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PAUL G. CASSELL, Plaintiffs/Counterclaim Defendants, vs. ALAN M. DERSHOWITZ, Defendant/Counterclaim Plaintiff. DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN M. DERSHOWITZ'S MOTION FOR LEAVE TO AMEND COUNTERCLAIM AND FOR LEAVE TO ASSERT CLAIM FOR PUNITIVE DAMAGES AGAINST PLAINTIFFS/COUNTERCLAIM DEFENDANTS EDWARDS AND C
LAIM FOR PUNITIVE DAMAGES AGAINST PLAINTIFFS/COUNTERCLAIM DEFENDANTS EDWARDS AND CASSELL Defendant and Counterclaim Plaintiff, Alan M. Dershowitz ("Dershowitz"), pursuant to Florida Rules of Civil Procedure 1.170(a), 1.170(e), 1.190(a) and 1.190(f) and Florida Statute § 768.72, hereby respectfully moves t
cooperate and give me those names. But I very much believe that there were going to be other girls who would come forward and swear under oath that Alan Ders ' bused them in exactly the same ■ as he had sexually abuse See Cassell Tr. Vol. I, at 36:20-37:1 and 60:5-10 (emphasis added). • When questio
SSELL, Plaintiffs/Counterclaim Defendants, vs. ALAN M. DERSHOWITZ, Defendant/Counterclaim Plaintiff.
he pleading are not privileged because they were totally irrelevant to the proceeding before the federal court. Indeed, United States District Judge Kenneth Main I EFTA00613409 has held that the "lurid" allegations about Dershowitz were "unnecessary," "immaterial," and "impertinent," and ordered them stri
should be charged with four counts of unlawful sex with minors and one molestation count.12°I His team of defense lawyers included Gerald Lefkourt, Alan Dershowitz and later Ken Starr." Epstein passed a polygraph test in which he was asked whether he knew of the underage status of the girls.I231 After the feder
cover-up.r ‘ i Roberts said she served as Epstein's sex slave horn 1999 to 2002. and recruited other under-age girls.1" 1 Prince Andrew. Epstein and Dershowitz all deny having had sex with Roberts. Dershowitz reportedly was taking legal action over the allegations."" °I A diary purported to belong to Robert
om 1973 to 1975. Among his students was a son of Alan C. Greenberg, chairman of Bear Steams. In 1976,
nvlelogstuncleatharadar(2014112thoundiling- levels-sex-elaims-abalamchrshowitz-200495 htin1). Pa WM 39. Murphy. Sean P. (April 7.2015). 'Judge drops Dershowirz from Jansen involving 'lurid allegations (Mtprilwww.hostongthbeimmtmetra20193407dridge.drops. dershowitz-from-lawsuit-involving-lurid- alkgationsi
nformation of material witnesses and additional victims'?" Solt against federal government re: plea deal In a separate case, on April 7.2015, Judge Kenneth Main ruled that the allegations made by Virginia Roberts against Prince Andrew had no bearing on a current (and longrunning) lawsuit by alleged victims s
should be charged with four counts of unlawful sex with minors and one molestation countl29I His team of defense lawyers included Gerald Lefiourt. Alan Dershowitz and later Ken Starr." " Epstein passed a polygraph test in which he was asked whether he knew of the underage status of the gjris.113I After the fe
in a cover-up.tf01 Roberts said She served as Epstein's sex slave from 1999 to 2002, and recruited Mita under-age girls." Prince Andrew. Epstein and Dershowitz all deny having had sex with Roberts. Dershowltz reportedly was taking legal action over the allegations.""G)I A diary purposed to belong to Roberts
om 1973 to 1975. Among his students was a son of Alan C. Greenberg, chairman of Bear Steams. In 1976,
lalogstunOratharadarf3014112.thoun-filing- levels-sex-elaims-abalarwchtshowite-200495 htin1). Pa WM 39. Murphy. Sean P. (April 7.20151. "Judge drops Dershowirz from Jansen involving 'laid allegations (Mtpseiwww.bostenglabe.eantmona:20193407Sudge.drops. dershowitz-fram4awsuibinvolving4urid- alkgationsirWSS
ation of material witnesses and additional victims'.129r" Suit against federal government re: plea deal In a separate case, on April 7, 2015, Judge Kenneth Main ruled that the allegations made by Virginia Roberts against Prince Andrew had no bearing on a current (and longrunning) lawsuit by alleged victims s
in a 53-page indictment in June 2oo7.- Alexander Acosta, then the U S. Attorney for the Southern District of Florida, agreed to a plea deal, which Alan Dershowitz helped to negotiate, ag to grant immunity from all federal criminal charges to Epstein, along with four naiRed co-conspirators sand any unnamedillp
s to that case.11321 The addition accused Alan Dershowitz of sexually abusing a minor, Jane Doe 3, provided by Epstein ['331 The allegations against Dershowitz were stricken by the judge and eliminated from the case because he said they were outside the intent of the suit to re-open the plea agreement. WAI
laintiffs to that case.11321 The addition accused Alan Dershowitz of sexually abusing a minor, Jane Doe
l On February 21, 2019, in the case of Two Jane Does v. United States, Senior Judge of the U.S. District Court for the Southern District of Florida Kenneth Main said federal prosecutors violated the law by failing to notify victims before they allowed him to plead guilty to only the two Florida offenses. Th
later unsuccessful effort to add Virginia Roberts (Jane Doe 3) and another woman (Jane Doe 4) as plaintiffs to that case.11321 The addition accused Alan Dershowitz of sexually abusing a minor, Jane Doe 3, provided by Epstein.in31 The allegations against Dershowitz were stricken by the judge and eliminated from
fs to that case.11321 The addition accused Alan Dershowitz of sexually abusing a minor, Jane Doe 3, provided by Epstein.in31 The allegations against Dershowitz were stricken by the judge and eliminated from the case because he said they were outside the intent of the suit to re-open the plea agreementil341
laintiffs to that case.11321 The addition accused Alan Dershowitz of sexually abusing a minor, Jane Doe
pending in federal court, aimed at vacating the federal plea agreement on the grounds that it violated victims' rights.1131/ on April 7, 2015, Judge Kenneth Main ruled that the allegations made by alleged victim Virginia Roberts against Prince Andrew had no bearing on the lawsuit by alleged victims seeking t
Entities connected to both Alan Dershowitz and Kenneth Main

Jeffrey Epstein
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Lesley Groff
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
Virginia Giuffre
PERSONWeiss
PERSON
Barry Diller
PERSON
Scarlett Johansson
PERSON
Department of Justice
ORGANIZATION