EFTA00191396

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Dexter Lee 
A. Marie Villafatia 
500 S. Australian Ave., Suite 400 
West Palm Beach, FL 33401 
EFTA00191396

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Johnson 
JANE DOE #1 and JANE DOE #2, 
Petitioners, 
1. 
UNITED STATES, 
Respondent. 
SEALED 
DOCUMENT 
EFTA00191397

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Johnson 
JANE DOE #1 and JANE DOE #2, 
Petitioners, 
UNITED STATES, 
Respondent. 
SEALED DOCUMENT 
MOTION TO SEAL 
Petitioners Jane Doc No. 1 and Jane Doe No. 2, joined by movants Jane Doe No. 3 and 
Jane Doe No. 4, move to file the attached pleading and supporting exhibit 30 under seal. A 
public pleading has been filed that has one sentenced redacted. That sentence comes from 
exhibit 30, which is correspondence sent by Alan Dershowitz and Gerald Lefcourt, attorneys for 
Jeffrey Epstein. 
As the Court is aware, the parties are currently briefing issues surrounding whether such 
correspondence should be kept under seal or filed in the public court file. See DE 286 
(requesting justification for a motion for a supplemental protective order). To give the Court the 
opportunity to rule on that issue before this correspondence is released, the victims are filing this 
under seal. It is the victims' view that these materials should be included in the public court file, 
for reasons articulated in the Opposition to Epstein's Motion for a Protective Confidentiality 
Order (DE 251). The victims intend to elaborate on their position in a filing they will make 
shortly. 
1 
EFTA00191398

WHEREFORE, Petitioners respectfully request that attached pleading and supporting 
exhibit 30 be sealed until further order of the Court. Alternatively, if the Court denies the instant 
motion to seal, then Petitioners respectfully request that their attached pleading and supporting 
exhibit 30 be filed in the public file and docketed as of today's date, as timely filed. 
DATED: January 21, 2015. 
Respectfully Submitted, 
Bradley J. Edwards 
FARMER, JAFFE, WEISSING, 
EDWARDS, FISTOS & LEHRMAN, P.L. 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, Florida 33301 
Telephone (954) 524-2820 
Facsimile (954) 524-2822 
E-mail: brad(gpathtojustice.com 
And 
Paul G. Cassell 
Pro Hoc 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: 801-585-6833 
E-Mail: [email protected] 
Attorneys for Jane Doe #1 and Jane Doe #2 
' This daytime business address is provided for identification and correspondence 
purposes only and is not intended to imply institutional endorsement by the University of Utah 
2 
EFTA00191399

CERTIFICATE OF SERVICE 
I certify that the foregoing document was served on January 21, 2015, on the following via 
US Mail: 
Dexter Lee 
A. Marie Villafaiia 
500 S. Australian Ave., Suite 400 
West Palm Beach, FL 33401 
(561) 820-8711 
Fax: (561) 820-8777 
E-mail: [email protected] 
E-mail: ann.marie.c.villafana@usdojdzov 
Attorneys for the Government 
Thomas Scott 
[email protected] 
COLE, SCOTT & KISSANE, P.A. 
Dadeland Centre H 
9150 South Dadeland Boulevard, Suite 1400 
Miami, Florida 33156 
Telephone: (305) 350-5300 
Facsimile: (305) 373-2294 
-and-
Kendall Coffey 
[email protected] 
Gabriel Groisman 
ggroisman®coffeyburlington.com 
Benjamin H. Brodsky 
bbrodsky®coffeyburlington.com 
COFFEY BURLINGTON, P.L. 
2601 South Bayshore Drive, PH 1 
Miami, Florida 33133 
Telephone: (305) 858-2900 
Facsimile: (305) 858-5261 
Attorneys for Alan Dershowitz 
/s/ Bradley J. Edwards 
1
EFTA00191400

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Johnson 
JANE DOE #1 and JANE DOE #2, 
Petitioners, 
I 
UNITED STATES, 
Respondent. 
/ 
ORDER GRANTING MOTION TO SEAL 
It is hereby ordered that the Unredacted version of Plaintiff's Response to Motion for 
Limited Intervention by Alan M. Dershowitz and Exhibit 30 of said Response be sealed until 
further order of this Court. 
DONE AND ORDERED in Chambers at Palm Beach County, Florida, this 
day of 
January, 2015. 
KENNETH A. MARRA 
UNITED STATES DISTRICT JUDGE 
EFTA00191401

