Case 1:17-mc-00025-RWS Document 10-2 Filed 06/30/16 Page 1 of 29

# EXHIBIT B

Filing #351801711298452BYSS03: Pocument 10-2

Filed 06/30/16

Page 2 of 29

HIT OFFICIAL LAS

HOT OFREC

IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA

NIT OFFICIAL LIBRA

WARDS Y WARDS Y

PAU PAU

CACE 15-000072

HUT HELT LOO

BRADLEY J.
CASSELL, CASSELL, CON

ILIAL

-

DAT

Cefendants.

## J. J.
MOTION

HATUA,

BRAD
RS

J. and throu
"SUL WAR PAUL CASSELLS NOT Y
counsel and pursuant to 1.510, of move

(1) partial su claim or Sell, on the of the false nature of the
he ATI dure,
issue in defamation as well to the presumed from

respect to bot of
s to Dershowitz's First the , and final
summ judgment them, in support

TODUC

HIT OFFICIAL ell we
and Cassell. They conter
METAR the Court is well aware, this
repeatedly

had conspiring

1 abuse alle temRY HYBILL CA them by

Alatz,
that the

Dershoga world case i media and

make
The pleadings and discoveir client o genuine issue st
taken to show that there is no

NOT OFFICIAL that

AL

Dre dates

*FIL

Case 1:17-mc-00025-RWS 1:17-mc-00025-RWS

DIS
Dershowitz

Document 10-2

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Edwards, Bradley vs. Dershowitz

Case No.: CACE 15-000072

Page 2 of 20

statement CIFY statement CIFY

HAT GENEL any

fact that were false defamatory.
privilege fa
entitled to to parts they filed in court on their
Edwards and Cassell are summary Amended Counter
and Cassell are judgment on I to summary cir complain ershowitz's First
1 final summary judgment on I

and

plain

Tregard to Tregard to They h on the

Decio Edwards and Cassell are entitled Edwards and Cassell are entitled summ

c issue of the false and defamato nature statements ade against

provided ample evidence they had a
were that accordinglyful basis I in filin believing
1 abuse allegati - and a legal docume on

behalf As a result, the
evient &hich contained
establishes that Dersho waged a baseless international media on the

honesty, ty, and p Dershowitz went
s to repeatedofessionalism of Edwards and Cassell. In p I mi arr
So far a accuse Edward and Cassell of n actively ing

allegations him- would

from legal misconduct a The undisputed record conclusion
that the of
and Cassell the sexual against Dershowitz

to be is all that is court to er partial s mary judgment Put
s made highly defamatory allegations that
simply, no basis in Indeed,
ab have
his lawsuit was merely a desperate measure by a child to avoid stigma of the

of his miscon Detz's charges a Edwards 1 Cassell we and

nothing of a far-fetched fictional fairy-tale - a preposterous clai lacking

th client th client their

NOT ATLANT

Case 1:17-mc-00025-RWS Document 10-2 Filed 06/30/16 Page 4 of 29

TOTAL C

Edwards and Cassells Motion for Summary Judgment on LiaIAL CHRY Edwards, Bradley vs. Dershowitz Case No.: CACE 15-000072

Page 3 of 20

that he the Edwards Cassell-

of law therefore Stancar ack with a of
ffered.
the court should for summary the
2. ant plaintiffs'
issues of the false and as the issue of the

flowed from those statements.

With regard First the material establish

against the Plaintiffs are by the
8 8 amended
The of the Edwards Cassell forms the

federal court pro ation: the claim for I pro bono client well ded than filing a
on behalf of In his recent deposition,
be ou cenotion int
Dershowitz Sult, conceded that the were e relevant to the federal
and
filing is sibly p Florida's broad
y judgmenta
Consequ motion for pending

absolute NLHIPY

IN CH

ARE ENTITLED TO PARTIAL SUMMARY JUDGMENT ON THE PENDING PRIMARY CLAIM BECAUSE THERE NOT WARDS AND CASS GUMENT ARE NO MATERIAL DISPUTED FACTS AND THE UNDISPUTED FACTS ESTABLISH THAT DERSHOWITZ REPEATEDLY BROADCAST FALSE

DEFAMATORY STATEMENTS ABOUT THEM.
END S Standard. Standard.
Rhe S
1.510(c), orida Rules ter sum

HAY GITIAL COPT

OFFICIAL CURY

CHULA COP

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Page

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CALC

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Edwards, Bradley vs. Dershowitz

Case No.: CACE I 5-000072

Edwards and Cassells Motion for Summary Judgment on Liability

Page4 of20

NIEL OFFICIAL LI Jude

HOT OITHIN COPY

here i

that the party is to as a matter

prevail, it is incumbo actual V. Development 373 So. 720 DCA 1.510(c)

Fla. R. Civ. P. Once the party that the y cannot

on the party to but ther for

judgment. Holl v. 191 So. 43 (Fla. It is not

opposing to assert an issue of does exist. v. Wynns,

Landers v. 370 370

HAT A CU

party faced a Judgment
Moreover, it is
supported appropriate may not on bare, conc assertions found in the

pleadings to create an issue and thus avoid party must
genuine summary j ent. Instead,
counter dence fact. See با

Clinics, 479 168 (Fla. Ct. see also

of North Beach, 141 626 3d Dist Ct. 1962)
t sufficient to preclude sumrethat mere
contrary egations of c were judgment on of
tevide bas
without Where nonmoving fails
fact butt
for summary there is no issue entry of

Lent is proper as an of law. See. V.

