Epstein Secrets

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

his Counterclaim. 30 EFTA00613438 Respectfully submitted, s/ Thomas E. Scott Thomas E. Scott, FBN 149100 • c vice) ary . orja ro iac vice) Ashley E. Eiler (pro hoc vice) Nicole Audet Richardson WILEY REIN LLP ro hac vice) Counsel for Alan M. Dershowitz 31 EFTA00613439 CERTIFICATE OF SERVICE I H

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

(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 REIN LLP 1776 K St. NW Washington, DC 20006 Phone: (202) 719-7000 Fax: (202) 719-7049 HOUSE_OVERSIGHT_010

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

deland 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 Phone: (202) 719-7000 Fax: (202) 719-7049 Counsel for Alan M

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

iami, 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 Washington, DC 20006 20 EFTA00584081 Phone: (202) 719-7000 Fax: (202) 719-7049 Coun

United States of America Case No. 08-80736-CIV-MARRA/JOHNSON, [ECF No. 291-1] (the "Federal Action").

d 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 20006 Phone: (202) 719-7000 Fax: (202) 719-7049 Counsel for Alan M. Dersho

e: (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] Nicole Audet Richardson (pro hac vice) [email protected] WILEY REIN LLP 1776 K Street NW Washington, D

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

ne: (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 A. Richardson (pro hac vice) [email protected] WILEY REIN LLP 1776 K Street NW Washington, DC 2

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, VS. U

HERN DISTRICT OF FLORIDA Case No. 9:08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED ST

ons, Defendant responds that he will produce any responsive, non-privileged documents currently in his possession, custody or control. Of Counsel: Ashley E. Eiler [email protected] WILEY REIN LLP 1776 K Street, NW Washington, DC 20006 Phone: (202) 719-7000 Fax: (202) 719-7049 Kenneth A. Sweder ksweder@swede