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Johnson 
JANE DOE #1 and JANE DOE #2, 
Petitioners, 
v. 
UNITED STATES, 
Respondent. 
SEALED 
DOCUMENT 
EFTA00191402

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 9:08-cv-80736-KAM 
JANE DOE #1 and JANE DOE #2, 
Petitioners, 
vs. 
UNITED STATES OF AMERICA, 
Respondent. 
PLAINTIFFS RESPONSE TO MOTION FOR 
LIMITED INTERVENTION BY ALAN M. DERSHOWITZ 
COME NOW petitioners Janc Doc No. 1 and Jane Doc 2, as well as movants Jane Doe 
No. 3 and Jane Doe No. 4 ("the victims"l), to respond in opposition to Mr. Dershowitz's motion 
for limited intervention (DE 282). Dershowitz moves to intervene to strike a proffer made by 
Jane Doe No. 3 of facts that support her pending motion to join this action. The Court should 
deny the motion. Dershowitz has not established any direct interest in this Crime Victims' 
Rights Act (CVRA) action that would entitle him to intervene as of right under Fed. R. Civ. P. 
24(a). Nor has he met Rule 24(b)'s standards for discretionary intervention for four reasons: 
First, Dershowitz has another forum in which to litigate and defend his reputational interests — a 
pending defamation action regarding this very case; second, Dershowitz (and other persons Jane 
Doe No. 3 specifically alleged abused her) have not availed themselves of other opportunities to 
defend their reputational interests; third, Dershowitz lacks any basis to strike allegations that are 
directly relevant to pending issues in this case; and fourth and finally, Jane Doe No. 3 attests in a 
' As promised in their motion to join (DE 280), Jane Doe No. 3 and Jane Doe No. 4 do not seek to expand 
the number of pleadings filed in this case. If allowed to join this action, they would simply support the 
pleadings already being filed by Jane Doe No. 1 and Jane Doc No. 2 - including this opposition. 
EFTA00191403

sworn affidavit (attached as Exhibit I) that all her allegations are true - an affidavit consistent 
with compelling corroborating evidence. 
BACKGROUND AND COURSE OF PROCEEDINGS 
Because this case has been proceeding for more than six-and-a-half years, it is useful to 
summarize some of the events pertinent to Dershowitz's intervention motion and Jane Doe No. 
3's related and pending motion for joinder. As the Court is aware, on July 7, 2008, a young 
woman identified as Jane Doe No. I filed an emergency petition to enforce her rights under the 
Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, alleging that the Government had failed 
to provide her rights with regard to a plea arrangement it was pursuing with Jeffrey Epstein. The 
Court rapidly held a hearing. During that hearing, victim's counsel (having previously made a 
proffer of the relevant circumstances to Government counsel) orally moved to have Jane Doe 
No. 2 added into the case as another "victim" under the CVRA. Government counsel had no 
objection to adding her to the case, apparently believing that, in light of the sexual abuse 
perpetrated against her, she met the "victim" definition in the statute. DE 15 (Tr. July I I, 2008) 
at 14. 
The Court then instructed the parties to attempt to reach a stipulated set of facts. Over the 
next several years, the Government took conflicting positions on whether it would stipulate to 
facts provided by Jane Doe No. I and Jane Do. 2, ultimately refusing to stipulate to any facts. 
See generally DE 225-I at 2-4. Unable to obtain stipulations by the Government, in 2011 the 
victims filed a summary judgment motion alleging 53 proposed undisputed facts (DE 48), along 
with a motion to have the Court accept those facts because of the Government's failure to contest 
them (DE 49). On September 26, 2011, the Court allowed the case to move forward. DE 99. 
The Court, however, declined to accept victims' argument that it should simply accept their facts 
2 
EFTA00191404

