: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

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

as Boulevard Cassels 1.D. Exhibit No. 4 - document 203 11 Suite 1200 10 produced by the witness Fort Lauderdale, Florida 33301 12 Tel: 954.356.0011 4 Cassell's 1.D. Exhibit No, 5 - copy of 229 Fax: 954.356.0022 ad AYEES LOOK 13 E-mail: smccawley@ bsfllp.com 42 14 Cassell's 1.0. Exhibit No. 6 - series of 309

: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

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

AK --- 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, Plaintiff(s), vs. ALAN M. DERSHOWITZ, Defendant(s). / NOTICE OF SERVING ANSWERS TO INTERROGATORIES Plaintiffs, Bradley J. Edwards and Paul G. Cas

n referencing Dershowitz by name that Concern the allegations set forth in Paragraphs 24-31 of the 2015 Jane Doe #3 Declaration. ANSWER: Edwards and Cassell lack sufficient information to determine all circumstances in which Jane Doe No. 3 has mentioned to others Dershowitz’s name as someone who abused he

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

a monogrammed fleece pullover like the ones favored a : “There was a criminal ae by Jeffrey Epstein, he describes an evening at sa i 4 ] Edwards and Paul Cassell’s | “The party was in full swing,” he explains. “A trig “a _ 4 ‘= stern wanted to give me a special present. Told me to wait in my : meer an Sep interr

essor named Paul Cassell, he had Gled a lawsuit on behalf of another unnamed woman. Six years later, that case is still pending, and now, Edwards and Cassell i petition to have the two suits combined. Allin all, four Jane Does take part in the lawsuit. Jane Doe 3 is Virginia Roberts, the girl who says th

young, suggestible woman who was other unnamed woman. Six years interested in money,” Dershowitz says. “This is a disbarrable g, and now, Edwards and Cassell J offense, and they will be disbarred. They will rue the day the -ontined. a ever made this false charge against me.” It’s a vehement seals. ake part i

HF AF BF HF Fe Fe HF |S ao FBP WN F- 970 DO DN ODO OT BR W NY — ROUGH DRAFT TITLE ***ROUGH DRAFT TRANSCRIPT *** CASE NAME: BRADLEY J. EDWARDS and PAUL G. CASSELL vs. ALAN M. DERSHOWITZ WITNESS NAME: PAUL G. CASSELL DATE OF DEPOSITION: 10/16/15 This is an unedited, unproofread, | uncertified transcript for a

. Will counsel please announce their appearances for the record. MR. SCAROLA: Jack Scarola appearing on behalf of Bradley Edwards and Professor Paul Cassell. With me is Joni J. Jones from the Utah Attorney General's Office. MS. McCAWLEY: Sigrid McCawley on behalf of Virginia Roberts from Boies Schiller &

required for the more complex cases. MR. SCAROLA: Professor Cassell, I know it is ROUGH DRAFT ONLY HOUSE_OVERSIGHT_

M/ECF on this 28" day of June, 2010: Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Ave. Suite #2 {e) Paul G. Cassell, Esq. Pro Hace Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australi

greed to. represent these girls, along with attorney Jay Howell (an attomey in Jacksonville, Florida with Jay Howell & Associates) and Professor Paul Cassell (a law professor at the University of Utah College Of Law). I filed state court actions on behalf of L.M. and E.W. and a federal court action on beha

10, along with other attomeys at Farmer Jaffe and Professor Cassell, I reached favorable settlement terms for my thre

roceedings, we will be able to prove that clear violation of the CVRA and then obtain the remedy of invalidating the illegally-negotiated plea deal. Paul G. Cassell teaches criminal law, criminal procedure, and crime victims’ rights at the S.J. Quinney College of Law at the University of Utah. Before coming to Ut

at the case will ultimately set an important precedent that federal prosecutors can't keep victims in the dark about the plea deals that they reach." Cassell said. Epstein served 13 months of an 18-month sentence on the prostitution charge. sold his Palm Beach home in 2011 and now divides his time between

all documents and discussion of the Jane Doe 102 case, including the settlement of those claims (Motion in Limine 17) «0.0... eeeeeeeeees 26 18. The Cassell/Edwards v. Dershowitz litigation is relevant and admissible (Motion in Limine 18) oo. eeeesseesseceseesseesseceseesseesseceseesseeeseeeseeessesseessa

I electronically served this Defendant’s Response in Opposition to Plaintiff's Omnibus Motion In Limine via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meredith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 P| Ft. Lau

: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 DERSHOWITZ’