HIT GEFITIAL SEA CODE facts

the

H

HUT OFFICIAL COPY

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OFFICAL COP

Edwards, Bradley vs. Dershowitz

Page 5 of 20

Case No.: CACE 15-000072

L

Statements Concerning Edwards and

In support motion,

NOT BETAL DIT GEFC Defamatory and Have A

Exhibit 2,

I incorpora ell Were ]
of the

and
n actual Basis.
is a

client,

Exhibits

attached Exhibit 1, most important
of some of t
is a sworn and Exhibit

from materials considerable considerable
Edwards These on behalf considerable
relied to file client, client, Ms. Ms.

Giuffre. theless, is not a case for granting

a r partial
To the Edward mary judg
Whment. Whment. one Cassell meni meni
Cand
and defamatory se.

which

upon
HOT SCOPO position t
Virginia

FRENCH FRENCH

URDU URDU

course, one that a Florida is an
hitation plaintif
a Publish: Se es of a stateme
ed publication
Mile Marker, Inc. v. L.L.C., 811 841, 845 Dist. Ct.
or defamatory Stone
The App. 4th App. 2). Another that a must is damage to
the ponefamation plaintiff
person that ensued person of the false of of the the false false or or 124 124 124 d d Id

CH

and Cassell entitled entitled entitled entitled to to to to on other on on of their
element element element element summary summary
% in this it is two two are

HOT AFFICIAL PUMP

As the undisputed facts establish a

filed those alle

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Edwards, Br,adley vs. bershowitz
CaseNo.: CACE 15-000072
Edwards and Cassells Motion for Summary Judgment on Liability
Page 6 of20

CHY CO

Re Re

OFFICIAL CU

e e those those allegation allegation were were were e pertinent e e went

rampage, that the So

clearlase filing e in their chosen professions in court for client, and demonstrated that they

fitness to the law. ate

Hershowitz's
as

THE OFFICIAL TEC

And it takes real effort understand that Dershowitz statements

Exhibit #1 and elsewhere) are obviously recounted in Dershowitz had had
sandtably
the have to create false charges

and should be disbarred. these statements involve the conduct
of two attorneys inte
their chosen Dershowitz had committed defamation per se and and

damage is rexercise anothe "is per se is, withou
showsumed. It is well settled in F fit imida that
of special to or a

incomp with the his lawful trade,

Campbell v. v. 1953)
Tcksonville. (570). (570).

HIT UNTRAL CONS

lability itself create a
presumption of lose volves defamation per se,
damage. Therefore a finding of liability for [defamation] p se, coupled
r and asseclusive legal
with an finding was intended to injure plaintiff and did in fact

cause the jury to without any finding of
S." Lawnw D
a specific amount of Tory Med. Ctr., Inc. v. Sadow, 42

HOT BETITIAL LINTO

NOT SITCOM HET

6

Case 1:17-mc-00025-RWS Document 10-2 Filed 06/30/16 Page 8 of 29

CHEY

Edwards, Bradley vs. Dershowitz

Case No.: CACE 15-000071

Edwards and Cassells Motion for Summary Judgment on Liability

Page 7 of 20

710, 720 4th for need be

no specific Edwards

Co
and on on aspect of t aspect of t
threoconduct.
THE

of of

evidence are

1 summary ent Edwards and Cassell must the

absence of any dispute that t 2 spute best evidence are profession is legal profession. Second,
Cards and et inconsissell
the of that Dershowitz has imputed with

that7 (1 legal And third, must the
Der exes of t
absence of any di statements were false Ample and

unrebutted Evidence each of three which is The

the

HOT HIFICIAL

HIT OFFICIAL SUP

Cassell are both a Dershowitz appears
to 1 is counsel in Derant] See to 12-6 (conceding
a Florida rights case and has held other legal positions); id. at 16-

ing the same as to

#14) he is a in

the law of Farmer, Ja , Weissing, Edwards, Fisto Lehrman and I I a Board Certifi

Civi

T

獎

>

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HOT OFFE

HAL

L. CHEY

Edwards, Bradley vs. Dershowitz

Case No.: CACE 15-000072

Edwards and Cassells Motion for Summary Judgment on Liability

Page 8 of20

HOT OITHIN COPY

jury trials. He has been in The Lawyers
Tri 2
in the 40 Under and by

National of Dist:Onal of Injury "Top 10 40." In the
6₁ssociation's "
Counsel Mr. as one of nation's One

AV his through the
Peer Rev Edwards is 1
Rating Before Mr. was a attorney

the County State Attorney's many violent In

Cine has handle cases on of victims sexual abuse
L
a mbe a of pro bono

NOT DIFICIAL CUPPY

Professor G. G. Cassell has established by affidavit Exhibit #15W that that he is he is

Ronald N. yce Presidential Professor of C S.J. College at
y of Utah. He graduated Criminal Law a 1 from Stanford Law School,
he served as President
1 for then-Judiki
of Review. He c Antonin when Scalia was on the the
Canford Law
Court of for the Circuit and then for the Justice United States, States

Cassell then served as an Associate General with the U.S.

Justice as s an Assistant Eastern t t t of Virginia, C of of Virginia, Virginia, C C
thement and a at the Colle Attorney for t
the facul of Law, where he taught full until until until he was sworn in as he he was was sworn sworn in in as as

a U.S. District Court Judge the District Utah in 2002. I he resigned his resigned resigned his his

return full time to the of to and litigate issues issues refs refs to to to crime crime crime
victims'e
He a co-author of law school casebook, Victims in Criminal Procedure

C C

HER ER

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CAL CO

HOT OFFICIAL

Page 9 of 20

曲

OFFICIAL

has
h Victims'

cases in and e Court for a cobono courts across the country, e v. U.S.). io s a recent

he argued to U.S. victim a

good of the bar and legal cases on a paid and bono basis in Utah

ALVORY

and
COPY COPY
Has Has Has Mad Mad Mad Defamatory Statements Defamatory Defamatory Statements Statements Conduct Conduct Conduct Incompatible Proper
Exercise of Edwards and Cassell's Profession. Edwards Edwards and and Cassell's Cassell's Profession. Profession.

