Epstein Secrets

edacted, with the 21 exception of Does 1 and 2, Professor Dershowitz, and in 22 deposition testimony already unseale

1 and 2 should 8 be unsealed. 9 Additionally, Alan Dershowitz's name and information 10 identifyin

eir names in this case's documents. Accordingly, 7 the names and identifying information for Does 1 and 2 should 8 be unsealed. 9 Additionally, Alan Dershowitz's name and information 10 identifying him may be unsealed. By his letter at docket entry 11 1138, he has requested that redactions of his name in t

specific comment, personal identifying 20 information for all nonparty Does should be redacted, with the 21 exception of Does 1 and 2, Professor Dershowitz, and in 22 deposition testimony already unsealed by the Court of Appeals. 23 The other names of Does and identifying information 2.1 will remai

ARANCES BOIES SCHILLER & FLEXNER LLP Attorneys for Plaintiff BY: SIGRID S. McCAWLEY HADDON MORGAN and FOREMAN, P.C. Attorneys for Defendant BY: LAURA A. MENNINGER HOLLAND & KNIGHT Attorneys for Intervenors Julie Brown and Miami Herald Media Company BY: CHRISTINE N. WALZ KRIEGER KIM & LEWIN, LLP Attorneys

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

, 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 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00075527 Case 20-2413, Document40,08/20/2020. 2913550. Page52 o

e that's at issue in this case, our client said, "Now her 6 story has grown and evolved, and she's included allegations 7 about world leaders and Alan Dershowitz, which he denies." We 8 can't just take that part out of her statement, that's what 9 Ms. Maxwell put in her statement. 10 And your Honor, what

at statement, 6 so there's no substantive evidence on that point that would be 7 coming in. 8 And the third category is with respect to 9 Mr. Dershowitz, who is on the defendant's witness list for 10 trial, and we have a few points there to raise. I mean, one is 11 obviously that if that were allo

included allegations 7 about world leaders and Alan Dershowitz, which he denies." We 8 can't just t

UTAH For Plaintiff 18 BY: PAUL G. CASSELL, ESQ. 19 HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant 20 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794556 2 H3VOGIU1 1 (Case called) 2 THE COURT: Like all of

he one that's at issue in this case, our client said, "Now her story has grown and evolved, and she's included allegations about world leaders and Alan Dershowitz, which he denies." We can't just take that part out of her statement, that's what Ms. Maxwell put in her statement. And your Honor, what we will u

at statement, 6 so there's no substantive evidence on that point that would be 7 coming in. 8 And the third category is with respect to 9 Mr. Dershowitz, who is on the defendant's witness list for 10 trial, and we have a few points there to raise. I mean, one is 11 obviously that if that were allo

arate lawsuit that's spun out of this situation where Cassell and Edwards filed a defamation action in Florida State Court against Alan Dershowitz. Alan. Dershowitz then counterclaimed. That was litigated in Florida State Court for about a year. Ultimately, the parties settled their differences in

IVERSITY OF UTAH For Plaintiff BY: PAUL G. CASSELL, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00612250 H3VOGIU1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19

ent Right, sir. Q. Have you socialized with Alan Dershowitz? A. Yes, sir. He's my attorney, as well as a 832-

r de Roshi Mchiwn. Jerome Pierre (Gardner) M- F Alan Stopeck Landscape designer, Checks the garden Fra

like to answer that question, at least today I'm going to have to assert my Fifth, Sixth and 14th Amendment Right, sir. Q. Have you socialized with Alan Dershowitz? A. Yes, sir. He's my attorney, as well as a 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (40

[email protected] 8 Defendant's Exhibit 3 7 9 (Two Pictures of Apartment Building) i 9 10 ON BEHALF OF THE DEFENDANT: Defendant's Exhibit 4 83 il LAURA A. MENNINGER, Esquire 0 (Palm Beach County Sheriff's Reports - | Haddon, Morgan and Foreman, P.C. Case Number 02075321) 12 oe Fas ae 03 Defendant's Exhibit 5 134

arate lawsuit that's spun out of this situation where Cassell and Edwards filed a defamation action in Florida State Court against Alan Dershowitz. Alan Dershowitz then counterclaimed. That was litigated in Florida State Court for about a year. Ultimately, the parties settled their differences in an undisclose

ere to make that statement, so there's no substantive evidence on that point that would be coming in. And the third category is with respect to Mr. Dershowitz, who is on the defendant's witness list for trial, and we have a few points there to raise. I mean, one is obviously that if that were allowed to c

e's included allegations about world leaders and Alan Dershowitz, which he denies." We can't just take

THE UNIVERSITY OF UTAH For Plaintiff BY: PAUL G. CASSELL, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT R (212) 805- PORT 0300 ERS, HOUSE_OVERSIGHT_011304 10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25

reading of that document, the press release by Barden and Gow, is that she's talking about the allegations against her, Maxwell, and she includes Dershowitz, and that's essentially it. I mean, she's not parsing through the 102 pleading and saying, you know, this is wrong and that is wrong. And the funda

.L. Attorneys for Plaintiff BY: BRADLEY J. EDWARDS, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT REPORTERS, P.C. EFTA00592369 H3ulgiva (Case called) THE COURT: We have a problem, folks. By my count 4 5 6 7 8 9

7 Case 20-2413, Document 10-9,07/30/2020, 2896538, Page8 of 17 K7N9GIUD 4 5 already public. 165-8. Excerpts from Ms. deposition taken in the Dershowitz matter on January 16, 2016. Unseal. 165-10. Copy of e-mail correspondence. Unseal. 165-11. Excerpts from Ms. deposition, 6 May 3, 2016. Unseal.

, 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 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. EFTA00074941 Case 20-2413, Document 10-9,07/30/2020, 2896538, Page2 of 17 K7N9GIUD

that 21 document, the press release by Barden and Gow, is that she's 22 talking about the allegations against her, Maxwell, and she 23 includes Dershowitz, and that's essentially it. I mean, she's 24 not parsing through the 102 pleading and saying, you know, this 25 is wrong and that is wrong. And t

ys for Plaintiff 20 BY: BRADLEY J. EDWARDS, ESQ. 21 HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant 22 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. EFTA00794367 (212) 805-0300 EFTA00794368 2 H3ulgiva 1 2 (Case called) 3 THE COURT: W