because of the Government's failure to contest their facts, directing instead that discovery should 
proceed. M. at 11. 
In light of the Court's direction, on October 11, 2011, the victims filed discovery requests 
with the Government, including requests specifically seeking information about Dershowitz, 
Prince Andrew, and others. 
Further efforts from the Government to avoid any discovery 
followed (see generally DE 225-1 at 4-5),2 ultimately leading to a further Court ruling in June 
2013 that the Government should produce documents. DE 189. The Government then produced 
about 1,500 pages of irrelevant materials to the victims (DE 225-I at 5), while simultaneously 
submitting 14,825 pages of relevant materials under seal to the Court. The Government claimed 
that these pages were "privileged" for various reasons, attaching an abbreviated privilege log. 
Jane Doe No. I and Jane No. 2 objected to those claims of privilege, see generally DE 225 and 
DE 265, and also to the Government's failure to specify in its privilege log the names of all the 
persons involved in the materials (DE 265 at 1-2). These issues remain pending today.3
In the summer of 2014, undersigned counsel for Jane Doe No. 1 and Jane Doe No. 2 
contacted Government counsel to request their agreement to add an additional victim to this case: 
a young woman Jeffrey Epstein sexual abused when she was under age. On August 20, 2014, 
counsel sent a letter to U.S. Attorney Wilfredo Ferrer requesting the Govermnent's consent to a 
stipulated motion to simply add her into the case (as had been done earlier with Jane Doe No. 2). 
Counsel attached a draft proposed motion that would have blandly recounted that she was 
similarly situated to Jane Doe No. 1 and Jane Doe No. 2. See Exhibit 2. The proposed motion 
2 Jeffrey Epstein also attempted to block discovery of materials in this case, leading to an Eleventh Circuit 
ruling that the victims' discovery efforts were proper. Doe'. Epstein, 749 F.3d 999 (1 1 th Cir. 2014). 
3 Remarkably, even though the Court directed the Government to begin producing discovery in June 
2013, the Government has yet to finish that production some 19 months later. 
3 
EFTA00191405

did not include any of the facts surrounding her abuse, relying instead on a stipulation to secure 
the Court's anticipated approval. 
Three months later, having received no response from the Government, victims' counsel 
sent an additional letter to Mr. Ferrer, requesting agreement to add an additional victim to the 
case — a young woman identified in current pleadings as Jane Doe No. 34: 
Dear Mr. Ferrer: 
I sent you a letter in August requesting your office's stipulation to our 
adding Jane Doe #[4] in this case. Unfortunately, we did not receive a response 
from your office. We are hopeful that your lack of a response was simple 
oversight. 
In addition to following up on the August letter, we are now requesting 
your Stipulation to the adding of Jane Doe #[3] as well. Her true name is 
[redacted].... As we expressed in our personal meetings a couple years ago, we 
don't understand the tactical decision to be adversarial to victims of known sexual 
abuse on every point in this litigation. Now that many of those issues we 
discussed have been resolved in our favor, it seems to make even more sense to 
avoid engaging in unnecessary battles that could only serve the purpose of 
delaying the victims' rights to have this case resolved on its merits. 
As I indicated in my August letter requesting your stipulation to the 
adding of lane Doe #[4], adding Jane Doe #[3] will also not delay matters, so long 
as we can stipulate to her being added. 
Without a stipulation, we foresee 
litigation over this point, which will produce nothing but additional delay — and 
further question about your Office's commitment to full protection of victims' 
rights under the Crime Victims Rights Act. 
Your office is very familiar with [redacted) and her circumstance. She 
was sexually trafficked and abused by Mr. Epstein (and others at the direction of 
Mr. Epstein) not only in this jurisdiction but throughout the United States and 
beyond. . . . 
. . . [E]ven if you were to object and prevail on the motion to add her to 
the current litigation, the only consequence would be that Ms. [name redacted] 
would then file a separate CVRA lawsuit, something she is entitled to do because 
the CVRA contains no time limit. . . .We have, throughout this case, consciously 
avoided filing anything that would unnecessarily cast your office in a bad light, 
and it is again with that in mind that we request your stipulation here. We need 
this stipulation by December 10, 2014 to avoid delaying any other aspects of this 
case. We will not file any pleadings on this subject before that date. 
4 In the letter to Mr. Ferrer, the woman identified in current court pleadings as Jane No. 3 is referred to as 
"Jane Doe No. 4." For consistency with the court pleadings, the designations in correspondence have 
been modified here - as indicated by brackets - to track the current designation in the pleadings. 
4 
EFTA00191406

