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08-80736-C1V-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Plaintiffs. vs. UNITED STATES OF AMERICA, Defendant. MOTION FOR LIMITED INTERVENTION BY ALAN M. DERSHOWITZ Alan M. Dershowitz (herein, "Prof. Dershowitz"), a nonparty to this litigation, is the victim of scurrilous allegations made in Jane Doe #3 and Jan
g duplicative discovery to that which is already being sought in Broward County Circuit Court. One forum is enough to litigate reputations] issues. B. DERSHOWITZ SHOULD NOT BE ALLOWED TO INTERVENE IN THIS ACTION WHEN HE HAS DECLINED TO DEFEND HIS REPUTATION IN OTHER ACTIONS. Dershowitz also claims that he h
and they have spread around the world. What makes them doubly troubling is their irrelevancy: although categorically false, the allegations against Prof Dershowitz have absolutely nothing to do with whether the United States government violated its duty to confer with the Plaintiffs prior to entering into the n
in New York in Epstein's home. It was in Epstein's room (not the massage room). I was approximately 16 years old at the time. I called Dershowitz "Alan." I knew he was a famous professor. 27. The second time that I had sex with Dershowitz was at Epstein's house in Palm Beach. During this encounter
n-a I legal ions—tota Ily-fa Ise-38194285 I 573 (Dershow kz: "Right now. they have accused me of these .
e latest date on which, according to Dershowitz, the Government made the decision not to pursue federal criminal charges against Epstein. DE 285 at I. Dershowitz appears to be unaware that the Government told the victims well after that date that the Government was still "investigating" the case. DE 48 at 16.
2015 Page 27 of 40 attorneys proffered in her earlier motion — i.e., that Epstein sexually trafficked Jane Doc No. 3 to numerous persons, including Dcrshowitz. If the Court believes it would be useful. Jane Doe No. 3 requests an evidentiary hearing to prove she is telling the truth 19 and directs the Court
. at 122 (Palm Beach Cty. Cir. Ct. Oct. 8, 2009). In short, all the key conspirators in Epstein's sexual trafficking ring who could be asked about Derhowitz's involvement took the Fifth." This "[sJilence is . . . evidence of the most persuasive character." United States ex rd. Bilokumsky 'Tod, 263 U.S. 1
such intervention is reviewed only for abuse of discretion. Stone'. First Union Corp.. 371 F.3d 1305, 1309 (1Ith Cir. 2004); see also AT&T Corp. '. Sprint Corp., 407 F.3d 560, 561-62 (2nd Cir. 2005) ("[a] denial of permissive intervention has virtually never been reversed" because of the considerable discret
from exhibit 30, which is correspondence sent by Alan Dershowitz and Gerald Lefcourt, attorneys for Je
t. / ORDER GRANTING MOTION TO SEAL It is hereby ordered that the Unredacted version of Plaintiff's Response to Motion for Limited Intervention by Alan M. Dershowitz and Exhibit 30 of said Response be sealed until further order of this Court. DONE AND ORDERED in Chambers at Palm Beach County, Florida, this day
ung girls, there is no good reason that the Court should now allow a special, discretionary opportunity to intervene to respond to the allegations. C. DERSHOWITZ SHOULD NOT BE ALLOWED TO INTERVENE TO STRIKE ALLEGATIONS RELEVANT TO ISSUES PENDING BEFORE THE COURT. The Court should also deny Dershowitz's motio
ut lacking such an allegation, his existing motion does not allege any concrete impainnent of his interests supporting mandatory intervention. II. DERSHOWITZ IIAS NOT SHOWN THAT THE COURT SHOULD ALLOW PERMISSIVE INTERVENTION UNDER RULE 24(B). 7 During the hearing on Reinhart's intervention motion, the Governm
. at 122 (Palm Beach Cty. Cir. Ct. Oct. 8, 2009). In short, all the key conspirators in Epstein's sexual trafficking ring who could be asked about Derhowitz's involvement took the Fifth.29 This Isjilence is . . . evidence of the most persuasive character." United States ex rd. Biloktanskyl. Tod. 263 U.S.
n such intervention is reviewed only for abuse of discretion. Stone' First Union Corp.. 371 F.3d 1305, 1309 (11th Cir. 2004); see also AT&T Cap. ' Sprint Corp., 407 F.3d 560, 561-62 (2nd Cir. 2005) ("[a] denial of permissive intervention has virtually never been reversed" because of the considerable discret
led under seal by order of Judge unsealed and made public. (15-cv-7433, Dkt. Nos. 362, 550, 935.) Harvard Law professor and criminal defense lawyer Alan Dershowitz, whom publicly alleged of perpetrating sex crimes alongside Epstein, moved to unseal a limited portion of the record in order to clear his name. (
d Law professor and criminal defense lawyer Alan Dershowitz, whom publicly alleged of perpetrating sex crim
arvard Law professor and criminal defense lawyer Alan Dershowitz, whom publicly alleged of perpetratin
Protective Order. Permissive intervention is the appropriate procedural device when any non-party seeks to modify a protective order. AT&T Corp. v. Sprint Corp., 407 F.3d 560, 562 (2d Cir. 2005) ("We have stated that permissive intervention is the proper method for a nonparty to seek a modification of a pro
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
cument 40, 08/20/2020, 2913550, Page4 of 74 Table of Authorities Cases Application of Newsday, Inc., 895 F.2d 74 (2d Cir. 1990) 40 AT&T Corp. v. Sprint Corp., 407 F.3d 560 (2d Cir. 2005) 26 Bernstein v. Bernstein Li towitz Berger & Grossmann LLP, 814 F.3d 132 (2d Cir. 2016) 17 Brown v. Maxwell, 929 F
der seal by order of Judge Sweet unsealed and made public. (15-cv-7433, Dkt. Nos. 362, 550, 935.) Harvard Law professor and criminal defense lawyer Alan Dershowitz, whom Giuffre publicly alleged of perpetrating sex crimes alongside Epstein, moved to unseal a limited portion of the record in order to clear his
d Law professor and criminal defense lawyer Alan Dershowitz, whom Giuffre publicly alleged of perpetrating se
arvard Law professor and criminal defense lawyer Alan Dershowitz, whom Giuffre publicly alleged of perp
Protective Order. Permissive intervention is the appropriate procedural device when any non-party seeks to modify a protective order. AT&T Corp. v. Sprint Corp., 407 F.3d 560, 562 (2d Cir. 2005) ("We have stated that permissive intervention is the proper method for a nonparty to seek a modification of a pro
Entities connected to both Alan Dershowitz and Sprint Corp.

Jeffrey Epstein
PERSONLeon Black
PERSON
Marc Rich
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSON
Paul Cassell
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONMaria Farmer
PERSON
Woody Allen
PERSON
Joe Biden
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION