This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →
FBI VOL00009
EFTA01111154
54 pages
Pages 41–54
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' 4 95 1 2 3 MS. McCAWLEY: I have a standing objection and, I'm objecting again. I'm not going to -- THE WITNESS: No, no, no. Does she have 11:39:47 11:39:49 4 standing in this deposition? 5 MR. SCOTT: Let's take a break for a 11:39:51 6 minute, okay? 7 THE WITNESS: I'm not sure she has standing. 11:39:54 9 MR. SCAROLA: Arc we finished with the 11:39:57 10 speech? 11 MR. SCOTT: No. If he -- 11:39:58 12 MR. SCAROLA: I'd like him to finish the 11:39:59 13 speech so that we can get to my question and 14 then we can take a break. 15 A. So the question -- the answer to your 11:40:02 16 question is -- ^5- <> 17 N.R. SIMPSON: Wait a minute. Wait a 18 minute. Wait a minute. Please don't disclose %•••.' 19 something that she has a right to raise that S>/ objection if she wants to. MR. SCOTT: Exactly. 11:40:13SP. 22 23 \ 44 4 4 .2$›- <1 the THE WITNESS: Okay. 11:40:14 MR. SCOTT: Ask your question. .11:40:17 A CO) : .,$≥1 MR. SWEDER: Maybe you want to read back,S, 11:40:2tw %Sty ,A .44\ 4 A \ 4 C SN' .:( ..t 4 last couple of sentences. AC" Nr A" sci,' "C..'" N ,' A , <I5C ' ) _ .\.:'' 4t'" N : S • EFTA01111194
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Sigrid McCawley From: Sigrid McCawley Sent: Tuesday, February 16, 2016 11:10 AM To: 'Mary E. Pirrotta; Simpson, Richard; Bor. , Ma ; Eiler, Ashley; [email protected]; Cc: ad Edwards (MINIM ); Paul Cassell Subject: RE: Regarding: Edwards, Bradley vs. Dershowitz (File fr: 20150013) Hello Mary — the parties have agreed to move my motions set for tomorrows hearing to the special set that is already on the calendar for March 11th and bump the March 11"' motions to a later date special set. My understanding is that Jack is in agreement with that plan. I am preparing now a Notice of Cancellation for tomorrow's hearing and rescheduling my motions for the March date. I don't believe Jack'spresence is required for the re-scheduled March lf motions as they are motions that relate to non-part Dershowites lawyers will then file a Notice of Cancellation for their Motions pending on March li n and move them to a later special set hearing time. Thank you, Sigrid Siprid S. McCav1/4 Partner BOIES,SCIIILLER & FLEXNER LIP 401 Fast f.as ()Las B1‘(1.. Suite 1200 Fort Lauderdale, 33301 From: Mary E. Pirrotta [mailto: Sent: Tuesday, February 16, 2016 10:59 AM To: Sim son, Richard; Borja, Mary; Eiler, Ashley; Sigrid McCawley; - Cc Brad Edwards Paul Cassell Su egar Mg : ards, Bradley vs. Ders owitz (Ft 1 0013) I received a Notice of Hearing for March 11 (a date that was not coordinated with us) for some of the matters that were scheduled for tomorrow but not all. Is that correct? From: Simpson, Richard.....111 1M Sent: February 16, 2016 10.54 AM To: Ma E. Pirrotta < • Bor a Ma ; Eiler, Ashle au assell Subject: RE: Regarding: Edwards, Bradley vs. Dershowitz (File #: 20150013) Those hearings are being taken off calendar and rescheduled • EFTA01111196
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From: Mary E. Pirrotta Sent: Tuesday, February 16, To: Boda, Mary; Eiler, Ashley; Mal Subject: Regarding: Edwards, Bradley vs. Dershowitz (File #: 20150013) Simpson, Richard; Please confirm hearings scheduled for tomorrow 2/17 at UMC (8:45 a.m.) and Specially Set at 10:00 a.m. Thank you. ****************************************************************************************** Privileged and Confidential I Electronic communication is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firm of Seamy Denney Scarola Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. 52510- 2521. The information contained in this E-mail message is privileged and confidential under Ha. R. hid. Admin. 