See Exhibit 3. Weeks went by and the Government — once again -- did not respond to counsel's 
request for a stipulation. This prompted a further email from counsel to the AUSA's handling 
this matter to inquire about the status of request: 
When we spoke a few months ago, I told you that we represented [Jane 
Doe No. 3) and were considering adding her to this suit. At the time of our call 
we asked if you would agree to our adding her, and 1 understood that you would 
have to check with others. Consequently, I sent a couple of letters to Mr. Ferrer 
that I have attached to this email. I was hoping for a response letting me know 
that the Office would not oppose the amendments adding Doe 3 and 4... . I realize 
our 11/19 letter asked for a response by the 10th. However, I was hoping you 
could give me some indication whether we will get an answer before the 10th 
(and perhaps what that answer will be), because if there will not be an agreement 
to adding these Plaintiffs then I want to get the Motion prepared. 
See Exhibit 4; see also Exhibit 5 (short response regarding trying to get an answer). 
On December 10, 2014, despite having had four months to provide a position, the 
Government responded by email to counsel that it was seeking more time, indicating that the 
Government understood that victims' counsel might need to file a motion with the court on the 
matter immediately: "The U.S. Attorney is on travel and I do not have an answer for you on 
whether the government will agree to the addition of two new petitioners. I appreciate you not 
filing your motion until December [15), 2014. If you need to file the motion, we understand. 
Thanks." See Exhibit 6. 
Rather than file a motion immediately, victims' counsel waited and continued to press the 
Government for a stipulation. See Exhibits 7, 8, and 9. Finally, on December 23, 2014 — more 
than four months after the initial request for a stipulated joinder into the case — the Government 
tersely indicated its objection, without indicating any reason: "Our position is that we oppose 
adding new petitioners at this stage of the litigation." See Exhibit 10. 
5 
EFTA00191407

Because the Government now contested the joinder motion, undersigned counsel 
prepared a more detailed pleading explaining the justification for granting the motion. One week 
after receiving the Government's objection, on December 30, 2014, Jane Doe No. 3 and Jane 
Doe No. 4 filed a motion (and later a corrected motion) seeking to join the case. DE 279 and DE 
280.5 Uncertain as to the basis for the Government's objection, the motion briefly proffered the 
circumstances of Jane Doe No. 3 and Jane Doe No. 4 that would qualify them as "victims" 
eligible to assert rights under the CVRA. See 18 U.S.C. 3771(e) ("For the purposes of this 
chapter, the term 'crime victim' means a person directly and proximately harmed as a result of 
the commission of federal offense . . . ."). With regard to Jane Doe No. 3, the motion indicated 
that when she was a minor, Jeffrey Epstein had trafficked her to Dershowitz and Prince Andrew 
(among others) for sexual purposes. Jane Doe No. 3 stated that she was prepared to prove her 
proffer. See DE 280 at 3 ("If allowed to join this action, Jane Doe No. 3 would prove the 
following . . . . "). The motion also provided specific reasons why Jane Doe No. 3's participation 
was relevant to the case, including the pending discovery issues regarding Dershowitz and Prince 
Andrew. DE 280 at 9-10 (explaining several reasons participation of new victims was relevant 
to existing issues). 
After the motion was filed, various news organizations published articles about it. 
Dershowitz also made numerous media statements about the filing, including calling Jane Doe 
No. 3 "a serial liar" who "has lied through her teeth about many world leaders." 
http://www.cnn.com/2015/01/06/usidershowitz-sex-allegation/. 
Dershowitz also repeatedly 
5 Dershowitz argues that Jane Doe No. 3 violated Local Rule 15.1 by failing to attach a proposed 
amended complaint. DE 282 at 2. But Jane Doe No. 3 was simply following the same approach that Jane 
Doe No. 2 had taken earlier, by filing a motion to join rather than a proposed amendment to pleadings. 
6 
EFTA00191408