De

As stablished stablished stablished dispute dispute dispute om om om reviewing the reviewing reviewing the the few few few in the
presentation, Dershow Dershow Dershow alleging ached
has has has defamed Edwards defamed defamed Edwards Edwards by by by
f [Edwards an
charactics, or or or a a a with the with with the the f f
lawful businesscondi businesscondi businesscondi
and and and י, י, י,
illustratesti illustratesti
assell failed to failed failed to to e e e the as they a the the as as they they a a on on behalf of their client on

and even that they sat they they sat sat with with with her her her the the a a attached Ideo clips

some some of of of the assault on the Plaintiffs' the the assault assault on on the the Plaintiffs' Plaintiffs' professional professional fitness, professional but other
false stateme, the a
statements Dershowitz has 1

dispara false stateme, P

and
BY GYNernational r

g deliberately, C

CHL

MAT BERCIAL Edwards and Cassell] are

I will
disbarred. g New York Times Edwards and Cassell] are - .2015 disbarred.
- .2015

"[Edwards and Cassell] manipulated a young, suggestible woman who was disbarred. They will rue the day terested in money. This is a disbarable offense, and they will be they di ever made this false charge against me." Miami Herald - January 3, 2

ST

R

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HALAL CO

IAL, CHEY

K, CH

Case Nq.: CACE 15-000072

on

Page 10 of 20

[Edwards and they're disbarred," Cassell they're disbarred," [Edwards and

Boston Globe- Boston Globe- 4, 4,

HUT GITHIN COPY

"If they [Casse 1 and 1 and had just done an hours' worth of work, the would have seen she is lying through her teeth. . . . They're prepared to lie, cheat, and steal. These are unethical lawyers. This is Professor Cassell who shouldn't be Towed near a student. . . . He is essentially a c who's distorted the legal system. Why crook. He is essentially somebod would he charge a person with a sterling reputation for 50 years on the basis of the word alone woman who is serial liar. If they just checked the records, they could have known from themselves that she was lying about me... So we can prove it without any doubt. That's what's so absurd. That's what's so strange why two experienced lawyers would file this kind of statement knowing it was untrue. These [Cassell End Edwards] are virtually the equivalent of perjurers and they have to be taken out of the legal profession. They more innocent people." to have a bar card to victimize

3be allowed

HOT BICIAL Hola Gorani-C

CNN Live (

HOT OFFICIAL DANNY

"There was no contact, no contact whatsoever. And I will prove it conclusively, and then I will bring disciplinary charges and prove that these lawyers knew that was false, could easily have checked, and dn't. And the these lawyers will be disbarred." be disbarred." COPS

5, 2015 5, 2015

OFFICIAL

CasAL So they and and the woman got together and contrived and and the made this up. They have been talking to the woman for years. She never alleged me before. She never made any mention. Many of the others were mentioned First time my name was mentioned was a week ago. . . . I've never two lawyers like Paul Cassell and Brad Edwards engage in such unethical, disbarrable And I am accusing t

HIT OFFICIAL COR

頭

CNN Tonight Conduct. Jan. 5, on the lawyers' public statements about the case. He also plans to file NAINE CHE "Dershowitz told Reuters Monday that he would file a defamation lawsuit based With their respective states' disciplinary boards asking that t 01. be disbarred."

NOT A CONT

Case 1:17-mc-00025-RWS Document 10-2 Filed 06/30/16 Page 12 of 29

BUY CALC

Edwards, Bradley vs. Dershowitz Case No.: CACE 15-000072 Edwards and Cassells Motion for Summary Judgment on Liability Page 11 of 20

[i.e., Cassell, Edwards, and Jane Doe No. 37 HEPT #CHEVES CH

MEET AFFICH

proHIFY will be 1- all of the 1- all to be categorically lying and making up this story. And it will be a terrible thing rape victims. They have put rape victims in a terrible position. Because when I unequivocally that they sat down and made this all up, tragically it will hurt all rape victims. . . The lawyers are lying through their teeth when they say I've refused to be deposed.. We [Epstein and Dershowitz] had an academic onship. I was never in the presence of a single, young, under-aged woman. I was with him, it was with scientists, prominent academic

HOT GIR COPY

And they're just - again - lying a a this
Today Jan. 22 22, 2015. 22, But

Hothstein is now in jail for 50 years for a Ponzi scheme involving the same case CEMETERY CHE

"Now, your own rules of the profession, which I read coming in this morning, include as a professional I will always avoid personal criticism of another lawyer. And yet these two lawyers Brad Edwards, from, whose partner and a guy named Cassell - filed this... allegation again me in passing without even the most minimal of investigation, which would have conclusively that I not only didn't, but couldn't have, Speech to Dade County Bar Association, Feb. 20, 2015.

r respective by done it." Cassell's

fitnesshowitz has a Clearly to and Land

has a

tattEdwards
of th r

mbers

Derse

Were False Were False

The evidence statements were false. The The

sworn affidavit of Roberts Giuffre (identified as #3), and
s Alan Dershowit, 3 Aane Doe a
ed herein as Exhibit #2, unequivocally c
Edwards and stations of
and his statements made However,

denied the accuracy of Ms Giuffre's against While at

Dershow will be pro to be a at this could not if

the element of the claims on

MBT SHH thfulness of

Giuffre's were a

御緻 stages 11

which

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AL. CHEY

Page 12 of 20

NEET OFFICIAL

o to
Easy reach o

will

But while and

of Ms. of charges at this is not issue that the
the summary judgments Dial
GiuffCeking to before before the judgments 4 Edwards pleading.
this
The The issue issue which Edward and and complaint complaint is not
nd Cassell seek in

ets is not
but instead Ther lacked to
Edwards and Car
his claims not knew that statements The basis

actively participated in f fabricating false statements.

