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

: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

If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the bars of other states. Thank you. From: Jackie Perczek Sent: Monday, August 05, 2013 11:08 PM To: P

assell" rote: Hi Jackie -- Thanks! (And I hope Roy is paying you double overtime for answering case-related emails at 1 AM in the morning!). Paul Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah ou can access my pu Ica ons on p://ssrn.c

To: Paul Cassell MM. From: Jackie Percze Cc: ra' 'war's Subject: Re: Position on Motion for Expedited Ruling on Motion to Dismiss Date: Tue, 06 Aug 2013 14:02:59 +0

Entered on FLSD Docket 08/16/2013 Page 43 of 64 with you to try and minimize any unnecessary burden from your discovery obligations. E-mail from Paul G. Cassell & Bradley J. Edwards to Dexter Lee. et al., Counsel for the Government (February 25, 2013). The Government ignored the e-mail and did not respond in

tion does not mean agreeing to facts that are not relevant to the resolution of the legal dispute at issue . . . . Letter from Wifredo A. Ferrer to Paul G. Cassell (March 15, 2011). 17. Accordingly, unable to work with the Government to reach a resolution of the facts, on March 21, 2011, the victims filed a Mo

U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Ferrer, asking him to personally investigate what happened during the Epstein prosecution and how the

U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Ferrer, asking him to personally investigate what happened during the Epstein prosecution and how the

ney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Fer

542075 E-mail: brad(4)pathtojustice.com EFTA00179735 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 38 of 64 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile:

: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

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

traordinary circumstances. Based on our review of Professor Cassell's correspondence, and the pleadings filed in the

f misconduct by a DOJ attorney or law enforcement personnel or there are present other extraordinary circumstances. Based on our review of Professor Cassell's correspondence, and the pleadings filed in the Doe case, we have determined that his allegations fall into this category. No 08-80736-CV-MARRA P

ited States Attorney forwarded to the Office of Professional Responsibility (OPR) a letter dated December 10, 2010 that you received from Professor Paul Cassel), of the S.J. Quinney College of Law at the University of Utah. In his letter, Professor Cassell alleged misconduct by the United States Attorney's

cooperate, cooperation does not mean agreeing to facts that are not relevant to the resolution of the legal dispute at issue .... Letter from w to Paul G. Cassell (March 15, 2011). 17. Accordingly, unable to work with the Government to reach a resolution of the facts, on March 21, 2011, the victims filed a Mo

U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Ferrer, asking him to personally investigate what happened during the Epstein prosecution and how the

ney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Fer

She’s made the whole story up out of whole cloth.” are part of a plot to exto Bradley Edwards had already become involved in lawsuits q Edwards and Cassell have { against Epstein. In 2007, working with a former federal judge i. he’s ever seen. and University of Utah law professor named Paul Cassell, he h

dan to get off scot-free. But the plot twist that E on the day of Alan Dershow Florida, courthouse was eve “There was a criminal extort Edwards and Paul Cassell’s | 2015. “Your clients were involv Bradley and Cassell had s for defamation— payback fo : law professor had made in th Dershowitz had counters HOUS

involved in encouraging rious affidavit that they knew or perjurious recently when they matory allegation in the federal that what you are charging Brad- Paul Cassell with doing was sub- Pore ere oy om OB e question, I am directly charging dwards with suborning perjury. I irginia Roberts did not want to © ds that

all me directly, my cell phone is Thank you for any assistance you can extend rapidly on this important matter. Paul Cassell (and Brad Edwards) for IMI Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinncy College of Law at the University of Utah 332 S. 1400 E. , Room 101 Salt Lakc City,

at local law enforcement responds to. EFTA01660359 Can you have the appropriate FBI agent contact me quickly? My cell phone is 801-201-8271. Paul Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law 5.1. Quinney College of Law at the University of Utah 332 South 1400 East, Room 101 Salt La

moments ago -- can you have the FBI agent call me? Special Agents and This e-mail from Paul Cassell claims that home in Colorado was broken into. Cassell wants to know who at the FBI is responsible for MI safety. When this issue first arose on Sunday, and I spoke and decided to forward to request fo

2015. The time is approximately 9:31 5 a.m. This is the videotaped deposition of Alan 6 M. Dershowitz in the matter of Bradley J. 7 Edwards and Paul Cassell versus Alan M. 8 Dershowitz. This deposition is being held at 9 110 Southeast 6th Street, Suite 1850, Fort 10 Lauderdale, Florida, 33301. 11

. SCAROLA: My name is Jack Scarola. 09:31:48 17 I'm counsel on behalf of Bradley Edwards and 18 Professor Paul Cassell. Mr. Edwards and 19 Mr. Cassell are also present. 20 Also with us from the Utah Attorney 09:31:58 21 General's office is Joni Jones. 22 MS. McCAWLEY: Sigrid McCawley. I'm wit

