Epstein Secrets

g matters: 1) Non-Party Motion to Strike And For Sanctions; 2) Non-Party Sanctions Giuffre's Supplemental Motion to Strike and For 3) Defendant Alan Dershowitz's Motion in Limine to Overrule Objections 4) Defendant Alan Dershowitz's Motion to Strike Motion of Non-Party a ' Motion for Sanctions NOTICE TO DIS

Specifically, the Court has specially set for hearing on May 12. 2016, non-party Supplemental Motion to Strike and for Sanctions against Defendant Dershowitz. See Exhibit A. The parties agreed that the settlement between the Plaintiffs and the Defendant would in no way affect the right of non-party to ha

EDWARDS, and PAUI G. CASSELL, Plaintiffs, v. ALAN DERSHOWITZ, Defendant. PLAINTIFFS AND NON-PARTY

11, 2016 Respectfully submitted, Botos, SCHILLER & FLEXNER LLP By: /s/Sigrid S. MeCawley,. Sigrid S. McCawley, Esq. Florida Bar No. 129305 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, Florida 33301 Telephone: (954) 356-0011 Facsimile: (954) 356-0022 Attorney for Non-Party Git4Ifre By: /s/ Jack Sca

vidual witnesses with knowledge regarding the facts of this case, yet provided addresses (only of their counsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categories of witnesses such as "all other then-minor girls, whose identities Plaintiff will attempt to determine" and "

ounsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categories of witness

heir counsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categorie

wing: Sigrid S. McCawley Paul G. Cassell Meridith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 [email protected] Ft. Lauderdale, FL 33301 [email protected] [email protected] Bradley J. Edwards FARMER, JAFFE, WEISSING,

elated to communications with or interaction with Alan Dershowitz from 1999 to present. DOCUMENT REOUE

ence of you or Jeffrey Epstein or between 1999 and 2005. DOCUMENT REOUEST NO. 32 All documents related to communications with or interaction with Alan Dershowitz from 1999 to present. DOCUMENT REOUEST NO. 33 All travel records between 1999 and the present reflecting your presence in: (a) Palm Beach, Florid

d to communications with or interaction with Alan Dershowitz from 1999 to present. DOCUMENT REOUEST NO. 33

the Federal Rules of Civil Procedure to the Defendant Ghislaine Maxwell. The responses are due at the offices of Boies, Schiller & Flexner LLP, 401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida 33301, within thirty (30) days of service hereof. DEFINITIONS Wherever they hereafter appear the following w

ents related to communications with any members of Ghislaine Maxwell's family from 1970 — present. 9. All Documents related to communications with Alan Dershowitz from 1999 — present. 9 EFTA00606504 Jeffrey Epstein EXIJIBIT A 10. All Documents relating to, and all media depicting, any of the following

All Documents related to communications with Alan Dershowitz from 1999 — present. 9 EFTA00606504 Jeffrey

9. All Documents related to communications with Alan Dershowitz from 1999 — present. 9 EFTA00606504

ey Epstein. INSTRUCTIONS 1. Production of Documents and items requested herein shall be made at the offices of Boies Schiller & Flexner, LLP, 401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida 33301, no later than five (5) days before the date noticed for Your deposition, or, if an alternate date is a

3301 125. 126. Zack Bryan Wellin' on, Florida 127. 128. Larry Morrison WELLINGTON, FL 33449 129. Story Cowles WEST PALM BEACH, FL 33401 130. Alan Dershowitz CAMBRIDGE, MA 02138 or EFTA00798055 DESCRIPTION OF WITNESSES NEW YORK, NY 10017. Subject to assertions of privilege 131. Michael Dawson Palm

tory Cowles WEST PALM BEACH, FL 33401 130. Alan Dershowitz CAMBRIDGE, MA 02138 or EFTA00798055 DESCRIPT

assertions of privilege 76. Donald Trtunp c/o Alan Garten, Esq. 725 Fifth Avenue EFTA00798051 DE

various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. 13 Charles Lichtman, Esquire 350 East Las Olas Boulevard I Suite 1000 Fort Lauderdale, FL 33301 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. W

uments related to communications with any members of Ghislaine Maxwell's family from 1970 present. 9. All Documents related to communications with Alan Dcrshowitz from 1999 - present. 9 EFTA00622780 Case 1:15-cv-07433-RWS Document 161-1 Filed 05/25/16 Page 13 of 40 Jeffrey Epstein IX11111IT A 10. All Do

om 1999 — present: , Eva Dubin, Glen Dubin, Alan Dershowitz, Jean Luc Brunel, (a/k/a or any females under