o support the ex: cof a a basis. 9 9 Y

to the the central iso central iso summary turns is

the p filing of Viro Roberts Roberts Giuffre's affidavit in the Crime
proceed Cots'
Victim's Act cases had any in that

conceded

expresonable relationship to the UFFSS CLAIMS

a sworn a sworn not only

HE URGINIA SUhat issue has b Ms. against

I law professor Alan Ders 2 OFFICIAL CHY 2 Wershowitz. to the The

2 about the about that she told

HIT OFFICIAL CER

regard to regard to I that: Hares, I law was around Epstein frequently. Dershowitz was so comfortable with the sex that was going on and that he observed me in sexual activity with Epstein. I had sexual intercourse with Dershowitz at least six times. The first time was when I was at least six times. The first time was when I was out 16, early on in to Epstein, and it continued until I was 19.

Epstein's hY BY CH

MIT SEG Cvitude to Epstein, and it continued until I was 19. TS.COM NETW y s

Epstein's The first time we had sex took place in New You in Epstein's room (not massage room). I was approximately 16 years old

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Edwards, Edwards, Edwards, Edwards, Bradley vs. Dershowitz Bradley Bradley Bradley vs. vs. vs. Dershowitz Dershowitz Dershowitz
Case Case Case Case No.: CACE 15-000072 No.: No.: No.: CACE CACE CACE 15-000072 15-000072 15-000072
Edwards Edwards Edwards and and and Cassells Cassells Cassells Motion Motion Motion for for for Summary Summary Summary Judgment Judgment Judgment on on on Liah Liah Liah
Page 13 of 20

C

z "Alan." I knew he was a famous professor. The

I also sex with Dershowitz at Epstein's Zorro Ranch in New Mexic in the massage room off of the indoor pool area, which was still being painted. NUT BETHAL DAY Bond time that I had sex with Dershowitz was at Epstein's house in Palm Beach. ein other sexual encounter between me and Dershowitz happened on We also had sex at Little Saint James Island in the U.S. Virgin Islands. 's airplane. Another girl was present on the plane with us. I have recently seen a former Harvard law professor identified as Alan Dershowitz on had

sex

at

I

HOT A CONY NOT

Cast

times.

six

on calling me a "liar." He is lying by denying that he
sex with me. elevision t t man is the same man that I h man is the same man that I I h sex with at I Cast six times. ad ad sex with at I h with

Since I filed my motion in the Jane Doe 1 and Jan 2 I filed motion in the Jane Doe Jan 2 case, my credibility
has been attacked, including attacks from Alan Dershowitz on me and on my
attorneys who believed in me. I am telling the truth and will not let these attacks
event me from exposing the truth of how I was trafficked for sex to many
powerful people. These powerful people seem to think that they don't have
as e else. That is

Suollow the same r affidavit of

The sertions of ser abuse are more than corroborated by compelling
I eviden which is detail at Cassell in his deposition. Ho the
ately heath
Court the jury this not ever whether

abused Ms. Giuffre to in Edwards. Cassell's in this Regardless
Dershowitz
whether Dershowitz sexually abused Ms. Wards and Cassell had a

basis for on the of a. - and
r repeatedly e media plShowitz had a s that Edwa "Solut
on s worldwi and Cassell

got together With their client" contrived and made this up." In addition, wards and
d no basis for 60
conducted investigation into the basis for Ms. 3re's assell - and

Dershow absolutely that if just done an

13

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Edwards, Bradley vs. Dershowitz

Case No.: CACE 15-000072

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NIET HEDICIAL BUT WON

worth they I have seen her teeth."

what between Dershowitz Giuffre of Jeffrey

Giuffst Dec and on 's exclusive island, undisputed evidence establishes
ainedibility Di nagt
Edwards Cassell had every right their to rely

is the
account of her i
they did
Ms. Sworn
with the

with Rotte

HET INICIAL ROY

good faith faith sand on Mere's a

depind laid out in detail by 5 by Cassell more than pages of (Exhibits testi
Oxassell Edward HY
See of Paul 1 (Oct. 16 & 17, 2015), a Some

Professor testimony in the PowerPoint as
testimoni
part the Motion. Cassel following
informcord
that he and Edwards relied upon the truth of s allegatio

FICIAL CONS

HIT OFFICIAL

- The Palm Beach Police Department put together an report based on
witness interviews and other evidence documenting sexual abuse of dozens of
minor girls occurring in Epstein's Florida mansion - a location
said Dershowitz had used her (see (see # Yere Ms.
Shibit

- Palm Beach police report showed the sexual abuse was showed the
basis and, indeed, in some cases as much as two or three times in one day in
circumstances that would have made it to a siting g guest that
were Coming to the home for sexual p

ŻYCHL in

Ms.

- logs for Epstein's private jet showed that Epstein (accompanied by Ms. Maxwell) flew Ms. Giuffre to the New York City area, a location where CO hibit #5);

MT SHE CGiuffre said Dershowitz had abused her (see F

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the AL. CHEY

A very
NOT BE stein's
to

HOT OITHIN COPY

- identity e passeng
using such not as "one Temale"

well Floridons a

- lawyer (Bob Josefsberg), who was selected by the
U.S. Government to represent the victims of Epstein's sexual abuse, had found
Ms. Giuffre to be credible and in 2009 filed a civil complaint for her alleging not
only s sex abuse by Epstein but So (see ] ibit #6) - a
icians"

ershowitz f fell f
by
conducting depositions in Epstein-related erg's Ms. TOPY Josefsberg filed

HOT NEWS COPY NOT

- after for
"academicians" had abuse her, one of Ms. Ezell,
cases asking
awareness of sexual buse;

