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EXHIBIT A 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
VIRGINIA GIUFFRE, 
Plaintiff, 
v. 
ALAN DERSHOWITZ, 
Defendant. 
ALAN DERSHOWITZ, 
Counterclaim Plaintiff, 
v. 
VIRGINIA L. GIUFFRE, 
Counterclaim Defendant. 
Civil Action No. I :19-cv-3377 (LAP) 
AMENDED COMPLAINT 
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Plaintiff, 
formerly known as 'for 
her 
Complaint against Defendant, Alan Dershowitz, avers upon personal knowledge as to her own 
acts and status and upon information and belief and to all other matters: 
NATURE OF THE ACTION 
1. 
This suit arises out of Defendant's sexual abuse of Plaintiff, his defamatory 
statements of and concerning Plaintiff, and his unlawful interception of Plaintiff's 
communications. 
2. 
During 2000-2002, beginning when Plaintiff was 16, Plaintiff was the victim of 
sex trafficking and abuse by convicted sex offender Jeffrey Epstein. 
3. 
Epstein's trafficking scheme involved recruiting young girls, often by claiming 
they would be paid $200 for simply providing a massage to a wealthy billionaire. The young girl 
would then be brought up to Epstein's bedroom where Epstein would be on a massage table; 
Epstein would then sexually abuse the girl. This same pattern was repeated numerous times with 
numerous children. 
4. 
"From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 
30 minor girls . . . at his mansion in Palm Beach, Florida, and elsewhere in the United States and 
overseas.... In addition to his own sexual abuse of the victims, Epstein directed other persons to 
abuse the girls sexually. Epstein used paid employees to find and bring minor girls to him. 
Epstein worked in concert with others to obtain minors not only for his own sexual gratification, 
but also for the sexual gratification of others." Opinion and Order, Doc. No. 435 at 1-2, Jane 
Doe 1 and Jane Doe 2 v. United States, Case No. 9:08-cv-80736 (S.D. Fla. Feb. 21,2019) 
("Order") (internal citations omitted). One of the persons with whom Epstein acted in concert 
was Defendant. 
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5. 
Like other minor children who came before and after her, Plaintiff was initially 
recruited to provide massages, and thereafter to engage in a variety of sexual acts, for Epstein. 
Plaintiff was required to be on call for Epstein for sexual purposes and frequently traveled with 
him both nationally and internationally. Plaintiff was regularly abused by Epstein and was lent 
out by Epstein to others for sexual purposes. 
6. 
Defendant was Epstein's lawyer, close friend, and co-conspirator. Defendant was 
also a participant in sex trafficking, including as one of the men to whom Epstein lent out 
Plaintiff for sex. Between 2000 and 2002, Defendant sexually abused Plaintiff on numerous 
occasions, including at least once in New York. 
7. 
When Epstein was arrested for sex trafficking in 2006, Defendant defended his 
friend and client by falsely attacking the truthfulness of his accusers, including calling the 
children whom Epstein had abused (and, in the case of Plaintiff, whom the Defendant himself 
had also abused) liars and prostitutes. 
8. 
Despite his significant criminal activity, Epstein's criminal charges were resolved 
by a guilty plea to a single Florida state law charge and a non-prosecution agreement ("NPA") 
with the U.S. Attorney for the Southern District of Florida. Unknown to the public and the 
victims at the time, Epstein's lawyers, including Defendant, were pressuring the Government to 
commit to the NPA without informing the victims. Epstein's multiple victims, including 
Plaintiff, were kept in the dark and many victims were told to be "patient" while Defendant 
participated in the drafting of the NPA and worked to protect Epstein and other "potential co-
conspirators" (including himself) from prosecution. 
9. 
On July 7, 2008, a challenge to the NPA was brought on behalf of two of 
Epstein's victims (not including Plaintiff) based on the fact that, contrary to the requirements of 
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the Crime Victims' Rights Act (the "CVRA"), the NPA had been concealed from Epstein's 
victims. 
