Epstein Secrets

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.

Amended Counterclaim, which expands on the factual allegations of Edwards's and Cassell's tortious conduct in several ways: • First, the proposed Second Amended Complaint asserts an additional count for defamation based on the attorneys' actions in asserting the unsubstantiated and irresponsible allegation that Dersh

ivities on EPSTEIN's aircraft (¶ 32(1)); sending letters asking for deposition dat4 for the deposition of TV personality Donald Trump, law professor Alan Dcrshowitz, magician David Copperfield, and other individuals who were without any knowledge of relevant eviarnce about EPSTEIN's sex offenses (¶ 32(2)); subp

ment that EPSTEIN abused underage children everywhere, including his airplanes, and that EP' TEIN's pilots and certain other individuals, including Dershowitz, had information relevant to EPSTEIN's repeated abuse of underage girls. mo As yet another example, EPSTEINalleges that EDWARDS had no basis for fi

ion of TV personality Donald Trump, law professor Alan Dcrshowitz, magician David Copperfield, and othe

and prosecute against El) ARDS and the pending, closely related counterclaims. FACTUAL BACKGROUND Plaintiff/Counterdefendant, EPSTEIN has filed a Second Amended Complaint against ED ARDS. The complaint challenges EDWARDS' professionalism as an attorney rep enting girls who had been sexually abused. In particular,

otified Defendant that he intended to take the depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul); (ii) Alan Dershowitz (noted Harvard Law professor, constitutional attorney . and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of t

al-estate magnate and business mogul); (ii) Alan Dershowitz (noted Harvard Law professor, constitutional atto

Civil Actions. 19. Miami attorney and developer, Alan Sakowitz, was quoted in a November 2009 article

int In April 2009, after EDWARDS Joined RRA, the allegations against EPSTEIN in ■.'s complaint became even more salacious. In paragraph 12 of ■.'s Second Amended Complaint, II. alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . . .the then minor Plaintiff to commit various acts of sexu

otified Defendant that he intended to take the depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul); (ii) Alan Dershowiti (noted Harvard Law professor, constitutional attorney and one of EPSTEIN'S criminal defense attorneys); ill Clinton (Former President of the United

Civil Actions. 19. Miami attorney and developer, Alan Sakowitz, was quoted in a November 2009 article

aint in April 2009, after EDWARDS joined RRA, the allegations against EPSTEIN in <SL7 complaint became even more salacious. In paragraph 12 of .'s Second Amended Complaint, L.M. alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . . .the then minor Plaintiff to commit various acts of sexu

tz, P.A. Counsel for Plaintiff Jane Doe #1 Jack Alan Goldberger Atterbury Goldberger & Weiss. P.A. C

s ability to earn a living and be self-supporting has not only a financial component, but also an emotional/psychological/mental component. In her Second Amended Complaint, Plaintiff attempts to allege claims in Count I for "Sexual Assault and Battery," Count II for "Intentional Infliction of Emotional Distress," and

FL 33160 Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 2

nfidentiality of the information obtained through discovery. The evidence sought is relevant based on the facts and theories of this action. In her Second Amended Complaint, Plaintiff attempts to allege claims in Count I for "Sexual Assault and Battery," Count II for "Intentional Infliction of Emotional Distress," and

each Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss,

lving your misconduct with minor females. Answer: If there is a contract for legal services relating to the damages claimed by Mr. Epstein in his Second Amended Complaint, it will be produced. Plaintiff objects to producing any and all other contracts for legal services in the defense of criminal charges or other civi