Beach Lakes Blvd., West Palm Beach, Florida 33409; [email protected] to: Joni J. Jones, Esq., Assistant Utah Attorney General, Counsel for Plaintiff Cassell, 160 East 300 South, Salt Lake City, Utah 84114; [email protected] to: Bradley J. Edwards, Esq, Farmer, Jaffe et al, 425 North Andrews Avenue, S

masturbated Providing clients with proven and sexually assaulted them. experience and innovative solutions to complex compliance and Brad Edwards and Paul Cassell, attorneys representing two of his alleged victims, say in enforcement issues inside the the filing that the U.S. Attorney's office for the Southern

day in those cases before U.S. District Judge Kenneth Marra. Doe could have settled the lawsuit for $50,000 but is asking for $50 million in damages, Cassell said Tuesday. "Jane Doe was repeatedly sexually assaulted over a lengthy period of time by this wealthy and powerful man," Cassell said. Epstein, 57,

ticle 2 Winter 2014 Crime Victims’ Rights During Criminal Investigations? Applying the Crime Victims’ Rights Act Bebore Criminal Charges Are Filed Paul G. Cassell Nathanael J. Mitchell Bradley J. Edwards Follow this and additional works at: http://scholarlycommons.law.northwestern.edu/jclc o& Part of the Cr

The statute that Congress passed to solve these problems—the Crime Victims’ Rights Act of 2004—-gave victims “the right to participate in the 18 See Cassell, supra note 17, at 848-49. For the pros and cons of the amendment as originally introduced, compare Paul G. Cassell, Barbarians at the Gates? A Reply

of 34 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, Plaintiff(s), VS. ALAN M. DERSHOWITZ, Defendant(s). / PLAINTIFFS’ MOTION TO COMPEL PRODUCTION OF DOCUMENTS Plaintiffs, Bradley J. Edwards and P

KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 3 of 34 records that I couldn’t have been in these places. The woman is a serial liar. If [Cassell and Edwards] had done that investigation, they would have come to the same conclusion.”! Similarly, on January 8, 2015, on the Greta van Susteren s

Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law Univer

J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake = UT 84112 * This daytime business address is provided

0, along with other attorneys at Farmer Jaffe and Professor Cassell, I reached favorable settlement terms for my thre

greed to. represent these girls, along with attorney Jay Howell (an attomey in Jacksonville, Florida with Jay Howell & Associates) and Professor Paul Cassell (a law professor at the University of Utah College Of Law). I filed state court actions on behalf of L.M. and E.W. and a federal court action on beha

ttorneys for Plaintiff BY: SIGRID S. McCAWLEY, ESQ. MEREDITH L. SCHULTZ, ESQ. S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH For Plaintiff BY: PAUL G. CASSELL, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT R (212) 805

tive value that's past sexual assault that Ms. Giuffre experienced as a child is completely swallowed by the prejudicial effect on the jury. r MR. CASSELL: Your Honor, I think I'm the next one up. For purposes of clarity, we're up to point number 7 in our omnibus motion. This one I think is just a ver

“sweetheart deal.” Marra could make a decision as early as this fall. The stakes for all crime victims are high, said attorneys Bradley Edwards and Paul Cassell, who filed the rare lawsuit against the federal government on behalf of two Jane Does who were 13 and 14 when they claim Epstein paid them for sex.

lives up to his end of the bargain, the government is bound to perform its promises,” he wrote, quoting a prior court decision. However, Edwards and Cassell claim that because federal prosecutors didn’t confer with their clients about the plea deal before it was made, they violated the law and that makes

Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] 2 Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 [email protected] J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@

gation has concluded and | am gratified by the Joint Statement issued today by Jeffrey E. Streitfeld on behalf of the parties, in which “Edwards and Cassell acknowledge that it was a mistake to have filed sexual misconduct accusations against Dershowitz and the sexual misconduct accusations made in all pu

Mike Fisten Investigators RRA N.R. Client communication Nora Batian RRA Staff Pasqual “Pat” Diaz Pat Roberts Investigators RRA Investigators RRA Paul Cassel Co-Counsel on Epstein Case Phaedra Xanthos Forensic Accountant Priscila Nascimento Staff RRA Richard Willits Attorney Richard Wolfe Attorney RRA

oberts Investigators RRA Investigators RRA Paul Cassel Co-Counsel on Epstein Case Phaedra Xanthos For

. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 [email protected] J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@

ion in Limine 17) ................0005 26 18. The Cassell/Edwards v. Dershowitz litigation is relevant and