10. 
In December 2014, Plaintiff, who had not initially been part of the CVRA action, 
was asked to, and did, provide information to plaintiffs' lawyers in the CVRA case in which she 
discussed her sex trafficking by Epstein. On December 31, 2014, Plaintiff's lawyers in the 
CVRA proceeding (Brad Edwards and Paul Cassell) filed a Motion Pursuant to Rule 21 for 
Joinder in the Action ("Joinder Motion") on behalf of Plaintiff. Plaintiff's joinder motion 
described how she had been sexually trafficked by Jeffrey Epstein and was forced to have sex 
with, among others, Defendant. 
11. 
Based on Plaintiff's December 2014 filing, Defendant, as he had previously done 
to Epstein's victims, publicly and viciously attacked Plaintiff's lawyers in the CVRA actions, 
Brad Edwards and Paul Cassell. Defendant, in nationally televised news interviews, wrongfully 
claimed that Edwards and Cassell had engaged in unethical behavior warranting disbarment for 
filing the Joinder Motion that described Defendant's involvement with Epstein and Plaintiff. 
Edwards, who is a prominent lawyer for sexually abused women and children, and Cassell, who 
is a former United States District Court judge who left the bench to advocate for criminal 
victims, sued Defendant for defamation. Edwards and Cassell asserted that the factual allegations 
that Defendant had knowledge of and participated in Epstein's criminal conduct were entirely 
proper and well founded and that Defendant's statements about Edwards and Cassell were 
defamatory. 
12. 
In April 2016, Defendant settled the Edwards and Cassell defamation claims 
against him. As a condition of the settlement, Defendant required that the financial terms of the 
settlement be kept confidential. 
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13. 
In November 2018, after conducting a lengthy investigation that involved 
interviewing over eighty (80) women, the Miami Herald published the first in a series of articles 
exposing how Epstein and his lawyers had corrupted the legal system to obtain the NPA and 
referring to Defendant's sexual abuse of Plaintiff. Defendant's response on behalf of himself and 
his client and co-conspirator Epstein has been a desperate barrage of false and increasingly 
defamatory attacks on Plaintiff. The purpose and effect of these attacks has been to damage 
Plaintiff's reputation and credibility and to try to intimidate her into silence. 
14. 
Defendant's central assertion is that Plaintiff has committed perjury, and that in 
December 2014, Plaintiff and her lawyers hatched a scheme to falsely accuse Defendant of sex 
trafficking as part of a criminal attempt to extort a settlement from another party. 
15. 
As Defendant well knew, Defendant's assertion was false. Defendant knew that 
he had in fact had sex with Plaintiff. Defendant also knew that Plaintiff's assertions about 
Defendant were not part of any criminal extortion plot. Indeed, Plaintiff had identified Defendant 
as a sexual predator years before December 2014. 
16. 
Defendant's knowledge of the falsity of his attacks on Plaintiff have not, however, 
limited the scope or scale of those attacks. 
17. 
Examples of Defendant's knowingly false and malicious defamatory statements 
are: 
(a) 
November 28, 2018, in an interview with the Miami Herald: "[T]he story 
was 100 percent flatly categorically made-up," and "Roberts and her attorneys 
fabricated the assertion in order to get money from other powerful, wealthy 
people ...." I
1 Julie K. Brown, Even from jail, sex abuser manipulated the system. His victims were kept in the dark, MIAMI 
HERALD (Nov. 28, 2018), https://hrld.us/38X1HYW. 
