Epstein Secrets

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

on the following using the Court's CM/ECF system: 500 S. Australian Ave., Suite 400 sis s West Palm Reach, FL 33401 Attorneys for the Government Thomas Scott [email protected] ar COLE. SCOTT & KISSANE, P.A. -and- Kendall Coffe Gabriel Groisman Benjamin H. Brodsk COFFEY BURLINGTON. P.L. Atto

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.

, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: [email protected] E-mail: ann.marie.c.villafana@usdojdzov Attorneys for the Government Thomas Scott [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre H 9150 South Dadeland Boulevard, Suite 1400 Miami, Florida 33156 Telephon

t for the record. I may want to mark two things. A. Okay. Q. Exhibit 1 is documented Plaintiff's Response to Motion for Limited Intervention by Alan M. Dershowitz, and I'm going to ask the reporter to mark another exhibit at the same time. This will be Exhibit 2, and this is a document entitled Jane Doe Numb

DRAFT ONLY EFTA00607220 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Sweeder & Ross for Professor Dershowitz. Thereupon, PAUL G. CASSELL, having been first duly sworn, was examined and testified as follows: THE WITNESS: I do. DIRECT EXAMINATION BY MR.

8 19 20 21 22 23 24 25 Sweeder & Ross for Professor Dershowitz. Thereupon, PAUL G. CASSELL, having been first

NAME: BRADLEY J. EDWARDS and PAUL G. CASSELL vs. ALAN M. DERSHOWITZ WITNESS NAME: PAUL G. CASSELL DAT

MR. SIMPSON: Richard Simpson on behalf of Defendant and Counter-Claim Plaintiff Alan Dershowitz. And with me is my colleague Nicole Richardson and Thomas Scott from the firm of Cole Scott & Kissane. Ms. Richardson and I are from the firm of Wiley Rein. MR. SWEDER: Kenneth Sweder from the firm of ROUGH DR

F |S ao FBP WN F- 970 DO DN ODO OT BR W NY — ROUGH DRAFT TITLE ***ROUGH DRAFT TRANSCRIPT *** CASE NAME: BRADLEY J. EDWARDS and PAUL G. CASSELL vs. ALAN M. DERSHOWITZ WITNESS NAME: PAUL G. CASSELL DATE OF DEPOSITION: 10/16/15 This is an unedited, unproofread, | uncertified transcript for attorneys' information o

Oo O DN OO FF WwW NY =| NO RO PO PNP NM NO | S| S| HS SF S| S| S| S| S| non BP WO NO -|- ODO OO WDN OO OT BP WO NYO — Sweeder & Ross for Professor Dershowitz. Thereupon, PAUL G. CASSELL, having been first duly sworn, was examined and testified as follows: THE WITNESS: I do. DIRECT EXAMINATION BY MR. SI

ODO OO WDN OO OT BP WO NYO — Sweeder & Ross for Professor Dershowitz. Thereupon, PAUL G. CASSELL, having been first

NAME: BRADLEY J. EDWARDS and PAUL G. CASSELL vs. ALAN M. DERSHOWITZ WITNESS NAME: PAUL G. CASSELL DAT

. MR. SIMPSON: Richard Simpson on behalf of Defendant and Counter-Claim Plaintiff Alan Dershowitz. And with me is my colleague Nicole Richardson and Thomas Scott from the firm of Cole Scott & Kissane. Ms. Richardson and I are from the firm of Wiley Rein. MR. SWEDER: Kenneth Sweder from the firm of ROUGH DRAF

, 4:01 p.m. (Thereupon, a recess was taken.) THE VIDEOGRAPHER: We are back on the video record, 4:04 p.m. (Thereupon, Kenneth A. Sweder, Esquire, Alan M. Dershowitz and Carolyn Cohen left the proceedings.) ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 420 MR, SCAROLA: The record should reflect that Mr. and Mrs.

fy sealing these presumptively-public documents. L DERSHOWITZ HAS NOT JUSTIFIED SEALING ALLEGED DEFAMATORY RECO

e to speak up. MR. SCOTT: You're going to have to speak up a little bit more, Counsel. MR. INDYKE: Objection. This is Darren Indyke. Anything that Alan might have to say to that, to the extent they are covered under conversations with Jeffrey Epstein, privileged under attorney-client privileges as

UIRE DEPOSITION SOLUTIONS (954) 331-4400 mention Professor Dershowitz's name once. A. I said flight logs. And let's ta