IAL CO

- Dershowitz showed up on flight logs for Epstein's private jet, including a flight
with an (apparently young) woman with an (apparently purpose purpose young) for for woman med Mana"
about

y business p

When
HOT BITICAL COPY y business p

indeed,
volved

	- asked Epstein took the Fifth rather than indicate that Epstein 6
Dershowitz was not involved in any criminal activities (see Exhibit #7)
from which an obvious adverse inference could be drawn that Dershowitz was,
in stein's es;

	- moving down from the top of Epstein's crimi down
three women Sarah Kellen, Adrianna Mucinska, and Nadia
Marcinkova all took the Fifth when asked about Dershowitz's awareness of
sexual abuse of underage girls or whether Dershowitz was involved in
(see (see I I
Mugirls Ma0); cove
and and were were all non-

- Alan Derhsowitz) that provided immunity from prosecution sex trafficking not
only to Epstein but also to his "potential co-conspirators"; stein's Palm Beach mansion four or five times a year, staying two or three days INCHE

MIT BENICIAL FRET secution agreement (negotiated by, among others, Epstein defense attorney • One of f Epstein's household employees, Juan Alessi, said that Dershowitz visited f

when he went there - and Alessi was able to identify a photograph of Ms. Giuffre
who was at the as same )

	- as someone who was at the the time howitz (see

Mansion

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AL CHEY

A cus

Edwards, Bradley vs. Dershowitz

Case No.: CACE 15-000072

Edwards and Cassells Motion for Summary Judgment on

Epstein household employee, Alfredo Rodriguez, Sai NTCOAL CO

Page 16 of 20

	- that during the
time of his employment (2005), Dershowitz visited Epstein's mansion at the same
me as "massages" 'by underage girls were curring in the 1 ansion (see)
#9);

• When Rodriguez was arrested by the FBI trying to sell Epstein's "little black
of contacts and phone mbers, he appeared to have circled the name of
Dershowitz Dershowitz as someone who as someone who information about stein

		- 200dd
in that that he was an extremely close friend of Epstein he was an extremely
indeed, that the only person outside his immediately family with whom he
was

(see Exhibit #17);

Dershowitz had indicated

HOT COPYities (see Exhibit #17); shared drafts of his Ooks

had been made to

- Dershowitz or otherwise obtain information from him about his knowledge of Epstein's sexual abuse in 2009, 2011, 2013, and and he had avoided all those efforts (see Exhibit #

OCIAL Canuary 2015, a

- Dershowitz had told the Palm Beach Pol Department that he was going to
make Epstein available to answer questions about sex abuse of underage girls, but
then repeatedly rescheduled those meetings, ultimately never producing Epstein -
a pattern of deception deception that ared to be Signed berately berately delay t

LC LC

- DCP
pattern of avoiding deposition pattern of (and help Epstein Epstein Epstein
questioning) was consistent with a pattern of other persons who were involved in
Epstein's international sex trafficking organization evading
Formation from them;

by other powerful friends orts to obtain ICIAL COL

- Ms. Giuffre had alleged abue Epstein, including
Andrew, and there was a photograph showing Prince Andrew with his arm
she s the sex abuse had
taken place) (see Exhibit #11).

MTB Ms. Giuffre apparently taken in London (where she s Depo. Paul Cassell (Oct. 16 & 17, at 61-117 (Exhibit #3). Be #3).
5),

Edwards and Cassell clearly abused owerful basis a or believing allegation
that she had been made this

had

p

.

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Case 1:17-mc-00025-RWS

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Edwards and Cassells Motion for Summary Judgment on LiFIDIAL ESP Case No.: CACE 15-000072 Edwards, Bradley vs. Dershowitz

ANY OFFICAL COS

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Page 17 of 20

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17

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Filed 06/30/16

Page 19 of 29

CAL

Edwards, Bradley vs. Dershowitz

Case No.: CACE 15-000072

on

Page 18 of 20

that

statements Edwards Cassell
ofTe no
of these been in the which

intentional misconduct - a lies -- by

designed to culpability. Mowitz claimed that the flight logs w
him. had never looked at before Edwards Cassell.
sample, I
Depo. of Dershowitz at 239-42 2015) #13).
e airplan bikin
appears that "[a]s far as the planes are concerned, are flight

They I was never on any ivate any young wome 33 Hana
(Jan. 5, 20, eve
And yet a flight log Dershowitz on à a flight with a young woman

named ." Dershowitz also was to admit in his deposition whenever he met
Epstein "eye woman whom he des
with as

The 25 and 30.

OSTAL

also stated: been to the same woman for 28 She goes goes

know that I won't argue a case or give a unless y wife

travels me." Lawyer, 15, 2015. yet the aight for
Epst 's planes do not show Dersh s flights on and of wife à a single flight while showing EL Dershowitz

traveling without his wife on numerous i -including a flight with "Tatianna" on it.

HEAT TREIAAL Hight

Case 1:17-mc-00025-RWS Document 10-2 Filed 06/30/16 Page 20 of 29

Edwards, Bradley vs. Dershowitz

Case No.: CACE 15-000072

with

z travelted" 5, 2015. yet other a

and ICTAL AU

got a It's made le cloth."
But ershowitz said "I r
on an. 22, 20 Dershowitz Dershowitz Dershowitz said said he a my

on."

there there as the false nature
and Cassell.

of

## AS TO

Partial is in this case,
s strong protection for a Dr
reputation. the Fourth DCA has explained in

award in a

HOT OFFICIAL COPY HAT O

e damag defamation s is a value as old as the Pentateuch and the Book of Exodus, and its command HINTIP T

Florida's unusually high protection of personal reputation derives from the common consent of humankind and has ancient roots. It is highly valued by people. Our state constitution and common law powerfully support it. ized clear as the Decalogue: "Thou shall not bear false witness against thy ,, economics, business practices or money. It is a fundamental part of personhood, of individual standing and one's sense of worth. In short, the

NET OFFICIAL COATS The personal interest in one's own good name and reputation wrongdoing underlying the punitive damages in this case has Florida law's most severe condemnation, its highest blameworthiness, se, est. its most ing culpability. or [de se, reprehensibility is at its b Inc. v.