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(b) 
December 1, 2018, in a letter to the editor of Raw Story: "I never met 
Roberts; I never had sex with her; she simply made up the entire story for money."2
(c) 
December 2, 2018, in a letter to the editor of the Miami Herald: "I was 
'deliberately framed for financial reasons"; Plaintiff made her claims about 
Defendant "in order to obtain money from a wealthy businessman, and . . . Roberts 
had never previously included me among the people with whom she claimed to 
have had sex"; "one of Roberts' own lawyers has acknowledged in front of 
witnesses that her claims against me are `wrong' simply wrong"; "I never met 
Roberts; I never had sex with her; she simply made up the entire story for money.s3
(d) 
December 4, 2018, in an interview on the Law&Crime Network: Plaintiff 
is a "certified, complete, total liar"; "I can prove conclusively that she made the 
whole thing up." At the same time Defendant claimed "that the FBI recognized the 
evidence showed he was not where she said he was."' 
(e) 
December 5, 2018, in a letter to the editor of The Harvard Crimson: 
"Roberts made up the accusation out of whole cloth in order to obtain millions of 
dollars from Leslie Wexner," and "[t]here is evidence that directly proves I was 
framed. These include emails between Roberts and a journalist, a book manuscript 
by Roberts and a legal brief that are smoking guns showing that I was `deliberately 
framed for financial reasons?'S
2 Letter to the Editor: Alan Dershowitz responds to Raw Slimy report, RAW STORY (Dec. 1, 2018), 
https://bit.ly/35P6ust. 
3 Alan Dershowitz, Letter to the Editor, MIAMI HERALD (Dec. 2, 2018), https://hrld.us/35HFR8s. 
4 Ronn Blitzer, Dershowitz Goes Off on Woman Who Made Underage Sex Allegations, LAW & CRIME (Dec. 4, 
2018), https://bit.ly/2EASaYl. 
5 Alan M. Dershowitz, Letter to the Editor: Article Misrepresented Dershowitz, THE HARVARD CRIMSON (Dec. 5, 
2018), https://bit.ly/2S81Se5. 
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(ft 
March 2, 2019, on Twitter: "My perjuring accusers are 
and 
Sarah Ransomme [sic] [who reported that Epstein lent her out to Defendant for sex 
at the same time as Defendant was, at Epstein's request, representing Ransome as 
her lawyer]. Both have long records of lying."6
(g) 
April 16, 2019, in an interview with The Daily Mail: 7
i. "They [FBI agents] just have to walk down the block from the New 
York FBI headquarters, sit in on the trial and they will hear perjury 
being committed in their presence in a Federal court. The result will be 
[Plaintiff] will be prosecuted for perjury. This is a Federal crime being 
committed in a Federal courthouse.... This is an opportunity for me 
finally to have a judicial forum to prove that she made up the whole 
story and that she's a perjurer." 
it "[Plaintiff] hurts the Me Too movement terribly because when it's 
proved she lied for money the real victims will be people who have 
really been abused. She is a fake victim." 
May 2, 2019, on The View: "I support the Me Too movement, but when a 
women falsely accuses, for financial reasons-she was hoping to get a third of a 
billion dollars suing Leslie Wexner, the owner of Victoria's Secret. She also 
accused him in private, after accusing me in public, hoping to get a third of a billion 
6 Alan Dershowitz (®AlanDersh), TwirrER (Mar. 2, 2019, 6:42 PM), https://bit.ly/35G OHd. 
7 Ben Ashford & Cheyenne Roundtree, EXCLUSIVE: Defiant Alan Dershowitz brands 
a 'fake 
MeToo victim' as she files defamation suit claiming the lawyer who defended pedophile Jeffrey Epstein had 
underage sex with her and repeatedly called her a liar, DAILYMAIL.COM (Apr. 16, 2019), https://dailym.ai/2ScPyrF. 
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dollars. Where do I get that figure from? She told that to her best friend. I have that 
on tape."s
(i) 
July 5, 2019, on Twitter: Materials unsealed by the Second Circuit "prove 
that my false accuser—who I never even met—was told to include me in her 
manuscript describing her alleged sexual encounters, in order to help her market 
her book, despite her admitted knowledge of my total innocence. ... When the 
materials are unsealed , [sic] the public will see the evidence in my accuser's own 
words that ... prove I was framed for financial reasons & that I'm totally innocent, 
as I've consistently asserted since the day I was falsely accused."' 
