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e allegations are wholly impertinent to the issues in the Joinder Motion or the Federal Action more generally. Indeed, United States District Judge Kenneth Marra has already concluded — in an unchallenged order that is binding on Edward and Cassell in this action — that the allegations were "unnecessary," "i
r at the very least were "grossly negligent" in defaming Dershowitz, which would support his claim for punitive damages: • On April 7, 2015, Judge Marra expressly held that "lurid" allegations about Dershowitz are "impertinent" to the issues in the federal proceeding and ordered them to be stricken
claim for punitive damages: • On April 7, 2015, Judge Marra expressly held that "lurid" allegations about D
deny Dershowitz's request. 15 EFTA00613405 Respectfully submitted, s/ Thomas E. Scott Steven R. Safra, FBN 057028 COLE, SCOTT & KISSANE, P.A. Richard A. Simpson (pro hac vice) Ma E. Bo 'a ro hac vice) Ashle E. Filer ro hac vice) Nicole Audet Richardson (pro hac vice) Counsel for Alan M. Dershowitz 16 E
ral part of the civil proceeding, particularly when the condition is asserted as an issue by the party seeking closure” (emphasis added)). Il. JUDGE MARRA’S ORDER IN HIS CASE DOES NOT REQUIRE THAT THE RECORDS BE SEALED IN THIS CASE. Dershowitz also appears to contend that Judge Marra’s order striking s
he party seeking closure” (emphasis added)). Il. JUDGE MARRA’S ORDER IN HIS CASE DOES NOT REQUIRE THAT THE REC
Dershowitz's Motion to Determine Confidentiality of Court Records Page 19 of 20 Phone: (305)-350-5329 Fax: (305)-373-2294 Attorneys for Defendant Richard A. Simpson (pro hac vice) [email protected] Mary E. Borja (pro hac vice) [email protected] Ashley E. Eiler (pro hac vice) [email protected] WILEY
ncluding Prince Andrew. That the allegations were improper and irresponsible is not merely an assertion by Dershowitz; United States District Judge Marra has expressly held that the "lurid" allegations were "unnecessary," "immaterial," and "impertinent" to the federal lawsuit. See Exhibit A. Judge Mar
assertion by Dershowitz; United States District Judge Marra has expressly held that the "lurid" allegations w
E, SCOTT & KISSANE, Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson admittec i ce Mary E. Botja (admittet ice) Ashley E. Eiler (admitted m ro/ r tc 4ce) WILEY REIN LLP 1776 K Street NW Washington, DC 20006
assertion by Dershowitz; United States District Judge Marra has expressly held that the "lurid" allegations w
ncluding Prince Andrew. That the allegations were improper and irresponsible is not merely an assertion by Dershowitz; United States District Judge Marra has expressly held that the "lurid" allegations were "unnecessary," "immaterial," and "impertinent" to the federal lawsuit. See Exhibit A. Judge Mar
E, SCOTT & KISSANE, Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson (admitted pro hac vice) Mary E. Borja (admitted pro hac vice) Ashley E. Eiler (admitted pro hac vice) WILEY REIN LLP 1776 K Street NW Washing
United States of America Case No. 08-80736-CIV-MARRA/JOHNSON, [ECF No. 291-1] (the "Federal Action").
E, P.A. Cole, Scott & Kissane Building, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson [email protected] Mary E. Botja [email protected] Ashley E. Eiler [email protected] WILEY REIN LLP 1776 K Street NW Washington, DC
r Rule 21, Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla. Apr. 7, 2016). I declare under
Page: HOUSE_OVERSIGHT_014800 →IBIT R HOUSE_OVERSIGHT_014843 --- PAGE BREAK --- Case 1:15-cv-07433-RWS Document 751-18 Filed 03/17/17 Page 2 of 3 FOR IMMEDIATE RELEASE Contact: Richard A. Simpson, [email protected] April 8, 2016 Lawyers Acknowledge Mistake In Filing Sexual Misconduct Charges Against Professor Dershowitz Professor Alan M
Page: HOUSE_OVERSIGHT_014844 →16, 39, and 49. " DE 293, in its entirety. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 6" day of April, 2015. KENNETH A. MARRA United States District Judge 10 HOUSE_OVERSIGHT_014856
Page: HOUSE_OVERSIGHT_014856 →SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson (pro hac vice) [email protected] Marty E. Borja (pro hac vice) [email protected] Ashley E. Eiler (pro hac vice) [email protected] Nicol
Page: HOUSE_OVERSIGHT_015596 →ral part of the civil proceeding, particularly when the condition is asserted as an issue by the party seeking closure” (emphasis added)). Il. JUDGE MARRA’S ORDER IN HIS CASE DOES NOT REQUIRE THAT THE RECORDS BE SEALED IN THIS CASE. Dershowitz also appears to contend that Judge Marra’s order striking s
Page: HOUSE_OVERSIGHT_015626 →he party seeking closure” (emphasis added)). Il. JUDGE MARRA’S ORDER IN HIS CASE DOES NOT REQUIRE THAT THE REC
Page: HOUSE_OVERSIGHT_015626 →SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson (pro hac vice) [email protected] Mary E. Borja (pro hac vice) [email protected] Ashley E. Eiler (pro hac vice) [email protected] Nicole
Page: HOUSE_OVERSIGHT_010889 →UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, VS. U
Page: HOUSE_OVERSIGHT_010892 →HERN DISTRICT OF FLORIDA Case No. 9:08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED ST
Page: HOUSE_OVERSIGHT_014085 →SCOTT & KISSANE, P.A. Dadeland Centre I], 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson (pro hac vice) [email protected] Mary E. Borja (pro hac vice) [email protected] WILEY REIN LLP 1776 K Street, NW Washington, DC 20006 Ph
Page: HOUSE_OVERSIGHT_014111 →Entities connected to both Kenneth Marra and Richard A. Simpson

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSON
Paul Cassell
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATION
George W. Bush
PERSONMaria Farmer
PERSONSouthern District
LOCATION
Prince Andrew
PERSON
Ghislaine Maxwell
PERSONMartin Weinberg
PERSON
Virginia Giuffre
PERSON
Donald Trump
PERSON
Salt Lake City
LOCATION
the University of Utah
ORGANIZATION
Bill Clinton
PERSONFISTOS & LEHRMAN
ORGANIZATION