2.420 and information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this communication is strictly prohibited. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you rec ived this communication in error, please notify the sender immediately by e-mail or by telephone at nd destroy all copies of the original message. Thank you. ********************* ***** ********************* ****** ************************************* NOTICE: This message (including any attachments) from Wiley Rein UP may constitute an attorney-client communication and may contain information that is PRIVILEGED and CONFIDENTIAL and/or ATTORNEY WORK PRODUCT. If you are not an intended recipient, you are hereby notified that any dissemination of this message is strictly prohibited. If you have received this message in error, please do not read, copy or forward this message. Pleas any attachments and notify the sender immediately by sending an e-mail t 2 EFTA01111197
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! EXHIBIT 4 EFTA01111198
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Filing it 37850740 E-Filed 02/16/2016 11:46:12 AM IN THE CIRCUIT COURT OF THE 171H JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION BRADLEY J. EDWARDS, and CASE NO. CACE 15-000072 PAUL O. CASSELL, Plaintiffs, v. ALAN DERSHOWITZ, Defendant. RE-NOTICE OF SPECIAL SET HEARING f J hour) YOU ARE HEREBY NOTIFIED that the February 17, 2016 hearing is being rescheduled before the Honorable Thomas Lynch, IV, Circuit Court Judge, Seventeenth Judicial Circuit Court, Broward County Courthouse, 201 S.E. 6th Street, Room 950, Fort Lauderdale, Florida 33301, to Friday, March) 1,2016 beginning at 10:00 a.m., and will address the following matters: I) Non-Party otion to Strike And For Sanctions; 2) Non-Party Sanctions pplemental Motion to Strike and For 3) Defendant Alan Dershowitz's Motion in Limine to Overrule Objections NOTICE TO DISABLED PERSONS I If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you arc entitled, at no cost to you, to the provision of certain assistance. Please contact the Seventeenth Judicial Circuit's ; ADA Coordinator at 201 S.E. Sixth Street, Fort Lauderdale, FL 333W, telephone number (954) 831-7721, within two (2) working days of receipt of this document. TDD users may also call 1.800.955-8771 for the Florida Relay I Service. EFTA01111199
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Dated: February 16, 2016 Respectfully submitted, BOLES, SCHILLER & FLEXNER LLP Sigrid S. McCawley, Esq. Ion a Bai ll 1.9” 401 East Las Olas Boulevard, Suite 1200 as 1 Sigrid S. McCawley, Esq. - Attorney for Non-Party Virginia Giuffre CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served by Electronic Mail on February 16, 2016 to the individuals identified on the attached Service List. By: Is/Sigrid S. McCawley Sigrid S. McCawley 2 EFTA01111200
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SERVICE LIST 9150 S. Dadeland Blvd., Suite 1400 Miami, Florida 33156 4 \. s ey L. ler CO Nicole Richardson WILEY REIN, LLP 1776 K Street NW Washington, D.C. 20006 Jack Scarola SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, P.A. Blvd. West Palm Beach, FL 33409.6601 Attorney Jar Plaints:QS aO aO Counsel for Defendant Alan Dershowit: aO cA <4;,:s• ca :,- .t., -s.. • \=,-- . :z,t ' ca s>.'s" 'P * <s- -s ,.& 3 CSA EFTA01111201
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EXHIBIT 5 EFTA01111202
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Page 1 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT 1N AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS, and PAUL G. CASSELL, Plaintiffs, vs. ALAN DERSHOWITZ, Defendant. TRANSCRIPT OF NON-PARTY EMERGENCY MOTION TO SEAL DATE TAKEN: December 18, 2015 TIME: 9:26 a.m - 9:45 a.m. PLACE: Broward County Courthouse 201 Southeast 6th Street Fort Lauderdale, Florida 33301 BEFORE: Thomas M. Lynch, IV, Circuit Court Judge This cause came on to be heard at the time and place aforesaid, when and where the following proceedings were reported by: Michele Cameron MAG NA 0 LEGAL SERVICES EFTA01111203