(j) 
July 10, 2019, on CBS This Morning: "This is a woman with a long, long 
record of lying for money."1°
(k) 
July 12, 2019, on Fox News: "Let me repeat categorically, she made up the 
whole story. I never met this woman. It was part of an extortion plot to obtain a 
billion dollars from Leslie Wexner."11
(1) 
July 15, 2019, on NPR: "She made up the whole story out of whole cloth 
for financial reasons. The goal was to try to get a billion dollars from Leslie 
Wexner. The plan was to accuse me in public and then accuse Leslie Wexner in 
private of the identical conduct and say to him, essentially, if you don't want to 
have happen to you what happened to Dershowitz, there are ways of resolving it." 12 
8 The View, Alan Dershowitz on Epstein Case and Current Lawsuit, YOuTuRE (May 2, 2019), 
https://bit.ly/2McRSeF. 
9 Alan Dershowitz (gAlanDersh), TWITFER (Jul. 5, 2019, 6:50 AM), https://bit.ly/2EE9Hyl. 
I° CBS This Morning, Alan Dershowitz, Jeffrey Epstein's former lawyer, claims to have proof his accuser is lying, 
YOuTuRE (Jul. 10, 2019), https://bit.lyl38UNevs. 
11 The Ingraham Angle, Alan Dershowitz responds to Epstein accuser's defamation suit, sexual assault allegations, 
Fox NEWS (Jul. 12, 2019), https://bit.ly/35GIQOZ. 
12 Transcript: Alan Dershowitz Denies Epstein Rape Accusations And Defends Role In Sweetheart Deal, NPR (July 
15, 2019), https://n.pr/2PYsv0U. 
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(m) 
July 18, 2019, on Newsmax TV: "In the end, I hope David Boies goes to 
prison, because he has done terrible things in this case. All the women who have 
accused me started to commit their perjury only after they met David Boies. In other 
words, in every case, the woman said, 'I didn't have anything to do with 
Dershowitz. I never met him or had no association with him.' And then they meet 
David Boies, and suddenly they make accusations. There's a term for that, and I 
want the federal government to be examining whether Boies is guilty of subornation 
of perjury. I want the federal government to examine whether Boies is guilty of 
extortion, of trying to get a billion dollars from Leslie Wexner by essentially saying 
to Wexner privately, if you don't want to have happen to you what happened to 
Alan Dershowitz in public, there are ways of resolving this.s13
(n) 
July 19, 2019, on Fox News: 14
1. "1 have emails from the accuser in which she admits she didn't have sex 
with me and that she put me in her book in order to help sell the book 
and then she puts me in the book as somebody she didn't have sex 
with.... These are the most tainted, serial liars imaginable, and they all 
started telling their lies after they met David Boies." 
ii. "Each of the two accusers had said I didn't do it, and then they met 
David Boies, and he changed their minds. So they committed perjury 
after meeting David Boies. There's no coincidence about that." 
13 Newsmax TV, Alan Dershowitz Discusses Relationship with Jeffrey Epstein, YOuTuBE (July 18, 2019), 
https://bit.ly/2PEMenA. 
14 The Ingraham Angle, Dershowitz: Accusers said I didn't do it until David Boies changed their minds, FOX NEWS 
(Jul. 19, 2019), https://bitly/2EEIAgQ. 
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(o) 
July 19, 2019, in an interview with New York Magazine: "I know that I am 
a victim of a serious crime, a crime of perjury."15
(p) 
July 26, 2019, on Newsmax TV: 16
i. "The women first indicate they never had sex with me; then they meet 
Boies. Then they suddenly `remember' they had sex with me. Boies 
must know that both Accusers cannot be believed and that they made up 
the stories about me in the hope of getting money (which they got). Yet, 
he submitted their false affidavits, vouching for their credibility without 
disclosing to the courts their documented history of lying about 
prominent people." 
ii. "In all three instances, my false Accusers have refused to make their 
accusations to the media on the record. They have made them only in 
court papers, hiding behind the litigation privilege, which precludes 
defamation suits for false statements. This is a tactic developed and 
employed by David Boies to prevent any legal accountability for false 
accusations." 
