Epstein Secrets

LY IONTALVO. RPR. CLR Phipps Reporting. Inc. 1551 Forum Place Bulldog/200k Suite E West Palm Beach. Honda 33401 I do hereby waive my signature. ALAN M. DERSIIDWITZ 780 34 (Pages 777 to 780) www.phippsreporting.com (888)811-3408 EFTA00602472 781 ERRATA SHEET DO NOT WRITE ON IRANSCRIIT - EATER CHANGES HER

is lawyers. 6 together and contrived and made this up? 6 No other individuals: for example. 7 A. That will require a "no- answer and an 7 Mr. Dershowitis wife or anybody else can be 8 explanation. Okay. The explanation is that before 8 present at that deposition. It's a deposition 9 you made your f

664) www.phippsreporting.com (888)811-3408 EFTA00602443 665 667 1 please elaborate on that. You say you had sex with 1 MR. INDYKE: Instruct Alan not to answer 2 him. Was it one time? Was it two times? Could it 2 to the extent it would disclose communications 3 have been six times? Could

Q. (Via phone) 6 Bradley Edwards and Paul Cassell versus Alan 6 7 Dershowitz. 7 On behalf of 8 My name is Marcy Martinez_ I am the 8 BOLES. SCHILLER & FLEXNER, LLP 9 videographer representing Above & Beyond 401 E. Las Olas Blvd_ Ste. 1200 10 Reprographics. Will the attorneys please 9 Fat Lauderdale.

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

ANCTIONS FOR VIOLATION OF RULE 45 via ECF on the following: 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] mschul

ntiff in this matter about Harvard Law Professor Alan Dershowitz. Mr. Edwards is counsel for Plaintiff

. Mr. Edwards is a named Plaintiff and Counterclaim Defendant in an action captioned Edwards and Edwards, Plaintiffs and Counterclaim Defendants v. Dershowitz, 15-000072 pending in the Circuit Court in Broward County, Florida. The subject of that litigation includes allegations made by Mr. Edwards during

t of that litigation includes allegations made by Mr. Edwards during his representation of the Plaintiff in this matter about Harvard Law Professor Alan Dershowitz. Mr. Edwards is counsel for Plaintiff in other matters including Plaintiff's attempt to intervene in CVRA litigation pending in the United States D

Y THE PROTECTION ORDER TO RESTRICT MR. EDWARDS'S ACCESS TO INFORMATION DESIGNATED CONFIDENTIAL via ECF on the following: Sigrid S. McCawley BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale. FL 33301 /s/ Nicole Simmons Nicole Simmons 6 EFTA00595646

. Mr. Edwards is a named Plaintiff and Counterclaim Defendant in an action captioned Edwards and Edwards, Plaintiffs and Counterclaim Defendants v. Dershowitz, 15-000072 pending in the Circuit Court in Broward County, Florida. The subject of that litigation includes allegations made by Mr. Edwards during

t of that litigation includes allegations made by Mr. Edwards during his representation of the Plaintiff in this matter about Harvard Law Professor Alan Dershowitz. Mr. Edwards is counsel for Plaintiff in other matters including Plaintiff's attempt to intervene in CVRA litigation pending in the United States D

ntiff in this matter about Harvard Law Professor Alan Dershowitz. Mr. Edwards is counsel for Plaintiff

Y THE PROTECTION ORDER TO RESTRICT MR. EDWARDS'S ACCESS TO INFORMATION DESIGNATED CONFIDENTIAL via ECF on the following: Sigrid S. McCawley BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale. FL 33301 /s/ Nicole Simmons Nicole Simmons 6 EFTA00595639

elke, —against— GHISLA1NE MAXWELL, Defendant-Appellant, SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA Intervenors. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 15-CV-

access to all filings and discovery materials, including third-party discovery, from that case." App. p 514. The district court rightly rejected Mr. Dershowitz's motion, explaining that this Court "has held that where there has been reasonable reliance by a party or non-party in providing discovery pursuan

dents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH M

nt. x 9 New York, N.Y. 10 July 23, 2020 11:30 a.m. 11 Before: 12 HON. LORETTA A. PRESKA, 13 District Judge 14 APPEARANCES 15 BOIES, SCHILLER & FLEXNER, LLP 16 Attorney for Plaintiff BY: SIGRID S. MCCAWLEY 17 HADDON, MORGAN, AND FOREMAN, P.C. 18 Attorney for Defendant BY: LAURA A. MENNINGER

