Epstein Secrets

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:

g any alleged illegal activity involving Plaintiff from the Relevant Period. This request includes, but is not limited to, any documents concerning the Roadhouse Grill in Florida. RESPONSE: Ms. Maxwell objects to this Request as vague and confusing. Ms. Maxwell is unaware of all illegal activities in which Plainti

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

at entire time. 20 It got quashed because it had been such a long passage of time. 21 THE COURT: Who was the employer? 22 MS. MENNINGER: It was the Roadhouse Grill, your 23 Honor. It was a burger joint. And she was working at that 24 Roadhouse Grill in March of 2002 during the period of time she 25 claims

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

try during that entire time. It got quashed because it had been such a long passage of time. THE COURT: Who was the employer? MS. MENNINGER: It was the Roadhouse Grill, your Honor. It was a burger joint. And she was working at that Roadhouse Grill in March of 2002 during the period of time she claims that she was