Epstein Secrets

: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, vs. ALAN M. DERSHOWITZ, Defendant. / PLAINTIFFS/COUNTERCLAIM DEFENDANT EDWARDS AND CASSELL’S RESPONSE TO DERSHOWITZ’S MOTION TO DETER

E 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, vs. ALAN M. DERSHOWITZ, Defendant. / PLAINTIFFS/COUNTERCLAIM DEFENDANT EDWARDS AND CASSELL’S RESPONSE TO DERSHOWITZ’S MOTION TO DETERMINE CONFIDENTIALITY OF COURT RECORDS Plaintiffs/Counterclaim Defendants Bradley J. Edwards and Paul G. Ca

mountain evidence strongly support Ms. Giuffre’s allegations. See Deposition of Paul Cassell (Oct. 16, 2015) at 61-117 (Exhibit 3); see also Depo of Pual Cassell (Oct. 17, 2013) (Exhibit 4). CONCLUSION The Court should deny Defendant/Counterclaim Plaintiff Alan Dershowitz’s motion to place documents regarding

, and steal. These are unethical lawyers. This is Professor Cassell who shouldn’t be allowed near a student. This is

to mark as Exhibit -- are we up to 4 ~- Exhibit 4, the document that Mr. Cassell was referring to. lil fet the reporter do that. THE WITNESS: Okay. (Casseil's 1.D. Exhibit No. 4 - document produced by the witness was marked for identification.) MR. SIMPSON: I just want to make that part of the record. ESQ

of these materials is “inherent” in the case itself. The principle that defamatory material in a defamation case cannot be sealed is recognized in Carnegie v. Tedder, 698 So.2d 1310 (2d DCA 1997). Carnegie involved a claim and counterclaim between two parties (Carnegie and Tedder), one of whom alleged t

ru Southern District of Florida, seeking advice P-013278 regarding office-wide recusal, dated December 16 and 17, 2010, with attached letter from Paul Cassell to Wifredo A. Ferrer, dated December 10, 2010 Page 23 of 23 EFTA00086444 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 P

ted States, Case No. 08-80736-C1V-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Fort Lauderdale FL 33301-3268 Fax: Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Ci Utah 84112 Fax: (801) 585-6833 E-mail: Attorneys for Jane D

ida Fort Lauderdale FL 33301-3268 Fax: Paul G. Cassell S.J. Quinney College of Law at the University o

work product enjoys a nearly absolute immunity and can be discovered only in very rare and extraordinary circumstances." Cox v. Adm'r U.S. Steel & Carnegie, 17 F.3d 1386, 1422 (11th Cir. 1994). In the context of government attorneys, the "work-product privilege applies to . . . discussions between prose

:44 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 PLAINTIFF ALAN M. DERSHOWI

howitz has repeatedly referred to HOUSE_OVERSIGHT_015621 --- PAGE BREAK --- Edwards, Bradley vs. Dershowitz Case No.: CACE 15-000072 Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records Page 2 of 20 these documents, not only in defamatory statements broadc

lf. The principle that defamatory material in a defamation case cannot be sealed is recognized in Carnegie v. Tedder, 698 So.2d 1310 (2d DCA 1997). Carnegie involved a claim and counterclaim between two parties (Carnegie and Tedder), one of whom alleged that disclosure of HOUSE_OVERSIGHT_015623 --- PAG

of these materials is “inherent” in the case itself. The principle that defamatory material in a defamation case cannot be sealed is recognized in Carnegie v. Tedder, 698 So.2d 1310 (2d DCA 1997). Carnegie involved a claim and counterclaim between two parties (Carnegie and Tedder), one of whom alleged t