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e Mr. Dershowitz agrees to make his client, Jeffrey Epstein, and others with relevant testimony and with whom he has testified he shares a “common interest” — at least Epstein and Maxwell — available to any law enforcement agency reviewing any alleged criminal activities; or in the alternative, to attest to this Court that those necessary witnesses have consented to full cooperation in the investigation Mr. Dershowitz is seeking permission to initiate. e Mr. Dershowitz agrees to waive the statute of limitations in all jurisdictions for any criminal conduct he participated in or was aware of relating to Ms. Giuffre so that law enforcement can pursue any necessary charges. Defendant Dershowitz proclaimed that he was willing to waive any statute of limitation for criminal conduct so this should not be an issue. See Exhibit D, January 12, 2016 Deposition Transcript of Alan Dershowitz at 395. “T had talked about the statute of limitations for criminal purpose was what I said, that I would waive the statute of limitations for criminal purposes.” e Mr. Dershowitz agrees to provide the names and contact information for each State Attorney and United States Attorney for which he has or is planning to provide information relating to Ms. Giuffre; and agrees to jointly, with Ms. Giuffre’s counsel, request that the State Attorney and United States Attorney, in the relevant jurisdictions, investigate all potential criminal conduct. Both parties may provide any relevant information they have that may assist the authorities with their investigation. e For all other purposes non-party Ms. Giuffre’s January 16, 2016 deposition transcript shall remain confidential and sealed other than for confidential disclosure to law enforcement as described above. 2. Mr. Dershowitz Has No “Evidence” of Perjury And Instead Is Simply Trying To Bully This Victim As explained above, Defendant Dershowitz wrongly suggests to this Court that non-party Virginia Giuffre has committed perjury in an effort to taint the Court against this victim. His only “evidence” of this alleged perjury is a self-serving opinion from his retained expert that an “absence of records” in response to a FOJA request, establishes that former President Clinton was never on Jeffrey Epstein’s island in the USVI. Defendant Dershowitz misrepresents the government’s response. The government is only required to conduct a reasonable search of readily accessible records. Accordingly, an “absence of records” response does not mean that records do not exist. It simply means that in the course of the search, no records were found. See Cunningham v. U.S. Dept. of Justice, 961 F.Supp. 2d 226, 236 (D.C. 2013) (court reasoning that “t]he adequacy of a search is measured by a standard of reasonableness... The question is not 3 HOUSE_OVERSIGHT_015652