Epstein’s island in the United States Virgin Islands
(“USVI’)'.
Setting aside Defendant Dershowitz’s baseless claims of perjury, Ms. Giuffre agrees that
her confidential deposition should be provided to law enforcement, including the United States
Attorney and the State Attorney in each jurisdiction where any alleged crimes occurred so that
they may investigate all of the crimes committed against her when she was a minor child. To
ensure that justice is served and that Defendant Dershowitz’s request is not just another charade
designed only to bully a sexual abuse victim, Ms. Giuffre asks the Court to impose the following
reasonable conditions relating to the disclosure:
e Mr. Dershowitz agrees and is directed to cooperate with authorities and answer all
questions relating to the investigation of crimes against Ms. Giuffre.
' Defendant Dershowitz conveniently ignores that publicly available flight logs of Jeffrey Epstein’s private
planes demonstrate that President Clinton travelled with Jeffrey Epstein and others to various locations
throughout the world including Europe, Africa and Asia. See Exhibit C, Excerpts of Flight Logs from
Jeffrey Epstein’s private plane.
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