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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
he pleading are not privileged because they were totally irrelevant to the proceeding before the federal court. Indeed, United States District Judge Kenneth Main I EFTA00613409 has held that the "lurid" allegations about Dershowitz were "unnecessary," "immaterial," and "impertinent," and ordered them stri
emands at his mansion in New York City and on his private Caribbean island, Iittl! Saint James. The suit was settled in 2018 under undisclosed te- Bradley Edwards' defamation v. Epstein (2018) A state civil lawsuit in Florida filed by attorney Bradley Edwards against Epstein was scheduled for trial in December
opportunity to make their accusations in public. However, the case was settled on the first day of the trial, with Epstein publicly apologiLing to Edwards; other terms of the settlement were confidential.W7-0§31 eta Epstein was accused of sex trafficking of minors at his mansion at ?1st Street.
l On February 21, 2019, in the case of Two Jane Does v. United States, Senior Judge of the U.S. District Court for the Southern District of Florida Kenneth Main said federal prosecutors violated the law by failing to notify victims before they allowed him to plead guilty to only the two Florida offenses. Th
mansion in New York City and on his private Caribbean island, Little Saint James. The suit was settled in 2018 under undisclosed firms igti0)[}64 Bradley Edwards' defamation it.. Epstein (2018) A state civil lawsuit in Florida filed by attorney Bradley Edwards against Epstein was scheduled for trial in Decemb
opportunity to make their accusations in public. However, the case was settled on the first day of the trial, with Epstein publicly apolo,,,king to Edwards; other terms of the settlement were confidentiagnal et -Liela Epstein was accused of sex U CI acing of minors at his mansion at 9 East 71st Str
pending in federal court, aimed at vacating the federal plea agreement on the grounds that it violated victims' rights.1131/ on April 7, 2015, Judge Kenneth Main ruled that the allegations made by alleged victim Virginia Roberts against Prince Andrew had no bearing on the lawsuit by alleged victims seeking t
Entities connected to both Bradley Edwards and Kenneth Main

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSONLeon Black
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSON
Bill Clinton
PERSON
Virginia Giuffre
PERSON
Lesley Groff
PERSONRoy Black
PERSON