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 includi