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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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, uncerti

mmon interest privilege with you as counsel in the CVRA case? Had you entered into an agreement with any other attorney? You have co-counsel , Mr. Edwards. MS. McCAWLEY: Well , to the extent that's going to reveal privileged information about accountant interest agreement, I am not going to ROUGH DR

t know that it's directly responsive to your question, but also the Scarola law firm, Mr. Scarola in connection with litigation he was handling for Brad Edwards. Q. Any any other law firm lawyers that you had a common interest privilege with? A. No. Q. And you're going to refuse to answer questions ab

ds and Professor Paul Cassell . With me is Joni J. Jones from the Utah Attorney General's Office. MS. McCAWLEY: Sigrid McCawley on behalf of from Boies Schiller & Flexner. MR. SIMPSON: Richard Simpson on behalf of Defendant and Counter-Claim Plaintiff Alan Dershowitz. And with me is my colleague Nicole Richardson a

nd Amended Counterclaim, attached as Exhibit A, which includes (a) two additional counts for defamation against Plaintiffs / Counterclaim Defendants Bradley J. Edwards ("Edwards") and Paul G. Cassell ("Cassell") (together, "Plaintiffs"); (b) additional, recently discovered facts in support of Dershowitz's defamatio

DERSHOWITZ'S MOTION FOR LEAVE TO AMEND COUNTERCLAIM AND FOR LEAVE TO ASSERT CLAIM 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

ell made up the story. Whether ]'s statements are true or not — and we believe them to be trite — it really doesn't make a difference as to whether Brad Edwards and Paul Cassell reasonably believed them to be true" (emphasis added). This statement constitutes another extra-judicial statement on behalf of Edw

sel for Plaintiff Cassell to: o: Joni J. S to: Bradley J. Edwards, Esq, Farmer, Jaffe et al, Paul G. Cassell, Esq.,; Sigrid S. McCawley, Esq., Boies Schiller & Flexner, LLP, this day of February, 2016. By: sffhomas E. Scott THOMAS E. SCOTT FBN: 149100 17 to: 0: EFTA00613407 EXHIBIT A EFTA00613408 IN T

of 09:31:40 4 October, 2015. The time is approximately 9:31 5 a.m. This is the videotaped deposition of Alan 6 M. Dershowitz in the matter of Bradley J. 7 Edwards and Paul Cassell versus Alan M. 8 Dershowitz. This deposition is being held at 9 110 Southeast 6th Street, Suite 1850, Fort 10 Lauderdale, Flor

r the record. 16 MR. SCAROLA: My name is Jack Scarola. 09:31:48 17 I'm counsel on behalf of Bradley Edwards and 18 Professor Paul Cassell. Mr. Edwards and 19 Mr. Cassell are also present. 20 Also with us from the Utah Attorney 09:31:58 21 General's office is Joni Jones. 22 MS. McCAWLEY: Sig

:35 EFTA00601195 43 1 Go ahead. 10:18:36 2 A. Absolutely. If you ask me the question, I 10:18:37 3 am directly charging Judge Cassell and Bradley 4 Edwards with suborning perjury. I have been advised 5 that did not want to mention me, 6 told her friends that she did not want to mention 7 me. And w

us from the Utah Attorney 09:31:58 21 General's office is Joni Jones. 22 MS. McCAWLEY: Sigrid McCawley. I'm with 09:32:06 23 the law firm of Boies Schiller & Flexner on 24 behalf of 25 MR. SCOTT: Good morning. Tom Scott on 09:32:12 EFTA00601158 6 1 behalf of the Defendant Professor Dershowitz. 2 MR. SIM

M MO NM DB NYO NB HF HF HF AF BF HF Fe Fe HF |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, | uncertif

a common interest privilege with you as counsel in the CVRA case? Had you entered into an agreement with any other attorney? You have co-counsel, Mr. Edwards. MS. McCAWLEY: Well, to the extent that's going to reveal privileged information about accountant interest agreement, I am not going to ROUGH DRAF

question. BY MR. SIMPSON: Q. Who, as your understanding as of December 30th of 2014, with which attorneys did you have a common interest privilege? A. Brad Edwards from, obviously, the law firm that I've been working with here. Also attorneys from the Boies Schiller law firm who were representing Virginia Robert

sor Paul Cassell. With me is Joni J. Jones from the Utah Attorney General's Office. MS. McCAWLEY: Sigrid McCawley on behalf of Virginia Roberts from Boies Schiller & Flexner. MR. SIMPSON: Richard Simpson on behalf of Defendant and Counter-Claim Plaintiff Alan Dershowitz. And with me is my colleague Nicole Richardson and