NOT OFTEN COMMIT

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OFFICIAL COPY

FINAL CH

Page 20 of 20

and law here support à not

Giuffre, but also Stably the that

and alleging tha two and e attorneys who
is the imshow
"There's surrounde "There's surrounde in good should be

Equally Ders Ms. tive behind Alan

high e media assa In his

e's an old saying:

'If you have the law on 1 your side, on the law.

- you have the facts on your side, bang on the f the f
incts.
in a

- f you have neither, bang on the table.'

- If I have never believed that, but I do believe in a variation on that

- of public opinion." you don't have the law or don't have the law opinion." facts on our side, argue facts on case in

Alan M. Alan M. the Stand the Stand Life in the

neither law nor facts available e to defend himself e to defend himself against of

Dershowitz followed his o own took his d
den ross
opinion where he had an audience willing to ignore both law and facts. The ksprescription a he lawyer

victims victims of of Dershowitz's Dershowitz's a a I by their personal to

HEY OFFICIAL abandon their faith attacks remained temporarily s HEY OFFICIAL abandon their faith attacks remained temporarily s abandon abandon their their faith faith em or the i their pro bono client. They led this
r entitlement C
action to protect their and now supports partial
e defa erected!
on the issues that Dershowitz made false and defamatory

them and, addition, Edwards ffered presumed Cements about

statements a

HE HE

20

Case 1:17-mc-00025-RWS

Filed 06/30/16

Page 22 of 29

HUT OFFICIAL COPY

维

Page 21 of 20

NIET OFFICIAL LY

AND CASSELL ARE ENTITLED TO SUN JUDGMENT

## ON THE COUNTERCLAIM ON THE BASIS OF ON THE BASIS OF EIR
DEFENSE OF

HOT DITHIN COPY

Heference
the same

As the is aware, and have a motion dismiss

counts First and have a Edwards an on the Cassell specifically on the
corporate
argu In this Cassell specifically herein by

the argument s advanced th If for any the Court were to find that the motion

dismiss could not be Edwards and
o summary: sed on the 1
1 the 0th counts on on of the Amended Glare c for many of

as well as based on evidence such
has admitted that the allegations Ed
fact that

Che
relevant to relevant

專

ted from to an action in the course judicial
statements igation privi Fand her a
of how false or the may be, as long as the

some to or with subject of " V.

Barfield, So. 3d 830, (4th DCA see also Mabie,

v. U.S. Ins. Co., So. 2d 1994). immunity

to e during the of a not only to the
partie statements made
a to judges, as well. as well. The The privilege
applies Oceeding b
all causes action, for common-law torts or torts or violations. violations.

TRYgation

C

HOT AFFICIAL Part

T

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Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
on
Page 22 of 20

A CHEY

& 30 So. 2d 380

by while a

to litigation covered by absolute the

Traynor, 3d 4 (Fla. Ct. App. Dist. 2010),

grante 47 3d vidence ecause itin "Dears t to be that is
figure," carry extra proving his

"clear and Zorc v. 765 So. 771 (Fla. DCA 2000).

NOT OFTEN COPY P a

HOT WHICH Crime

effectively narrow the on

a single Question: did the y pending the the
the Federal Dist sa
Victim's Rights Act cases Court the Southern

District of Florida have to that
answered that question n in the a 1 multiple occing. s duriershowitz has himself
on s recent depositi

HIT OFFICIAL CERT

You were asked on the occasion of that same Don Lemon CNN interview what possible motive the attorneys, Brad Edwards and Paul Cassell, could have had to have identified you in the pleading that was filed in the Crime Victim's Rights Act Case. Do you remember that? s right es. CUPT s right es.

RENC

And your response was quote quote "The want to be able Chall
plea agreement. I got the very good deal for Jeffrey Epstein." Che
Did you make

a response?

MOST SIREGINA COM MET CO

as of January 5, statements were filed in the Crime Victim's Rights Act case was because

22

R

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COPY

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Document 10-2

Filed 06/30/16

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Page 23 of 20 Edwards and Cassells Motion for Summary Judgment on Liability Case No.: CACE 15-000072 Edwards, Bradley vs. Dershowitz CURY T OFFICIAL COPY NOT OFFICIAL COPY OFFICIAL COPY
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COPY

FFICIAL COPY

NOT OFFICIAL COPY

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NOT OFFICIAL COPY NOT

NOT OFFICIAL CU Said this over and over again, they profiled me. They sat down with their NOT REFINAL Crime Victim's Act case had, as an including me, they could make a claim, false as it was, could make a false into including me when she didn't want to include me, because by client, knowing that she has a history of lying, knowing that she is easily They There we at you had negotiated for agreement quote: AL * Ne NPA was also criminally involved quote: AL * Ne NPA was also criminally involved were trying to line their pockets with money. But as I also said, and multiple motives. One of the motives orrect? COPY an! COPY objective, setting aside the NO y Epstein, c AL COPY NOT OFF AL COPY

NOT OFFICIAL COPY

NOTAL CUPY NOT OFFICIAL COPY COPY

NOT OFFICIAL CUPY

crassly financial. OFFICIAL NOT OFFICIAL COPY NOT OFFICIAL Cgestible, and they basically pressured her, according to my source COPY NOT OFFICIAL CORY with her. claim that a person who negotiated

NOT OFFICIAL COPY

NOT OFFICIAL COPY

NOT OFFICIAL Could find a lawyer who helped d NOT OFFICIAL Could find a lawyer who helped d P NOT OFF!
up the agreement." "who also was a criminal

they," referring to Bradley Edwards and

NICIAL COPY NUT-OFFICIAL COPY

NOT OFFICIAL COPY

NELT DESIment" that could
COPY

OFFICIAL COPY

OFFICIAL COPY

NOT OFFICIAL CO NOT OFFICIAL CUP A.
Depo. of
M.