called undersigned legal counsel for Jane Doe No. 3 "two sleazy, unprofessional, disbarable 
lawyers." Id. On January 5, 2015, Dershowitz filed the pending motion to intervene. DE 282. 
DISCUSSION 
Dershowitz's motion to intervene relies on Fed. R. Civ. P. 24(a) (mandatory intervention) 
and 24(b) (permissive intervention). Neither argument for intervention is well-founded. 
I. 
DERSHOWITZ'S ALLEGED "REPUTATIONAL" INTERESTS DO NOT 
SATISFY RULE 24(A)'S REQUIREMENTS FOR INTERVENTION AS OF 
RIGHT. 
Dershowitz first claims that he meets Rule 24(a)'s requirements for mandatory 
intervention. Rule 24(a) requires that the Court allow a person to intervene in a case if that 
person "claims an interest relating to the property or transaction that is the subject of that action 
and is so situated that disposing of the action may as a practical matter impair or impede the 
movant's ability to protect his interest, unless existing parties adequately represent that interest." 
Dershowitz contends he meets Rule 24(a)'s requirements because he has a "reputational" interest 
in the matter, specifically an interest in contesting Jane Doe No. 3's allegation that Jeffrey 
Epstein trafficked her to Dershowitz for sexual purposes. 
Numerous courts have declined to allow a mere "reputational" interest to justify 
mandatory intervention. For example, Calloway" Westinghouse Eke. Cop., 115 F.R.D. 73 
(M.D. Ga. 1987), denied a motion to intervene where the alleged interest was a doctor's "own 
reputation and academic credibility." Id. at 74. The court denied intervention because "a 
witness' interest in his reputation alone . . . does not constitute the required 'interest relating to 
the property or transaction which is the subject of the present action' necessary to allow 
intervention as a matter of right. To find otherwise would invite intervention every time a court 
is required to determine the credibility of a witness." Id. Similarly, Flynn 
I
 
Hubbard, 82 F.2d 
7 
EFTA00191409

1084, 1093 (1st Cir. 1986), affirmed the denial of the Church of Scientology's request for 
intervention in part because "the church "merely claim[ed] a generalized injury to reputation 
[that] identifies no legal detriment arising from a default judgment against Hubbard." Id. at 1093 
(Coffin, J., concurring). See also Edmondson". State of Neb. a rel. Meyer, 383 F.2d 123, (8th 
Cir. 1967) ("The mere fact that Edmondson's reputation is thereby injured is not enough [to 
support intervention]. Edmondson's representative has pointed to no legal detriment flowing 
from this possible finding of the trial court, and we can find none."); Forsyth County". U.S. 
Army Corps of Engineers, No. 2:08-CV-0126-RWS, 2009 WL 1312511, at *2 (N.D. Ga. May 
8, 2009) (denying intervention because an "interest in protecting its reputation . . . is not direct, 
substantive, or derived from a legal right").6
The Court has previously considered — and rejected — a similar effort to intervene on a 
"reputational" claim. That claim was made by Bruce Reinhart who — like Dershowitz — had 
previously represented Jeffrey Epstein's interests in related litigation. 
Reinhart moved to 
intervene in this case to contest the victims' allegations that Reinhart (a former prosecutor in the 
U.S. Attorney's Office investigating Epstein) received confidential, non-public information 
about the investigation. The victims specifically alleged that Reinhart had 'joined Epstein's 
payroll shortly after important decisions were made limiting Epstein's criminal liability' and that 
Reinhart had gone on to improperly represent Epstein-related witnesses in various civil suits. 
See DE 99 at 12 (discussing DE 48 at 23). Reinhart filed a sworn affidavit admitting that he had 
represented Epstein-related clients, but claiming that he did not possess any such confidential 
information. He sought to intervene to challenge the victims' arguments. 
6 Dershowitz cites dicta in Saclmian I Liggett Gip., Inc., 167 F.R.D. 6, 20-21 (E.D.N.Y. 1996), that a 
reputational interest can support intervention. But Sackman did not analyze the issue; rather it simply 
cited another case, Penthouse Intl, Ltd. I Playboy Enterprises, Inc., 663 F.2d 371, 373, 392 (2d Cir. 
1981), which in turn contains no analysis of the issue or any such holding. 
8 
EFTA00191410

