Epstein Secrets

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

6 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been electronically filed through the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by electronic mai Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Plaintiff, Jones, Esq., Assistant

iled 12/11/2015 06:05:31 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/Counterclaim Defendants, vs. ALAN M. DERSHOWITZ, Defendant/Counterclaim Plaintiff. DEFENDANT/COUNTERCLAIM PLAIN

DLEY J. EDWARDS Defendant/Counterclaim Plaintiff Alan Dershowitz ("Dershowitz") requests that Plaintiff/Counterclaim Defendant Bradley J. Edwards ("Edwards" or "You"), pursuant to Fla. R. Civ. P. 1.350, produce for inspection and/or copying, at the offices of undersigned counsel, the following document

3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been electronically filed through the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by electronic mail (email) at email address: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Pl

iled 12/11/2015 06:05:31 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/Counterclaim Defendants, vs. ALAN M. DERSHOWITZ, Defendant/Counterclaim Plaintiff. DEFENDANT/COUNTERCLAIM PLAIN

TY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs/Counterclaim De

7 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been electronically filed through the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by electronic mail (email) at email address: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Pl

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

8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been electronically filed through the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by electronic mail: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Plaintiff, 2139 Palm Beach

nt/Counterclaim Plaintiff ALAN M. DERSHOWITZ ("Dershowitz") respectfully moves this Court for the entry of an Order that (a) directs Plaintiffs BRADLEY J. EDWARDS ("Edwards") and PAUL G. CASSELL ("Cassell") (together, "Plaintiffs") to make, within ten (10) days of the entry of the Order, a final determination

tiff ALAN M. DERSHOWITZ ("Dershowitz") respectfully moves this Court for the entry of an Order that (a) directs Plaintiffs BRADLEY J. EDWARDS ("Edwards") and PAUL G. CASSELL ("Cassell") (together, "Plaintiffs") to make, within ten (10) days of the entry of the Order, a final determination as to whet

laintiff Cassell, 160 East 300 South, Salt Lake City, Utah 84114, and I electronically filed the foregoing with the Clerk of Broward County by using the Florida Courts eFiling Portal this 24th day of November, 2015. By: s/Thomas E. Scott THOMAS E. SCOTT FBN: 149100 10 EFTA00622844

ed 12/11/2015 05:54:44 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No.: CACE 15-000072 EDWARDS, et at, Plaintiffs / Counterclaim Defendants, vs. DERSHOWITZ, Defendant / Counterclaim Plaintiff. DEFENDANT ALAN M. DERSHOWITZ'S OPPOSITION TO

2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been electronically filed through the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by electronic mail (email) at email address: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Pl

ed 12/11/2015 05:54:44 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No.: CACE 15-000072 EDWARDS, et at, Plaintiffs / Counterclaim Defendants, vs. DERSHOWITZ, Defendant / Counterclaim Plaintiff. DEFENDANT ALAN M. DERSHOWITZ'S OPPOSITION TO

1 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been electronically filed through the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by electronic mail (email) at email address: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Pl