Yes. UFFIC

Dide

UFFINALaving sex,

e that statement of

RY

NOT OFFICp them blow

NOT OFFICIAL COPY NOT OFFICIAL COPY

NUT r all the Vitz (Oct. 16, 2015), at 217-220 repeated it now, yes, under oath, yes. OFFICIAL NOT UFFICIAL COPY
the First s and Cassell DIAL CHY NOT OFFICIAL COPY
motion
But addition, a against dismissed are
Dersh Fhe Cupy the and evidence hi WAT SAL titled for as they
e on Count FIN I of the countercla; ad in Court.
NOT OFFICIAL COPY
OFFICIAL COPY NOT OFFICIAL COPY

NOT OFFICIAL COPY

NOT OFFICIAL COPY

counts
NOT OFFICIAL COAL
introduce

NOT CIAL COPY NOT OFFICIAL CUPY

NOT OFFICIAL CHIPY

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mary judo NOT OFFICIAL CUPY judgment is t given the the the proper way in their

NOT OFFICIAL COPY

NOT OFFICIAL OR ion, s because

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NOT DEFICIAL CIPY

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Case 1:17-mc-00025-RWS Document 10-2 Filed 06/30/16 Page 25 of 29

Case No.: CACE 15-000072

Edwards and Cassells Motion for Summary Judgment on Liabil

Page 24 of 20

Count I of t e pending terc it
length judgme
that judgment as to Count as well. As
in the record established and at
the motion to

showing Yeh disp that and Cassell not make
conta ything other t
against in ruling on this

actionable c judgment the "allegedly words must read in the of the

has simply collected Crshowitz. and if the documents not have a effect,

I may be dismisse " V. Jordan, 765 So. 2 (Fla.4th
of emails 768, 7
à claim. But when these o try t-as this Co000). together viable viable

s are each read in conte

ruling on summary judgment it is clear that Edwards Cassell were not

in a media but instead simply representing

avoid an example,

to allege that and defamed with the that "out
specie ershowitz.
respect for the court's e to keep this case from being litig in we are

to 1323 1906 4 time to Der of i First
Moreover,
at tries to claim a Cassell

sent an ail to a a journalist stating "I r woman who was sexually abused
resent... they
Andrew and in was ore than an
1 of Cassershowitz. y that permits a media represe ing sa context,
client in a to understa Who