Richard Simpson of Wiley Rein on behalf of the Defendant and Counterclaim Plaintiff, Alan Dershowitz. With me is my colleague, Nicole Richardson, and Thomas Scott of Cole, Scott & Kissane, also for Mr. -~ Professor Dershowitz. MR. SCAROLA: Before we begin the deposition, ESQUIRE DEPOSITION SOLUTIONS (954) 331

ucidate the interface between the Government and the victims. DE 280 at 8-10. In a later pleading (responding to arguments from putative intervenor Alan Dershowitz), the new victims also advanced eight specific reasons why their allegations related specifically to current issues in the case, including issues o

nding to arguments from putative intervenor Alan Dershowitz), the new victims also advanced eight specific r

responding to arguments from putative intervenor Alan Dershowitz), the new victims also advanced eight

certify that the foregoing document was served on February 6, 2015, on the following using the Court's CM/ECF system: Attorneys for the Government Thomas Scott [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre II Kendall Coffey Gabriel Groisman Groisman Benjamin H. Brodsky COFFEY

COFFEY BURLINGTON, P.L. 2601 South Bayshore Drive, PH 1 Miami, Florida 33133 Telephone: (305) 858-2900 Facsimile: (305) 858-5261 Attorneys for Alan Dershowitz /s/ Bradley J. Edwards 4 EFTA00618008

00 Facsimile: (305) 858-5261 Attorneys for Alan Dershowitz /s/ Bradley J. Edwards 4 EFTA00618008

58-2900 Facsimile: (305) 858-5261 Attorneys for Alan Dershowitz /s/ Bradley J. Edwards 4 EFTA006180

, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: [email protected] E-mail: ann.marie.c.villafanaeusdoj.gov Attorneys for the Government Thomas Scott [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre II 9150 South Dadeland Boulevard, Suite 1400 Miami, Florida 33156 Telepho

JANE DOES #2 Plaintiffs, vs. UNITED STATES OF AMERICA, Defendant. ALAN DERSHOWITZ'S SUPPLEMENT TO HIS MOTION FOR LIMITED INTERVENTION (DE 282) Alan M. Dershowitz, a nonparty to this litigation, respectfully supplements his previously filed Motion for Limited Intervention (DE 282), as follows': The rights aff

decision not to federally prosecute Mr. Epstein did not moot their CVRA In the event the Court declines to accept this submission as a supplement to Dershowitz's pending Motion for Limited Intervention (DE 282), he respectfully reserves the right to include this as part of any Reply he might file. We hereb

ffs, vs. UNITED STATES OF AMERICA, Defendant. ALAN DERSHOWITZ'S SUPPLEMENT TO HIS MOTION FOR LIMITE

iffs' counsel, and awarding such other relief that the Court deems just and proper under these unfortunate circumstances. Respectfully submitted, Thomas Scott. Fla. Bar No. 149100 COLE, SCOTT & KISSANE, U. Dadeland Centre H 9150 South Dadeland Boulevard, Stine 1400 Miami, Florida 33156 Telephone: (305

ICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA BRADLEY J. EDWARDS and PAUL G. CASSELL, CASE NO.: 15-000072 Plaintiff(s), JUDGE: LYNCH v. ALAN M. DERSHOWITZ, Defendant. I MOTION FOR RECONSIDERATION OF THIS COURT'S ORDER DENYING NON- PARTY JEFFREY EPSTEIN'S MOTION TO OUASH SUBPOENA Jeffrey Epstein (her

000072 Plaintiff(s), JUDGE: LYNCH v. ALAN M. DERSHOWITZ, Defendant. I MOTION FOR RECONSIDERATION OF TH

NO.: 15-000072 Plaintiff(s), JUDGE: LYNCH v. ALAN M. DERSHOWITZ, Defendant. I MOTION FOR RECONSI

ida 33301 954.337.3716 (facsimile) 9 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• 954.467.1223 EFTA00582769 SERVICE LIST Thomas Scott, Esquire Steven Safra, Esquire COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Ri

/JOHNSON JANE DOE #1 AND JANE DOE #2, Plaintiffs, VS. UNITED STATES OF AMERICA, Defendant. / REPLY IN SUPPORT OF MOTION FOR LIMITED INTERVENTION BY ALAN M. DERSHOWITZ Alan M. Dershowitz hereby replies in support of his Motion for Limited Intervention (DE 282). Prof. Dershowitz’s only interest in joining this case

N FOR LIMITED INTERVENTION BY ALAN M. DERSHOWITZ Alan M. Dershowitz hereby replies in support of his Motion for Limited Intervention (DE 282). Prof. Dershowitz’s only interest in joining this case is to strike the false, sensational and irrelevant allegations against him. In its response (DE 290), the govern

gton.com COFFEY BURLINGTON, P.L. 2601 South Bayshore Drive, PH1 Miami, Florida 33133 Telephone: (305) 858-2900 Facsimile: (305) 858-5261 - and— Thomas Scott, Fla. Bar No. 149100 [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre II 9150 South Dadeland Boulevard, Suite 1400 Miami, Flor