9. All Documents related to communications with Alan Dcrshowitz from 1999 - present. 9 EFTA00622780

rey Epstein. INSTRUCTIONS 1 Production of Documents and items requested herein shall be made at the offices of Soaks Schiller & Flexner, LLP, 401 East Las Olas Boulevard, Suite 1200, Port Lauderdale, Florida 33301, no later than five (5) days before the date noticed for Your deposition, or, if an alternate date is a

annot be met with respect to Mr. Rodriguez's deposition testimony. Indeed, the Plaintiff's Motions to Exclude Designation of Depositions Excerpts of Alan Dershowitz and Plaintiff argued this precise point. Ms. Maxwell was not a party to any of the litigations in which Mr. Rodriguez was deposed; Ms. Maxwell was

clude Designation of Depositions Excerpts of Alan Dershowitz and Plaintiff argued this precise point. Ms. Max

to Exclude Designation of Depositions Excerpts of Alan Dershowitz and Plaintiff argued this precise poi

ollowing: Sigrid S. McCawley Paul G. Cassell Meredith Schultz 383 S. University Street BOLES, SCHILLER & FLEXNER, LLP Salt Lake it UT 4112 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale FL 33301 Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2

w, how about Mr. Jack Goldberger, 6 Mr. Epstein's criminal defense attorney, did you ever 7 talk to him? 8 A. No. 9 Q. Did you ever talk to Alan Dershowitz about any 10 of these matters? 11 A. No, sir. 12 Q. Or Roy Black? 13 A. No, sir. 14 Q. Now, I'm just going back over some different 15

4 house that afternoon, the first time I saw rive in 5 at this -- Donald Trump's house. 6 Q. Now, you said you know -- you knew who Alan 7 Dershowitz or you know who Alan Dershowitz is, right? 8 A. Many times. 9 Q. And he was at the house? 10 A. He's been at the house a lot of times. 11

to him? 8 A. No. 9 Q. Did you ever talk to Alan Dershowitz about any 10 of these matters? 11

2 Page 82 1 APPEARANCES: On behalf of the Plaintiffs: 4 5 6 7 8 9 10 11 WILLIAM J. BERGER, ESQUIRE ROTHSTEIN ROSENFELDT ADLER 12 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida 33301 13 RICHARD WILLITS, ESQUIRE RICHARD H. WILLITS, P.A. 2290 10th Avenue North, Suite 404 ' 461 STUAR

w, how about Mr. Jack Goldberger, 6 Mr. Epstein's criminal defense attorney, did you ever 7 talk to him? 8 A. No. 9 Q. Did you ever talk to Alan Dershowitz about any 10 of these matters? 11 A. No, sir. 12 Q. Or Roy Black? 13 A. No, sir. 14 Q. Now, I'm just going back over some different 15

ouse that afternoon, the first time I sat-, ill drive in 5 at this -- Donald Trump's house. 6 Q. Now, you said you know -- you knew who Alan 7 Dershowitz or you know who Alan Dershowitz is, right? 8 A. Many times. 9 Q. And he was at the house? 10 A. He's been at the house a lot of times. 11

to him? 8 A. No. 9 Q. Did you ever talk to Alan Dershowitz about any 10 of these matters? 11

A. 8 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 9 Phone: 10 11 WILLIAM J. BERGER, ESQUIRE ROTHSTEIN ROSENFELDT ADLER 12 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida 33301 13 Phone: 14 15 KATHERINE W. EZELL, ESQUIRE PODHURST ORSECK, P.A. 16 25 West Flagler Street, Suit

s. Oct 29, 2013 LSI Reminder: 4:00pm JE to call Alan Halperin and Brad Okwi Wed. Oct 30, 2013 LSJ 4:

Oct 10. 2013 PARIS EFTA00284882 Reminder: Thursday, October 10, 2013 at 10 AM Video Deposition of Brad Edwards at Empire Legal Support Inc., 401 East Las Olas Boulevard, Suite 1400, Fort Lauderdale, FL 33301. Reminder: Scott to go to the house at 11am to work on your Apple Computers Fri. Oct 11, 2013 PARIS Remind