July 29, 2019, on NewsmaxTV: "I'm gonna continue to call them liars and 
perjurers. That's the truth. It's not victim shaming; it's criminal shaming. They're 
criminals. They belong in jail."17
15 Andrew Rice, Alan Dershowitz Cannot Stop Talking, NY MAGAZINE (Jul. 19, 2019), httpsJ/nym.ag/2Q2f6oJ. 
16 Alan Dershowitz, Open Letter to The New Yorker Exposes False Allegations, NEWSMAX (Jul. 26, 2019), 
https://nws mx/2PHXe3r. 
17 Newsmax TV, Alan Dershwitz fsicJ Responds to New Yorker Article, YOUTUBE (Jul. 29, 2019), 
https://bit.ly/36T5eoc. 
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(r) 
August 9, 2019, on Twitter: "The unsealed documents prove Roberts made 
up accusations after being pressured by her lawyers."'8
(s) 
August 10, 2019, on Fox News:19
i. "She told her best friend she didn't want to name me because I was 
innocent but she was pressured to do it by her lawyer because she saw 
a pot of gold at the end of the rainbow. She is a complete and total liar." 
ii. "We're gonna go to court and we're gonna prove that this woman is a 
liar who was put up to it by her lawyers.... We're gonna prove that for 
years and years and years she said she never had sex with me.... Now 
I don't know whether she is making up and fantasizing about these other 
people. I can tell you she is totally fantasizing about me. She's made up 
the whole story. There is no truth to it." 
(t) 
August 12, 2019, in a press statement issued after the Second Circuit's 
ruling in Giuffre v. Maxwell: "She invented the false accusation against me only in 
2014, when her lawyers `pressured' her to do so for financial reasons."2°
(u) 
August 30, 2019, on NewsmaxTV:2' "[A]s soon as [Plaintiff] met David 
Boies and the other lawyers, suddenly she remembered having had sex with me. 
It's totally made up. I never met her." 
(v) 
October 19, 2019, on Twitter: "I will prove that Giuffre never falsely 
claimed to have had sex w/ me until she was pressured by her lawyers. I will also 
Alan Dershowitz (®AlanDersh), TwrrrEit (Aug. 9, 2019, 3:52 PM), https://bit.ly/38UL6Uv. 
19 The Ingraham Angle, Alan Dershowitz responds to new allegations from Epstein case, FOX NEWS (Aug. 10, 
2019), https://bit.ly/38T1V3r. 
20 David A. Patten, Dershowitz: New Documents 'Categorically Prove' No Epstein-Related Sex, NEWSMAX (Aug. 
12, 2019), https://nws.nucaMdIOEZ. 
21 Newsmax TV, Alan Dershowitz Denies Claims from Epstein Accuser, You'rusE (Aug. 30, 2019), 
https://bit.ly/2s3vLjQ. 
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prove I never met her and she invented the entire story for money. Now she will 
have to give back all the money she made from her lies."22
(w) 
November 16, 2019, on BBC Radio: "She is lying about me. I have recorded 
evidence from her own lawyer admitting that she was wrong about me. I am a 
victim of her perjury."23
(x) 
November 19, 2019, in Guilt by Accusation: The Challenge of Proving 
Innocence in the Age of #MeToo:24
i. "Although I am the victim here—the victim of a deliberate frame-up 
motivated by money—I am being treated as a perpetrator, despite the 
fact that I have done absolutely nothing wrong." (1-2) 
ii. "[T]he decision to accuse me in public, while accusing others in private, 
was part of a carefully calculated shakedown plot to get money from a 
wealthy individual who was not publicly named—at least not yet." (21) 
iii. "Giuffre's lawyers had to be aware of her history of lying when they 
vouched for her credibility by submitting perjured affidavits by her 
falsely accusing me of sexual misconduct with her." (36) 
iv. "After meeting with her lawyers—and `feeling pressure' from them—
Giuffre suddenly `remembers' having sex with me seven times between 
2001 and 2002 (when she was 18 and 19)." (45) 
v. "Even after it was proved conclusively that she had committed 
numerous acts of perjury, she remained a free woman, unpunished for 
n  Alan Dershowitz (@AlanDersh), Twitter (Oct. 19, 2019), https://bit.ly/2Z5VqV2. 
