3
Shared Docs
3
Same-Page
6 / 3
Mentions
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
ely promoting story to the press. Various national and 21 EFTA00613429 international media outlets re-published this extra-judicial statement by Cassell and Edwards, in whole or in part, including but not limited to Business Insider, CNN, The Wall Street Journal, The Salt Lake Tribune, KSL Newsradio, The Huffin
From: (USAFLS)" <=1MIIM> To: (USAFLS)" Cc: 'ar, 'at" . (USAFLS)" Subject: Conference Call with Paul Cassell and Brad Edwards Date: Wed, 27 Oct 2010 16:31:04 +0000 Importance: Normal Willy and Ben, Marie and I just finished a conference call with Brad Edwards and Paul Ca
of such a motion would add to the "atmospherics" of delay by the victims. He even accused the government of "sandbagging" them. I told Cassell and Edwards that I would have to consult with the Executive Division on whether we would permanently forego filing a motion to dismiss for lack of prosecution.
end time is our forebearance from filing a motion to dismiss for lack of prosecution. There is no guarantee that any meetings between our office and Cassell and Edwards will resolve this matter, given what they seek. We may be in the same position again thirty days from now. We told Cassell and Edwards we would get
Subject: Emails in possession of Cassell and Edwards Date: Thu, 28 Oct 2010 20:03:21 +0000 Importance: Normal You had asked earlier about the emails that Cassell and Edwards have. Before Epstein's a
20:03:21 +0000 Importance: Normal You had asked earlier about the emails that Cassell and Edwards have. Before Epstein's attorneys pr uced them to Cassell and Edwards, they gave some items to me for review. I don't know if it is the complete production, but I still have those items electronically. They are very la
Entities connected to both Bradley Edwards and Cassell and Edwards