After a hearing, the Court denied Reinhart's motion, finding that his interest in litigating 
the validity of the victims' allegations was too attenuated to support intervention. DE 99 at B.7
The Court's rationale applies equally here and should lead the Court to deny Dershowitz's 
motion. Dershowitz claims that his situation is distinguishable in view of how "harmful" (DE 
282 at 6) he believes the current allegations are. But the degree of indignation at allegations is 
not a sound basis for allowing intervention. As the Court previously explained, it "cannot permit 
anyone slighted by allegations in court pleadings to intervene and conduct mini-trials to 
vindicate their reputation." DE 99 at 13. 
Dershowitz does have an alternative ground he could try to advance for intervention. As 
Jane Doe No. 3 pointed out in her motion to join the case, Dershowitz personally helped to 
negotiate the non-prosecution agreement (NPA) at issue in this case, which bars his prosecution 
in the Southern District of Florida as a "potential co-conspirator of Epstein." DE 280 at 4 
(quoting NPA at 5). The Court has previously allowed Epstein to prospectively intervene in any 
proceedings that might involve invalidating the NPA. DE 246. Dershowitz can make a similar 
motion if he identifies himself as a potential co-conspirator involved in crimes covered by the 
NPA. But lacking such an allegation, his existing motion does not allege any concrete 
impainnent of his interests supporting mandatory intervention. 
II. 
DERSHOWITZ IIAS NOT SHOWN THAT THE COURT SHOULD ALLOW 
PERMISSIVE INTERVENTION UNDER RULE 24(B). 
7 During the hearing on Reinhart's intervention motion, the Government stood silent about the accuracy 
of Reinhart's affidavit. Much later, after the Court had denied the motion, the Government admitted that 
it possessed information contradicting Reinhart's sworn affidavit. See DE 225.1 at 9-10, ¶¶ 43-45 ("in 
answering the victims' Requests for Admissions, the Government has admitted that it possess information 
that Reinhart leamed confidential non-public information about the Epstein case and he discussed the 
Epstein case with other prosecutors."). 
9 
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Dershowitz also contends that the Court should exercise its discretion to allow permissive 
intervention in this case under Fed. R. Civ. P. 24(b). The rule grants discretion to the court to 
allow intervention by a person who has "a claim or defense that shares with the main action a 
common question of law or fact." Fed. R. Civ. P. 24(b); accord Mt. Hawley his. Co. • Sandy 
Lake Properties, Inc., 425 F.3d 1308, 1311 (11th Cir. 2005) (permissive intervention allowed 
only where "a claim or defense and the main action have a question of law or fact in common 
and the intervention will not unduly prejudice or delay the adjudication of the rights of the 
original parties."). A district court's ruling on such intervention is reviewed only for abuse of 
discretion. Stone' First Union Corp.. 371 F.3d 1305, 1309 (11th Cir. 2004); see also AT&T 
Cap. ' 
Sprint Corp., 407 F.3d 560, 561-62 (2nd Cir. 2005) ("[a] denial of permissive 
intervention has virtually never been reversed" because of the considerable discretion afforded to 
district courts). 
In ruling on a motion for permissive intervention, the Court must consider all relevant 
factors, including "the nature and extent of the intervenor's interest." Poly'. Proposition 8 
Official Proponents, 587 F.3d 947, 955 (9th Cir. 2009). Here, Dershowitz lacks a "claim or 
defense" in common with the CVRA action. Instead, Dershowitz intends to advance satellite 
arguments, including raising questions about the credibility of crime victims that the 
Government apparently does not intend to presents Allowing his intervention would thus create 
a clear risk of adding undue delay to what is already a long-running case. Cf. id. (affirming 
district court decision to deny intervention that would "consume additional time and resources of 
8 For example, in the media Dershowitz has called lane Doe No. 3 — an alleged victim of international sex 
trafficking while she was a minor — "a serial perjurer, serial liar, serial prostitute." Washington Post, 
Morning 
Mix, 
http://www.washingtonpost.com/news/moming-mix/wp/2015/01/06/alan-dershowitz-
takes-legal-action-after-being-named-with-prince-andrew-in-scx-ring-caseJ . 
10 
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both the Court and the parties that have a direct stake in the outcome of the proceedings"). 
Moreover, several other important factors weigh against allowing intervention. 
A. DERSHOWITZ CAN LITIGATE HIS REPUTATIONAL INTERESTS IN A 
PENDING DEFAMATION ACTION IN BROWARD COUNTY CIRCUIT 
COURT. 
In the opening paragraph of his court pleading, Dershowitz claims he has "no remedy" to 
defend his reputation. DE 81 at 1. And yet, in his statements to the media, Dershowitz has made 
clear that he intends to defend his reputational interests in a pending defamation action. The 
Court need not allow duplicative litigation on the same reputational issues. 
After Jane Doe No. 3 filed her motion to intervene, Dershowitz attacked her in the media 
as a "serial perjurer." He also repeatedly named and attacked her attorneys — i.e., undersigned 
legal counsel Edwards and Cassell — branding them, among other disparaging names, "two 
sleazy, unprofessional, disbarablc lawyers." Dershowitz repeated his attacks on numerous 
worldwide media outlets, saying such things as victims' counsel "are prepared to lie, cheat and 
steal. These are unethical lawyers" (CNN Program "The World Right Now with Hala Gorani," 
Jan. 5, 2015) and that counsel "willfully and deliberately made this up in order to gain a 
litigation advantage, [to] line their pockets with money" (The Last Word with 
O'Donnell — MSNBC (Jan. 8, 2015). 
Following these statements, on January 6, 2015, attorneys Edwards and Cassell, 
represented by Jack Scarola, Esq., filed a defamation action in Broward County Circuit Court. 
See Exhibit 11 at 1117 (alleging Dershowitz has "initiated a massive public media assault on the 
reputation and character" of undersigned counsel, by "accusing them of intentionally lying in 
their filings, of having leveled knowingly false accusations against [Dershowitz], without ever 
conducting any investigation of the credibility of the accusations"). The attorneys also served 
II 
EFTA00191413