23 BBC Radio Broadcast 16/11/2019, BBC RADIO 4 (Nov. 16, 2019) (audio on file with counsel). 
24 ALAN DERSHOWITZ, GUILT BY ACCUSATION: THE CHALLENGE OF PROVING INNOCENCE IN THE AGE OF #METOO 
(2019). 
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repeatedly lying under oath and deliberately seeking to destroy the 
reputation of an innocent victim of a financially motivated frame-up. 
Nor was I the only victim of her perjury. Every real victim of sexual 
assault suffers when a false 'victim' is caught in a lie, as Giuffre has 
been." (57-58) 
vi. "It is these realities that incentivized Giuffre and her lawyers to falsely 
accuse me of a crime with complete impunity: they believed that I could 
not sue them, because their allegations were contained in a court filing, 
and were thus immune from a defamation suit." (58) 
(y) 
December 8, 2019, on Fox News:25
i. 
"She remembered after telling everybody she didn't have sex with me; 
she had an exchange of emails with somebody in which she said she 
never met me, she never met me. And then she meets her lawyers and 
suddenly she remembers not only having sex with me, but on seven 
occasions in places that I never was during the relevant time period." 
ii. "This was all part of an extortion plot against Leslie Wexner. ... The 
plot was to accuse me publicly, and then privately go to Leslie Wexner, 
which they did and essentially say to him look if you don't want to have 
happen to you what happened to Dershowitz, there are ways of resolving 
this." 
25Alan Dershowitz Defends Himself Against tiMeToo Accusation in Interview with Mark Levin, YOuTusE (Dec. 8, 
2019), https://bit.ly/35HTINCT. 
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18. 
In addition to these examples, in countless public statements, Defendant has 
accused Plaintiff of being a liar, of lying, and has otherwise impugned her integrity and 
reputation for truthfulness. 
19. 
Defendant knew his assertions about Plaintiff, including his assertions referenced 
in paragraph 17 above, were, and would be taken by persons who read and heard them to be, 
specific statements of fact. 
20. 
Defendant has repeatedly, publicly claimed that he wanted to have a trial that 
would determine the facts concerning his conduct. He said on national television that he would 
waive the statute of limitations so that Plaintiff could sue him for sex abuse. However, when 
Plaintiff's lawyer asked Defendant to do so, Defendant refused—and continues to refuse. 
21. 
When Defendant was faced with an actual case brought by Plaintiff's then-
lawyers Edwards and Cassell, which would have determined the veracity of Plaintiff's claims, 
however, Defendant settled to avoid that determination. 
22. 
More recently, Defendant has again taken to claiming publicly that he demands a 
trial on the question whether Plaintiff committed perjury and made up her statements about him 
for money. For example, on March 2, 2019: My "accusers are 
and Sarah 
Ransomme [sic]. . . . I hereby accuse my false accusers of committing the felony of perjury and 
challenge them to sue me for defamation." 
23. 
Defendant now has what he claims to have been looking for. 
JURISDICTION AND VENUE 
24. 
This is an action for damages in an amount in excess of the minimum 
jurisdictional limits of this Court. 
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25. 