1 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. / VIDEOTAPE DEPOSITION OF ALAN M. DERSHOWITZ VOLUME 1 Pages 1 through 179 Thursday, Octobe

electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the b

is that it should be filed by May 8, which gives you two months. I also suggest the reply be due July 8. Please let me know if that is acceptable. Paul Cassell for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law and University Distinguished Professor of La

ves you two months. I also suggest the reply be due July 8. Please let me know if that is acceptable. Paul Cassell for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law and University Distinguished Professor of Law S.J. Quinney College of Law at the University

Entered on FLSD Docket 08/16/2013 Page 43 of 64 with you to try and minimize any unnecessary burden from your discovery obligations. E-mail from Paul G. Cassell & Bradley J. Edwards to , et al., Counsel for the Government (February 25, 2013). The Government ignored the e-mail and did not respond in any way.

ney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. , a

cooperate, cooperation does not mean agreeing to facts that are not relevant to the resolution of the legal dispute at issue .... _ Letter from to Paul G. Cassell (March 15, 2011). 17. Accordingly, unable to work with the Government to reach a resolution of the facts, on March 21, 2011, the victims filed a Mo

electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the b

From: Paul Cassell •( > Subject: RE: supplemental discovery requests plus schedule moving forward Date: Mon, 29 Aug 2016 19:12:55 +0000 Importance: Normal Attachments

ing. Again, happy to propose something to Judge Marra that works conveniently for everyone at your end. Paul Cassell for Jane Doe 1 and Jane Doe 2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law University Distinguished Professor of Law Quinney College of Law at the University of Utah

From: Paul Cassel To: Brad Edwards Cc: Subject: RE: Conf call re scheduling and discovery? Date: Wed, 31 Aug 2016 21:27:30 +0000 Importance: Normal I free at tha

electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the b

If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the bars of other states. Thank you. From: Brad Edward Sent: Wednesda Au ust 31 2016 3:26 PM To: Cc:

is a formal request on behalf of Mr. Edwards and Professor Cassell to interview you, under oath, regarding interact

rely proper and well-founded pleading, DERSHOWITZ initiated a massive public media assault on the reputation and character of BRADLEY J. EDWARDS and PAUL G. CASSELL accusing them of intentionally lying in their filing, of having leveled knowingly false accusations against the Defendant, DERSHOWITZ, without ever

.,.._.Ket 01/21/2015 Page 2 of 2 Subject: FW: Meeting in January 2015 From: (USAFLS) Sent: Tuesday, December 16, 2014 3:03 PM To: Brad Edwards; Paul Cassel Subject: Meeting in January 2015 Brad and Paul, We would like to schedule a meeting with the Executive Division, as you requested, for January 201

electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the b

derstand the problem here, since you extended the same accommodation to Jane Doe #1 and Jane Doe #2. Paul Cassell and Brad Edwards for Jane Doe #3 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah CONFIDENTIAL: This electronic message

If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the bars of other states. Thank you. EFTA00210971 From: Paul Cassell Sent: Tuesday, January 06, 2015

you back my proposed stipulated facts. 1. I am working with two other attorneys on this case — Jay Howell in Jacksonville, Florida, and Professor Paul Cassell in Salt Lake City, Utah. Because they were not in court for the hearing last Friday, they will need to review a transcript of the hearing before our

ention the federal non-prosecution agreement to this counsel and that you did not mention that a plea agreement had already been reached. Professor Cassell has spoken to Meg Garvin, Esq., at the National Crime Victims' Law Institute, and that is her recollection of the events. 7. I think that your pro

that a plea agreement had already been reached. Professor Cassell has spoken to Meg Garvin, Esq., at the National

electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the b

iPhone >> On Mar 28, 2016, at 1:24 PM, Paul Cassell <MIII > wrote: >> Brad's worried that is too early to get everything done -- right Brad? PC » Paul G. Cassell >> Ronald N. Boyce Presidential Professor of Criminal Law >> University Distinguished Professor of Law >> S.J. Quinney College of Law at the Unive

If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the bars of other states. Thank you. >> Ori inal Messa e » From: . (USAFLS) [mailto: >> Sent: Monday

cial exposure for criminal restitution in federal court is likely to exceed $500 million, and the exposure in state court to exceed a billion," said Paul Cassell, a University of Utah law professor, a former federal judge and a lawyer for one of Epstein's alleged victims. "It's easy to foresee 160 victims in

re in state court to exceed a billion," said Paul Cassell, a University of Utah law professor, a former fe

ose properties would be subject to forfeiture. But if evidence shows that his jets or other residences were also involved, those also could be lost, Cassella said. The Santa Fe New Mexican reported last week that the New Mexico attorney general, Hector Balderas, is investigating whether Epstein committed

ney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. M ,

U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. M , asking him to personally investigate what happened during the Epstein prosecution and how the vict

, cooperation does not mean agreeing to facts that are not relevant to the resolution of the legal dispute at issue .... Letter from Wifredo A. to Paul G. Cassell (March 15, 2011). 17. Accordingly, unable to work with the Government to reach a resolution of the facts, on March 21, 2011, the victims filed a Mo