discovery requests on Dershowitz, as well as a notice of deposition. Dershowitz has yet to agree 
to a deposition date. 
Faced with a defamation action against him, Dershowitz stated that he was "thrilled" by 
the development because it "gives me a chance to litigate the case. 1 can expose their corruption. 
I can show how fraudulent the allegations are. This makes my day." Wall St. Journal Law Blog, 
http://blogs.wsj.com/law/2015/01/06/jane-doe-lawyers-sue-dershowitz-for-defamation/ (Jan. 6, 
2015); see also UMAR News, 
(Jan. 4, 2015) 
("1 just need a legal proceeding .. . to call witnesses ... to prove my case" (emphasis added)). 
Given that Dershowitz has the opportunity to litigate his concerns in the other case, this 
Court need not — and should not — allow permissive intervention in this one. See, e.g., Morgan
Sears, Roebuck & Co., 124 F.R.D. 231 (1988) (declining intervention in one case where 
litigation on a similar issue was already underway elsewhere). Permissive intervention in this 
case would, for example, presumably lead to Dershowitz (and, in turn, undersigned legal 
counsel) seeking duplicative discovery to that which is already being sought in Broward County 
Circuit Court. One forum is enough to litigate reputational issues. 
B. DERSIIOWITZ SHOULD NOT BE ALLOWED TO INTERVENE IN THIS 
ACTION WHEN HE HAS DECLINED TO DEFEND HIS REPUTATION IN 
OTHER ACTIONS. 
Dershowitz also claims that he has not been given an opportunity to address his 
connection to Epstein's sex trafficking. DE 282-1 at 3. This is untrue. Indeed, Dershowitz has 
been given (at least) three separate opportunities to provide information concerning his 
involvement in Epstein's offenses. Because Dershowitz has not availed himself of any of those 
prior opportunities, the Court should deny his motion to intervene now. 
2009 
12 
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On about September 17, 2009, one of undersigned counsel (Brad Edwards) arranged to 
have Dershowitz served with a subpoena for deposition in connection with a civil case brought 
by one of the underage females who had sued Epstein (Doe 'Epstein, No. 9:08-cv-80893-KAM 
(S.D. Fla.)). At that point, Dershowitz understood that counsel for many of Epstein's victims 
believed that mounting evidence pointed toward his role extending beyond merely being an 
attorney for Epstein. That deposition ultimately did not occur, and Dershowitz made no effort to 
provide information about his knowledge of relevant information. 
2011 
In 2011, in the state case of Epstein 1 Edwards (No. 502009CA040800XXXXMBAG 
(Palm Beach Cty. Cir. Ct.)), counsel for Edwards (Jack Scarola, Esq.) contacted Dershowitz to 
seek his cooperation in answering questions about his knowledge of Epstein's sex trafficking. 
On August 15, 2011, Dershowitz indicated that he wanted more information before would decide 
whether to cooperate: "If you would let me know what non-privileged information you would 
seek from me, I would then be able to decide whether to cooperate." See Exhibit 12 (emphasis 
added). 
On August 23, 2011, Scarola sent a letter to Dershowitz, explaining that there was no 
intent to inquire about attorney-client information, but adding: "[wje do, however, have reason to 
believe that you have personally observed Jeffrey Epstein in the presence of underage females, 
and we would like the opportunity to question you under oath about these observations." See 
Exhibit 13. Dershowitz declined to cooperate, so on September 7, 2011, Scarola again sent a 
letter to Dershowitz, noting that while there was "no obligation" to disclose the basis for wanting 
a deposition, the reason was that "[m]ultiple individuals have placed you in the presence of 
Jeffrey Epstein on multiple occasions and in various locations when Jeffrey Epstein was in the 
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