LAINE MAXWELL, SHARON CHURCHER, JEFFREY EPSTEIN, PlaintiffiAppellee, Defendant-Appellant, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA Intervenors. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 15-CV-

the nature of this case. 9 I think it's more like listing witnesses. So I would say that 10 the plaintiff should supply all residences. 11 The Dershowitz deposition will be produced under the 12 confidentiality provision. As I read what I've been given, 13 it's to be held in confidence and it will

dents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH M

nce GHISLAINE MAXWELL, Defendant. Before: New York, N.Y. July 23, 2020 11:30 a.m. HON. LORETTA A. PRESKA, District Judge APPEARANCES BOIES, SCHILLER & FLEXNER, LLP Attorney for Plaintiff BY: SIGRID S. MCCAWLEY HADDON, MORGAN, AND FOREMAN, P.C. Attorney for Defendant BY: LAURA A. MENNINGER SOUTHERN DIS

cuments responsive to this Request. DOCUMENT REOUEST NO. 11 Produce any documents concerning any of Your attorneys' or agents' communications with Alan Dershowitz's attorneys or agents from 1999 to the present RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or information protecte

ge, the work-product doctrine, the common interest privilege or any other applicable privilege. Defendant is withholding communications between Mr. Dershowitz's counsel and Defendant's counsel which contain work product and concern joint defense or common interest matters. DOCUMENT REOUEST NO. 12 Produce

nt Defense Agreement entered into between You and Alan Dershowitz from 1999 to the present. RESPONSE:

TO PLAINTIFF'S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS via email to the following counsel of record: Sigrid S. McCawley Meridith Schultz BOWS SCHILLER & FLEXNER. LLP Ft. Lauderdale. FL 33301 ME I FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN. P.L. Ft. Lauderdale. FL 33301 Paul G. Cassell Salt Lake

VENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, vs. ALAN M. DERSHOWITZ, Defendant. VIDEOTAPE CONTINUED DEPOSITION OF ALAN M. DERSHOWITZ VOLUME 4 Pages 462 through 647 Tuesday, January 12, 2016 1:05 p.m. - 4:45 p.m

ed Jul 6 2007 from Gerald 612 B. Lefcourt to First 19 Assistant U.S. torney an o hers 22 pages 20 23 Document titled NewsRoom/Alan 623 21 Dershowitz to talk in Alburquerque 22 24 628 23 24 25 www.phi sre orting.com EFTA00615586 466 1 VIDEOGRAPHER: Going back on the record. 2 The time

or the record, object to 2 the relevancy of all of this. 3 A. I'm not aware of that. 4 MR. INDYKE: Just for the record, to the 5 extent that Alan's answer requires him to 6 invade privilege, I would object and instruct 7 him not to answer. 8 SPECIAL MASTER POZZUOLI: Within the 9 confine

1 APPEARANCES (Continued): 2 3 On behalf of Jeffrey Epstein: 4 5 Sligi BY: DARREN K. INDYKE, ESQ. (Via phone) 6 7 On behalf of 8 BOIES, SCHILLER & FLEXNER, LLP 9 BY: SIGRID STONE MCCAWLEY, ESQ. 10 11 12 ALSO PRESENT: 13 Edward J. Pozzuoli, Special Master 14 Sean D. Reyes, Utah Attorney General

The Court denied these motions but granted Messrs. Cassell and Edwards leave to re-apply, if they provided evidence of "something that closes [the Dershowitz] case and I get the affidavit that there are no other matters in which they have any claims or defenses relating to any of these statements, that wi

PORT OF MOTION TO COMPEL RESPONSES TO DEFENDANT'S FIRST SET OF DISCOVERY REQUESTS TO PLAINTIFF via ECF on the following: Sigrid S. McCawley BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 [email protected] /s/ Laura A. Menninger Laura A. Menninger EFTA0060545

y Edwards. 8. Attached as Exhibit G is a Motion to Quash filed by counsel for Jeffrey Epstein in Broward County, Florida in Edwards and Cassell v. Dershoivitz, Case No. 15-0000072 on September 10, 2015. 9. Attached as Exhibit H is a true and correct copy of the Notice of Deposition and Subpoena for Jeff

to Complete Depositions and Motion for Sanctions for Violations of Rule 45 via ECF on the following: Sigrid S. McCawley Meridith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 [email protected] [email protected] Bradley J. Edwards FARMER, JAFFE,