This Court has jurisdiction over this dispute pursuant to 28 U.S.C. § 1331 (federal 
question jurisdiction) and 28 U.S.C. § 1367 (supplemental jurisdiction) because one claim in this 
action arises under the laws of the United States, and the remaining claims are so related to the 
claim within this Court's original jurisdiction that they form part of the same case or controversy 
under Article III of the United States Constitution. This Court also has jurisdiction over this 
dispute pursuant to 28 U.S.C. § 1332 (diversity jurisdiction), in that Plaintiff and Defendant are 
citizens of different states, and the amount in controversy exceeds seventy-five thousand dollars 
($75,000), exclusive of interest and costs. 
26. 
This Court has personal jurisdiction over Defendant. Defendant resides in New 
York City; Defendant conducts regular business in New York City; and this action arose, 
defamatory statements were made, and abuse occurred, within the Southern District of New 
York. 
27. 
Venue is proper in this Court under 28 U.S.C. § 1391(6) because (1) Defendant 
resides within this District, and (2) a substantial part of the events or omissions giving rise to 
Plaintiff's claims occurred within this District. 
PARTIES 
28. 
Plaintiff
an individual who is a citizen of the State of 
Colorado. 
29. 
On information and belief, Defendant Alan Dershowitz is an individual who is a 
citizen of the State of New York and resides in the Southern District of New York at 2 Tudor 
City Place Apt. 10EN, New York, New York 10017. 
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FACTUAL ALLEGATIONS 
A. 
Epstein's Sex Trafficking Enterprise 
30. 
Plaintiff became a victim of sex trafficking and repeated sexual abuse after being 
recruited by Ghislaine Maxwell and Jeffrey Epstein when Plaintiff was under the age of 
eighteen. 
31. 
Between 2000 and 2002, Epstein sexually abused Plaintiff at numerous locations 
including his mansions in West Palm Beach, Florida, New Mexico, the Virgin Islands, and this 
District. Epstein also flew Plaintiff on his plane nationally and internationally numerous times 
when she was under the age of 18. Only portions of the flight logs of Epstein's private planes are 
yet known, and Epstein also flew Plaintiff frequently on commercial airlines to meet him and 
others. However, the chart below, which shows Plaintiff's flights on Epstein's private plane from 
the limited logs that are available, illustrates the international scope of Epstein's sex trafficking. 
4114K-
Swim 
Van 
32. 
Between 1999 and 2007, with the assistance of numerous co-conspirators, Epstein 
abused more than thirty (30) minor underage girls, a fact confirmed by state and federal law 
enforcement. 
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33. 
After years of abuse, Epstein sent Plaintiff to Thailand in September 2002. One of 
Plaintiff's assignments from Epstein was to bring a young girl back to Epstein in the United 
States. Fearing for her life, and not wanting to subject another young girl to the abuse she was 
forced to endure, Plaintiff fled from Thailand to Australia to escape from Epstein. 
B. 
Defendant's Role with Epstein and Abuse of Plaintiff 
34. 
Defendant has been "a close friend of Mr. Epstein" for many years. In 2003, 
Defendant said "I'm on my 20th book... The only person outside of my immediate family that I 
send drafts to is Jeffrey." Vicky Ward, The Talented Mr. Epstein, VANITY FAIR (Jun. 27, 2003), 
https://bit.ly/2S9MzQU. Defendant also described Epstein as his friend. "I would be as interested 
in him [Epstein] as a friend if we had hamburgers on the boardwalk in Coney Island and talked 
about his ideas." Ray Gustini, Vanity Fair Reminds Us When Jef•ey Epstein Wasn't a Creep, 
THE ATLANTIC (June 21, 2011), https://bit.ly/38ZwHGK. Defendant frequently traveled with 
Epstein, including on Epstein's private plane. In addition, Epstein's employees have confirmed 
that Defendant visited Epstein's Palm Beach and New York City mansions often, would stay 
overnight, and was present when the victims of Epstein's sex trafficking were there. Defendant 
also visited Epstein's other homes. 
35. 
In addition to their close friendship, Defendant represented Epstein as his lawyer. 
On or about December 2, 2018, Defendant stated that he was still Epstein's lawyer. 
36. 
