Epstein Secrets

ty contends that the communications at issue were "settlement communications." The relevant meetings between Dershowitz and counsel for non-party David Boies, that are at issue and the subject of Dershowitz's Affidavit were not settlement discussions but rather were an attempt to resolve factual disputes

ead, the issue presented in the motion is whether baseless objections to the discovery before trial of those communications between Dershowitz and Boies and others as somehow "privileged" should be overruled. The cases on which relies did not seal anything; they simply held that evidence in the pub

intiff Alan Dershowitz's Affidavit exhibit filed as an attachment to his Motion in Limine under seal. Respectfully submitted, /s/ Steven R. Safra Thomas E. Scott, Esq. Florida Bar No. 14 100 Steven R. Safra, Esq. Florida Bar No. 057028 COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South

ty contends that the communications at issue were "settlement communications." The relevant meetings between Dershowitz and counsel for non-party David Boies, that are at issue and the subject of Dershowitz's Affidavit were not settlement discussions but rather were an attempt to resolve factual disputes

ead, the issue presented in the motion is whether baseless objections to the discovery before trial of those communications between Dershowitz and Boies and others as somehow "privileged" should be overruled. The cases on which relies did not seal anything; they simply held that evidence in the pub

intiff Alan Dershowitz's Affidavit exhibit filed as an attachment to his Motion in Limine under seal. Respectfully submitted, /s/ Steven R. Safra Thomas E. Scott, Esq. Florida Bar No. 14 100 Steven R. Safra, Esq. Florida Bar No. 057028 COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South

this document. TDD users may also call 1-800-955-8771 for the Florida Relay Service. EFTA00605444 Dated: March 30, 2016 Respectfully submitted, BOIES, ScHIt.1.ER & FLEXNER LLP Sigrid S. McCawley. Esq. b>i 0,n, Florida Bar No. 129305 401 Last Las Olas Boulevard, Suite 1200 Fort Lauderdale, Flo

correct copy of the foregoing was served by Electronic Mail to the individuals identified below. By: /s/Sigrid S. McCawley Sigrid S. McCawley " Thomas E. Scott I hgrna,.scott'd c,klecia I cop; Steven R. Safra Ste_‘ en safraw csk Icgal coin COLE, SCOTT & KISSANE. P.A. 9150 S. Dadeland Blvd., Suite 1400

ce of Takin Saturday, January 16, 2016 9:00 am Boies, Schiller & Flexner LLP 401 East Las Olas Blvd,

rola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm Beach, Florida 33409. Respectfully submitted, 5/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 Thomas.scott @csklegal.com Steven R. Safra Florida Bar No. 057028 [email protected] COLE, SCOTT &

aul G. Cassell, Esq.,; Sigrid S. McCawley, Esq., Boies Schiller & Flexner, LLP, this day of February,

d the right to amend, it would be an abuse of discretion for the Court to 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)

Utah 84114, as well as to: Sigrid McCawley, Esq, Boies, Schiller & Flexner LLP, 401 East Las Olas Blvd.

proves, evidences, shows, refutes, disputes, rebuts, controverts, and contradicts. 2 EFTA00592302 Respectfully submitted, /s/ Steven R. Safra Thomas E. Scott, Esq. Florida Bar IskLkt 0 Steven R. Safra, Esq. Florida Bar No. 057028 COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South D

Utah 84114, as well as to: Sigrid McCawley, Esq, Boies, Schiller & Flexner LLP, 401 East Las Olas Blvd.

proves, evidences, shows, refutes, disputes, rebuts, controverts, and contradicts. 2 EFTA00592306 Respectfully submitted, /s/ Steven R. Safra Thomas E. Scott, Esq. Florida Bar IskLkt 0 Steven R. Safra, Esq. Florida Bar No. 057028 COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South D

gment in order to represent Dershowitz in this case. HOUSE_OVERSIGHT_015595 --- PAGE BREAK --- Dated: February 3, 2016 Respectfully submitted, s/Thomas E. Scott Thomas E. Scott, FBN 149100 [email protected] Steven R. Safra, FBN 057028 [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Cen

lso containing discussion of Ms. Giuffre’s affidavit). The Court should be aware that within approximately two hours of this exchange, Ms. McCawley. (David Boies’ law partner) released a statement on his behalf, which stated that Dershowitz was misrepresenting what happened: “Because the discussions that Mr. Bo

s’ law partner) released a statement on his behalf, which stated that Dershowitz was misrepresenting what happened: “Because the discussions that Mr. Boies had with Mr. Dershowitz were expressly privileged settlement discussions, Mr. Boies will not, at least at this time, describe what was actually sai

Dated: February 8, 2016 Respectfully submitted, BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Boulev

and correct copy of the foregoing was served by Electronic Mail to the individuals identified below. By:_/s/Sigrid S. McCawley Sigrid S. McCawley Thomas E. Scott [email protected] Steven R. Safra [email protected] COLE, SCOTT & KISSANE, P.A. 9150 S. Dadeland Blvd., Suite 1400 Miami, Florida 33

he Court on December 18, 2015 upon Boies, Schiller & Flexner LLP’s Motion to Seal “Exhibit B, Affidavit of Alan M. Dershowitz Regarding Meetings with David Boies” to Defendant Alan M. Dershowitz’s Motion in Limine to Overrule Objections As to Application of Settlement Rules, Filing # 35429605 E-Filed 12/11/201

ourt that doing so would not violate the Confidentiality Order or alternatively relief from that Confidentiality Order. Respectfully submitted, s/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 [email protected] Steven R. Safra Florida Bar No. 057028 [email protected] COLE, SCOTT & KI

[email protected] to: Sigrid S. McCawley, Esq., Boies Schiller & Flexner, LLP, 401 E. Las Olas Blvd, Su