-Filed 11/23/2015 05:53:31 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, vs. ALAN M. DERSHOWITZ, Defendant. / PLAINTIFFS/COUNTERCLAIM DEFENDANT EDWARDS AND CASSELL’S RESPONSE TO DERSHOWI

ASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, vs. ALAN M. DERSHOWITZ, Defendant. / PLAINTIFFS/COUNTERCLAIM DEFENDANT EDWARDS AND CASSELL’S RESPONSE TO DERSHOWITZ’S MOTION TO DETERMINE CONFIDENTIALITY OF COURT RECORDS Plaintiffs/Counterclaim Defendants Bradley J. Edwards an

ous adult when she flew on that airplane. Q. You were asked on the occasion of that same Don Lemon CNN interview what possible motive the attorneys, Brad Edwards and Paul Cassell, could have had to have identified you in the pleading that was filed in the Crime Victim's Rights Act case. _ warn nw be wn Bb N

tiality of Court Records Page 20 of 20 COUNSEL LIST Sigrid Stone McCawley, Esquire [email protected]; [email protected]; [email protected] Boies Schiller & Flexner, LLP 401 E Las Olas Boulevard., Suite 1200 Fort Lauderdale, FL 33301 Phone: (954)-356-0011 Attorneys for Alan M.Dershowitz, Esquire Thomas Emers

led 11/24/2015 04:32:20 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, vs. ALAN M. DERSHOWITZ, Defendants. PLAINTIFFS' REOUEST FOR PRODUCTION TO DEFENDANT (PUNITIVE DAMAGES) BRADL

, diary entries, desk calendar entries, reported recollections and other written form of EFTA00602638 Edwards, Bradley vs. Dershowitz Plaintiffs, Edwards and Cassell, Request to Produce to Def. (Punitive Damages) Case No.: CACE 15-000072 Page 2 notation of events or intentions, transcripts and recor

) Case No.: CACE 15-000072 Page 13 COUNSEL LIST Sigrid Stone McCawley, Esquire [email protected]; [email protected]; [email protected] Boies Schiller & Flexner, LLP 401 E Las Olas Boulevard., Suite 1200 Fort Lauderdale, FL 33301 Phone: (954)-356-0011 Thomas Emerson Scott, Jr., Esquire Thomas.scott@cskle

Filing # 36323883 E-Filed 01/08/2016 12:18:27 PM BRADLEY J. EDWARDS and PAUL G. CASSELL, IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA Plaintiff's/Counterclaim Defen

323883 E-Filed 01/08/2016 12:18:27 PM BRADLEY J. EDWARDS and PAUL G. CASSELL, IN THE CIRCUIT COURT OF TH

Esq, Farmer, Jaffe et al, 425 North Andrews Avenue, Suite 2, Ft. Lauderdale, FL 33301; to: Paul G. Cassell, Esq.,: to: Sigrid S. McCawley, Esq., Boies Schiller & Flexner, LLP, 401 E. Las Olas Blvd, Suite 1200, Ft. Lauderdale, FL 33301, this 8th day of January, 2016. By: sffhornas E. Scott Thomas E. Scott FBN: 1491

E OF REPORTER 157 9 i VOLUME 2 (Pages 158 - 258) | VIDEOTAPED DEPOSITION OF TONY FIGUEROA 10 ; lime TFS TONY FIGUEROA | dd. Cross-Examination by Mr. Edwards 162 i Pages 1- 157 Redirect Examination by Ms. Menninger 218 ' 12 Recross-Examination by Mr. Edwards 243 Taken at the Instance of the Defendant Furth

osition wou e waived. Page 2 Page 4 1 APPEARANCE OF COUNSEL 1 INDEX OF EXHIBITS | 2 2 | 3 3 4 ON BEHALF OF THE PLAINTIFF: MARKED BY THE DEFENDANT:) 5 BRADLEY J. EDWARDS, Esquire Defendant's Exhibit 1 42 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 5 (Palm Beach County Sheriff's Reports - i 6 425 North And

XWELL, Defendant. ee re ee 7 x May 18, 2016 9:04 a.m. CONFIDENTIAL Deposition of Po pursuant 4 to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Not

lp.com; [email protected]; [email protected] Boies Schiller & Flexner, LLP 401 E Las Olas Boulevard., Suite 1200 Fort

Lake City, Utah 84114; [email protected] to: Bradley J. Edwards, Esq, Farmer, Jaffe et al, 425 North Andrews Aven

BREAK --- BACKGROUND The underlying action before this Court is a defamation case filed by a former federal judge, Paul Cassell, and his colleague Brad Edwards, who represent various sexual trafficking victims in a case pending in the Southern District of Florida, specifically case no. 08-cv-80736- KAM, here