During the time period that Plaintiff was being trafficked by Epstein, she was 
forced to have sex with Defendant. Plaintiff was forced to engage in sexual acts with Defendant 
in various locations. 
37. 
On one such occasion, in late 2000 or early 2001, Defendant sexually assaulted 
Plaintiff at Epstein's mansion located at 9 East 70 Street, New York, New York 10021. 
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38. 
At the time of the incident, Plaintiff was under the age of 18. Epstein had taken 
her from her home, family, and friends in Palm Beach, Florida, and flown her to New York, New 
York, where he repeatedly sexually abused her. In the weeks immediately prior to the incident, 
Defendant had met Plaintiff in circumstances that would have put a reasonable person on notice 
that she was being sexually trafficked. 
39. 
Defendant entered Epstein's bedroom immediately after one incident of abuse by 
Epstein, while Plaintiff was alone and unclothed. Without obtaining her consent to the contact. 
he proceeded to engage in sexual intercourse with her. 
40. 
As Defendant knew, Plaintiff did not consent to the sexual intercourse but rather 
was under the coercive influence of Epstein and/or his co-conspirators. 
C. 
The Arrest and Prosecution of Epstein 
41. 
Epstein ultimately pleaded guilty to procuring a minor for prostitution and was a 
registered sex offender until his death on August 10, 2019. 
42. 
In September 2007, while Defendant was representing him, Epstein entered into a 
Non-Prosecution Agreement ("NPA") in which the United States Attorney for the Southern 
District of Florida agreed not to prosecute Epstein for numerous federal sex crimes committed in 
that District. 
43. 
In the NPA, the United States Attorney for the Southern District of Florida 
additionally agreed that it would not institute any federal criminal charges against any potential 
co-conspirators of Epstein. 
44. 
Epstein flippantly referred to his sexual abuse of multiple minors, and the slap on 
the wrist he had received for it, in a 2011 interview with the New York Post: "Billionaire pervert 
Jeffrey Epstein is back in New York City—and making wisecracks about his just-ended jail stint 
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for having sex with an underage girl. `I am not a sexual predator, I'm an "offender,"' the 
financier told The Post yesterday. `It's the difference between a murderer and a person who 
steals a bagel,' said Epstein." See Amber Sutherland, Billionaire Jef•ey Epstein: I'm a Sex 
Wender, Not A Predator, NEW YORK POST (Feb. 25, 2011), https:/Ibit.ly/2s3ebwk. 
D. 
The Criminal Victims' Rights Act Proceeding 
45. 
Rather than confer with the victims about the NM. the U.S. Attorney's Office 
and Epstein, who was represented by Defendant at that time, agreed to a "confidentiality" 
provision in the Agreement barring its disclosure to anyone—including Epstein's victims. As a 
consequence, the victims were not told about the NPA. 
46. 
On July 7, 2008, a young woman identified as Jane Doe No. 1, one of Jeffrey 
Epstein's victims (other than Plaintiff), filed a petition to enforce her rights under the Crime 
Victims' Rights Act ("CVRA"), 18 U.S.C. § 3771, alleging that the Government failed to 
provide her the rights promised in the CVRA with regard to the plea arrangement with Epstein. 
47. 
On February 21, 2019, the Court found that the victims' rights had been violated 
and granted summary judgment in favor of the victims finding: "It was a material omission for 
the Government to suggest to the victims that they have patience relative to an investigation 
about which it had already bound itself not to prosecute." Order at 31. In its Order the Court 
acknowledged that: "Jeffrey Epstein sexually abused more than 30 minor girls." Id. at I. The 
Court also found: "Among other provisions, the NPA expanded immunity to any `potential 
coconspirator' of Epstein's: `In consideration of Epstein's agreement to plead guilty and to 
provide compensation in the manner described above, if Epstein successfully fulfills all of the 
terms and conditions of this agreement, the United States also agrees that it will not institute any 
criminal charges against any potential co-conspirators of Epstein, including but not limited to 
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