Epstein Secrets

tem 18 then is defamation litigation. And your Honor is aware that there was a separate lawsuit that's spun out of this situation where Cassell and Edwards filed a defamation action in Florida State Court against Alan Dershowitz. Alan. Dershowitz then counterclaimed. That was litigated in Florida Stat

forth because we think it's irrelevant. But if there was to be some kind of an attack launched on any of the members of the Boies Schiller Firm, of Brad Edwards, myself, we would ask that we be given leave to address that at sidebar, in-camera, or outside the presence of the jury SOUTHERN DISTRICT REPORTERS

no reason we should be allowed to ask about all these 14 other bad acts. 15 Sack cites, your Honor, to an Eleventh Circuit case, 16 Schafer vs. Time, Inc. In that case, your Honor, Sack says the 17 Eleventh Circuit found the district court had been correct when 18 it ruled that the defendant, which

tem 18 then is defamation litigation. And your Honor is aware that there was a separate lawsuit that's spun out of this situation where Cassell and Edwards filed a defamation action in Florida State Court against Alan Dershowitz. Alan Dershowitz then counterclaimed. That was litigated in Florida State

forth because we think it's irrelevant. But if there was to be some kind of an attack launched on any of the members of the Boies Schiller Firm, of Brad Edwards, myself, we would ask that we be given leave to address that at sidebar, in-camera, or outside the presence of the jury SOUTHERN DISTRICT REPORTERS

ere is just no reason we should be allowed to ask about all these other bad acts. Sack cites, your Honor, to an Eleventh CircuLt case, Schafer vs. Time, Inc. In that case, your Honor, Sack says the Eleventh Circuit found the district court had been correct when it ruled that the defendant, which allegedl

occurs in the United States." Burnett II, 292 F.Supp2d at 19 n. 4 (quoting Tel-Oven v. Libyan Arab Republic, 726 F.24 774, 775 (D.C.Cir.1984)) (Edwards, J., concurring) (some emphasis omitted). Courts in the Second Circuit seem to take the opposite approach. "Although cast in terms that may be re

in intentional wrongdoing—albeit extraterri- torially—expressly directed at forum") (citing Calder v. Jones, 465 U.S. at 789-90, 104 S.Ct. 1482)); Time, Inc. v. Simpson, No. 02 Civ. 4917(MBM), 2003 WL 23018890, at *5 (S.D.N.Y. Dec. 22, 2003) (finding Calder turned on "personal in- volvement of the indiv

hen is defamation litigation. And your Honor 10 is aware that there was a separate lawsuit that's spun out of 11 this situation where Cassell and Edwards filed a defamation 12 action in Florida State Court against Alan Dershowitz. Alan 13 Dershowitz then counterclaimed. That was litigated in Florid

no reason we should be allowed to ask about all these 14 other bad acts. 15 Sack cites, your Honor, to an Eleventh Circuit case, 16 Schafer vs. Time, Inc. In that case, your Honor, Sack says the 17 Eleventh Circuit found the district court had been correct when 18 it ruled that the defendant, which

essment rere memeneistseee 13, 28 S.E.C. v. Collins & Aikman Corp., 256 F.R.D. 403, 412 (S.D.N-Y. 2009) oo. ceeeeeecesteeteeteeeeeeeees 19 Schafer v. Time, Inc., 142 F.3d 1361, 1364-75 (1 1th Cir. 1998) oo. eee ceseesseesseeeseeeseeeseeeneessaee 3 Seligson, Morris & Neuburger v Fairbanks Whitney Corp., 257 N

et BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 P| Ft. Lauderdale, FL 33301 J. Stanley Pottinger Bradley J. Edwards 49 Twin Lakes Rd. FARMER, JAFFE, WEISSING, EDWARDS, — South Salem, NY 10590 FISTOS & LEHRMAN, P.L. Po 425 North Andrews Ave., Ste. 2 Ft. — FL 33301

2015 WL 3533844, at *5 (D. Utah i eb) 13,28 S.E.C. v. Collins & Aikman Corp., 256 F.R.D. 403, 412 (S.D.N.Y. 2009) oo. cccccteeeseeeee 19 Schafer v. Time, Inc., 142 F.3d 1361, 1364-75 (11th Cir. 1998) oo ccceeeeeseteeteesetseteeteesenes 3 Seligson, Morris & Neuburger v Fairbanks Whitney Corp., 257 N.Y.S.2d

th Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 [email protected] [email protected] Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] Paul G. C