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Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 15 of 28

57. Again, both to conceal his relationship with Epstein and to discredit Roberts,
Dershowitz has repeatedly asserted that he was never in Epstein’s residence in the presence of
young women. As both Dershowitz and Epstein know, that assertion was also false. As Mr.
Rodriguez has confirmed, there were “also young ladies in the house at the time he [Dershowitz]
was there”. Mr. Rodriguez also confirmed that “Mr. Dershowitz was there” when “women came
to Mr. Epstein’s home to give a massage”. Mr. Rodriguez also confirmed that “Alan Dershowitz
was at the house” with “the local Palm Beach girls” who he was “told to call masseuses”,
although he did not himself know whether or not Dershowitz personally received a massage.

58. Maria Farmer was an employee of Epstein responsible for “manning the front
door at his New York mansion and keeping records of people who came to the home” (Exhibit
12, ¶ 2).

(a) Ms. Farmer “witnessed a number of school age girls coming to the house,
some of the young girls would be wearing their school uniforms”…who “then
would be escorted upstairs” (Exhibit 12, ¶ 3).

(b) Ms. Farmer was told these young girls “were interviewing for modeling
positions” even though “it did not seem credible to me that these young girls were
interviewing for modeling positions”. (Exhibit 12, ¶ 3).

59. Ms. Farmer asserts that “Alan Dershowitz was an individual who came to visit
Epstein at his New York mansion a number of times when I was working for Epstein.
Dershowitz was very comfortable at the home and would come in and walk upstairs. On a
number of occasions I witnessed Dershowitz at the NY mansion going upstairs at the same time
there were young girls under the age of 18 who were present upstairs in the house” (Exhibit 12, ¶
4).

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