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Page 2 1 APPEARANCES: 2 On behalf of Non-Party, 3 SIGRID MCCAWLEY, E. .= BOIES, SCHILLER & FLEXNER, LLP 4 401 East Las Olas Boulevard Suite 1200 5 Fort Lauderdale, Florida 33301 6 7 On behalf of the Defendant: 8 STEVEN R. SAFRA, ESQUIRE COLE, SCOTT, KISSANE, P.A. 9 9150 South Dadeland Boulevard Suite 1400 10 Miami, Florida 33156 11 12 13 NO EXHIB ITS MARKED 14 15 16 17 18 19 20 21 22 23 24 25 MAGNAO LEGAL SERVICES EFTA01111204
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Page 23 1 negotiations between the parties. It is 2 without question that these were settlement 3 conversations. 4 I appreciate what he is trying to refer 5 to, this later mediation with Judge 6 Streitfeld. There is a mediation that has 7 gone on in the last couple of weeks with 6 Judge Streitfeld. These were confidential 9 settlement negotiations that started in May 10 and went up to the present; so to say that -- 11 THE COURT: I agree with you. I think 12 they're confidential settlement discussions. 13 I'm going to grant the Motion to Seal. 14 MS. MCCAWLEY: Thank you, Your Honor. 15 MR. SAFRA: Well, Your Honor -- 16 THE COURT: Over the strong objection of 17 the Defendant. 18 MR. SAFRA: Can I, for the record -- 19 MS. MCCAWLEY: Thank you. 20 MR. SAFRA: -- at least also reserve 21 that for the relief that needs to be shown 22 irreparable harm, death, or manifest injury, 23 and it's our position that that hasn't been 24 shown in the requested relief. 25 THE COURT: You don't think confidential MAG NA 0 LEGAL SERVICES EFTA01111205
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Page 24 1 settlement agreements should be sealed? I 2 know you don't think they are confidential 3 settlement agreements -- 4 MR. SAFRA: Well -- 5 THE COURT: -- but if they are, which 6 I've made that finding, you don't think they 7 should be sealed? 8 MR. SAFRA: Well, you're making the 9 finding that they were confidential 10 settlement -- 11 THE COURT: I am. 12 MR. SAFRA: -- but that wasn't at issue 13 here, and they haven't even filed the 14 opposition, and we have our Motion in Limine; 15 so you're ruling upon that when -- 16 THE COURT: No. I'm just sealing these 17 because I think they should be sealed. 18 MR. SAFRA: Okay. 19 THE COURT: Although, you know -- 20 MR. SAFRA: Take your words for the 21 future. 22 THE COURT: -- everyone is aware of 23 MR. SAFRA: Understood. 24 THE COURT: Well, everyone. Whoever 25 read the New York Times is aware of the MAG NA LEGAL SERVICES EFTA01111206
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Page 25 1 situation; so I will grant the motion. 2 MR. SAFRA: For clarity, the Motion in 3 Limine, when that gets scheduled, is your 4 finding that it's a settlement 5 communication -- 6 THE COURT: I'll listen to any argument 7 anyone has on any issue. We're not doing 8 that today. 9 MR. SAFRA: Just the seal. 10 THE COURT: I'm available for hearings 11 anytime after the 3rd of January. 12 MR. SAFRA: And can I state, so you 13 don't get a disagreement where we end up back 14 before the Court -- just because I'm aware 15 and I want to raise -- 16 MS. MCCAWLEY: Right. 17 MR. SAFRA: -- it and so that you have 18 an opportunity, it is our position or my 19 client's position that these meetings 20 occurred in New York and that the sealing 21 would apply to the public filings and in 22 Florida. 23 MS. MCCAWLEY: Your Honor, if the intent 24 here is to continue to spew the confidential 25 settlement negotiations and have MAG NA 0 LEGAL SERVICES EFTA01111207
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