disputed factY THAT SUP

Y Y

| NOT OFFICIAL COPY<br />NOT OFFICIAL COPY Case<br />Edwards, 1:17-mc-00025-RWS<br />NOT OFFICIAL COPY Paard 25 No.: CARS. Bradley COPY<br />NOT OFFICIAL CORS is of 2 Dershowitz<br />being AL COPY Motion Document<br />COAssed. that, Edwards discussed. for Summary 10-2<br />NOT OFFICIAL and<br />NOT OFFICIAL COPY hand. as Cassell See See ( Judgment Filed<br />on the For all Dershowitz's were Cassell Depo. on 06/30/16<br />these Simple simply at COPY Liability OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL mended reasons, asons, concession making 310-12 NOT OFFICIAL COPY Page 26<br />NOT OFFICIAL COP Edwards, For C summary summa in his a "fair DEAL (Oct. 17, COPY NOT OFFICIAL COPY of 29<br />the false Esq., the deposition report" 2015) NOT OFFICIAL COPY<br />foregoing judgment<br />NOT OFFICIAL COPY favor presumed and and Paul reasons, NOT OFFICIAL COPY in demonstrates, about NOTAL (Exhibit #3). COPY NOT OFFICIAL COPY NOT OFFICIAL COPY<br />NOT OFFICIAL COPY on the damages defamatory Cassell, CONCLUSIOFICIAL favor of properly-filed And NOT OFFICIAL COPY<br />NOT OFFICIAL First that nature Esq. defendant, COPY Edwards were relevant legal in addition, COPY<br />flow of partial the and plea<br />NOT OFFICIAL COPY NOT OFFICIAL COPY from the summary Court NOT OFFICE Cassell to the pleadings NOT OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL Counterclaim them. The statements should NOT OFFICIAL COPY is case at NOT OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL CORY f Court alleged judgment grant NOT OFFICPY appropriate<br />OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIA against should in their in their defendant NOT OFFICIAL COPY<br />NOT NOT OFFICIAL COPY NOT OFFICIAL COPY them also grant favor NOT OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL by complaint, on the Bradley NOT OFFICIAL COPY<br />COPY<br />NUT OFFICIAL COPY NOT OFFICIAL OFFICIAL COPY NOT OFFICIAL COPY Dershowitz. summary as well issues J.<br />COPY NOT OFFICIAL COPY NOT NOT OFFICIAL CORY judgment as of<br />NOT OFFICIAL NOT OFFICIAL COPY NOT OFFICIAL COPY in the NOT OFFICIAL COPY<br />OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY their OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY NOT<br />COPY<br />OFFICIAL COPY NOT OFFICIAL NOT OFFICIAL COPY NOT OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY<br />NOT OFFICIAL COPY<br />OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY<br />NOT OFFICIAL COR<br />OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY COPY<br />OFFICIAL COPY NOT OFFICIAL<br />NOT OFFICIAL COPY NOT<br />OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL COPY COPY<br />OFFICIAL COPY NOT OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL<br />OFFICIAL COPY<br />NOT OFFICIAL COPY<br />OFFICIAL COPY   |
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| NOT OFFICIAL COPY<br />NOT OFFICIAL COPY Case<br />Edwards, 1:17-mc-00025-RWS<br />NOT OFFICIAL COPY Paard 25 No.: CARS. Bradley COPY<br />NOT OFFICIAL CORS is of 2 Dershowitz<br />being AL COPY Motion Document<br />COAssed. that, Edwards discussed. for Summary 10-2<br />NOT OFFICIAL and<br />NOT OFFICIAL COPY hand. as Cassell See See ( Judgment Filed<br />on the For all Dershowitz's were Cassell Depo. on 06/30/16<br />these Simple simply at COPY Liability OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL mended reasons, asons, concession making 310-12 NOT OFFICIAL COPY Page 26<br />NOT OFFICIAL COP Edwards, For C summary summa in his a "fair DEAL (Oct. 17, COPY NOT OFFICIAL COPY of 29<br />the false Esq., the deposition report" 2015) NOT OFFICIAL COPY<br />foregoing judgment<br />NOT OFFICIAL COPY favor presumed and and Paul reasons, NOT OFFICIAL COPY in demonstrates, about NOTAL (Exhibit #3). COPY NOT OFFICIAL COPY NOT OFFICIAL COPY<br />NOT OFFICIAL COPY on the damages defamatory Cassell, CONCLUSIOFICIAL favor of properly-filed And NOT OFFICIAL COPY<br />NOT OFFICIAL First that nature Esq. defendant, COPY Edwards were relevant legal in addition, COPY<br />flow of partial the and plea<br />NOT OFFICIAL COPY NOT OFFICIAL COPY from the summary Court NOT OFFICE Cassell to the pleadings NOT OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL Counterclaim them. The statements should NOT OFFICIAL COPY is case at NOT OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL CORY f Court alleged judgment grant NOT OFFICPY appropriate<br />OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIA against should in their in their defendant NOT OFFICIAL COPY<br />NOT NOT OFFICIAL COPY NOT OFFICIAL COPY them also grant favor NOT OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL by complaint, on the Bradley NOT OFFICIAL COPY<br />COPY<br />NUT OFFICIAL COPY NOT OFFICIAL OFFICIAL COPY NOT OFFICIAL COPY Dershowitz. summary as well issues J.<br />COPY NOT OFFICIAL COPY NOT NOT OFFICIAL CORY judgment as of<br />NOT OFFICIAL NOT OFFICIAL COPY NOT OFFICIAL COPY in the NOT OFFICIAL COPY<br />OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY their OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY NOT<br />COPY<br />OFFICIAL COPY NOT OFFICIAL NOT OFFICIAL COPY NOT OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY<br />NOT OFFICIAL COPY<br />OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY<br />NOT OFFICIAL COR<br />OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY COPY<br />OFFICIAL COPY NOT OFFICIAL<br />NOT OFFICIAL COPY NOT<br />OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL COPY COPY<br />OFFICIAL COPY NOT OFFICIAL COPY<br />NOT OFFICIAL COPY NOT OFFICIAL<br />OFFICIAL COPY<br />NOT OFFICIAL COPY<br />OFFICIAL COPY   |

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Page 27 of 29

Page 26 of 20 Edwards and Cassells Motion for Summary Judgment on Lia P Edwards and Cassells Motion for Summary Judgment on Lia P Case No.: CACE 15-000072 Edwards, Bradley vs. Dershowitz FICIAL COPY I

Counsel on the attached list, HERE

CERTIFY that a true

ect copy of the foregoing was s

thday of November 2015.

via E-Serve to all

Fed Ex

NOT DIAL COPY NOT OFFICIAL COPY HOT OFFICIAL COPY

Jack Scarola

NET OFFlorida Bar No.: 169440

ey E-Mail(s): jsx@searcylaw.com and m

NET OFFICIAL COPY NOT BECmary E-Mail: scarolateam@searcylaw.com Phone: (561) 686-6300/Fax: (561) 383-9451 West Palm Beach, Florida 33409 Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard

NOT OFFICIAL CAPY NOT OFFICIAL CORY NOT OFFICIAL CHRY

Utah Attorney General SEAN D. REYES

NOT OFFICIAL CAPY NOT OFFICIAL

JOEL A. FERRE By: JONI J. JONES
Assistant Utah Attorneys General
Bradley J. Edwards
FARMER, JAFFE, WEISSING,
Telephone (954) 524-2820/Facsimile (954) 524-2822 FICIAL CHUY

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HITY OFFICIAL COPY NOT OFFICIAL EDWARDS, FISTOS & LEHRMAN, P.L. And E-mail: brad@pathtojustice.com Fort Lauderdale, Florida 33301 425 North Andrews Avenue, Suite 2

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Telephone:801-585-5202/Facsimile:NOT DECINAL CORY Salt Lake City, UT 84112 383 S. University St. S.J. Quinney College of Pro Hac Vice Motion University of Utah COPY at the

.Edwards and G. Cassell

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NIT OFFICIAL EPS FAPaul G. Cassell

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COPY NOT OFFICIAL COPY

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| OFFICIAL COPY NOT OFFICIAL COPY NOT OFFICIAL COPY                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |
| NOT OFFICIAL COPY NOT OFFICIAL COPY                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |
| OFFICIAL COPY NOT OFFICIAL COPY                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |
| NOT OFFICIAL COPY NOT OFFICIAL CORY                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |
| OFFICIAL COPY                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |
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| OFFICIAL COPY                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |
documents/doj-6de553bc9536f538.pdf
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