EFTA01116693

Filing # 34801581 E-Filed 11/23/2015 05:53:31 PM 
IN 
THE 
CIRCUIT 
COURT 
OF 
THE 
SEVENTEENTH JUDICIAL CIRCUIT, IN 
AND FOR BROWARD COUNTY, FLORIDA 
CASE NO.: CACE 15-000072 
BRADLEY J. EDWARDS and PAUL G. 
CASSELL, 
Plaintiffs, 
vs. 
ALAN M. DERSHOWITZ, 
Defendant. 
PLAINTIFFS/COUNTERCLAIM DEFENDANT EDWARDS AND 
CASSELL'S RESPONSE TO DERSHOWITZ'S MOTION TO DETERMINE 
CONFIDENTIALITY OF COURT RECORDS 
Plaintiffs/Counterclaim Defendants Bradley J. Edwards and Paul G. Cassell, by and 
through their undersigned attorneys, hereby file this response to Dershowitz's Motion to 
Determine Confidentiality of Court Records. The records at issue are not confidential, and so the 
Court should deny Dershowitz's motion in its entirety. 
The court records at issue are three court filings by attorneys Edwards and Cassell 
in which they recite their client's (Mr. 
allegations that she was sexually 
abused by Dershowitz. These records are hardly "confidential" in this defamation case, 
where the 
parties 
have 
claims and counterclaims about 
these sexual abuse 
Allegations. Rather, these records are an important part of this case, since they not only 
support the conclusion that Dershowitz abused Ms. 
a
l
 
ut also indisputably establish 
Edwards and Cassell's strong basis for filing the allegations on her behalf. Moreover, 
contrary to assertions made in Dershowitz's motion, these documents have never been 
found to be "confidential" by any other court. And Dershowitz has repeatedly referred to 
EFTA01116693

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
Page 2 of 20 
these documents, not only in defamatory statements broadcast worldwide, but also in his 
pleadings before this Court and in recent depositions. Indeed, Dershowitz said in his 
media interviews that he wants "everything to be made public" and implied that Edwards 
and Cassell had something to hide. Accordingly, Dershowitz has failed to carry his heavy 
burden to justify sealing these presumptively-public documents. 
I. 
DERSHOWITZ HAS NOT JUSTIFIED SEALING ALLEGED 
DEFAMATORY RECORDS THAT ARE INTEGRAL TO THIS 
DEFAMATION CASE. 
In his motion, Dershowitz never recounts the heavy burden that he must carry to seal the 
records at issue. To be sure, Florida Rule of Judicial Administration 2.420 allows for the sealing 
of "confidential" materials. But the Rule begins by recounting the overarching principle that 
"[t]he public shall have access to all records of the judicial branch of government, except as 
provided below." Fla. R. Jud. Admin. 2.420(a). This rule is a codification of the Florida 
Supreme Court's admonition that a "a strong presumption of openness exists for all court 
proceedings. A trial is a public event, and the filed records of court proceedings are public 
records available for public examination." Barron v. Florida Freedom Newspapers, Inc., 531 
So.2d 113, 118 (Fla. 1988) (emphasis added). In light of this presumption of openness, "[t]he 
burden of proof in [closure] proceedings shall always be on the party seeking closure." Id. To 
obtain a sealing order, the party seeking sealing must carry a "heavy burden." Id. 
Remarkably, Dershowitz fails to acknowledge these well-settled principles. More 
important, he even fails to cite (much less discuss) the limited substantive exceptions to this 
general principle of access — and which specific exception he believes applies to this 
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Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Edwards and CasselIs Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
Page 3 of 20 
case. Accordingly, it is impossible for Edwards and Cassell to respond with precision to his 
motion. 
The exceptions that might arguably be in play in this case permit records to be maintained 
as confidential in order to: 
(1) 
Prevent a serious and imminent threat to the fair, impartial, and orderly 
administration of justice; 
(ii) 
Protect trade secrets; 
(iii) 
Protect a compelling governmental interest; 
(iv) 
Obtain evidence to determine legal issues in a case; 
(v) 
Avoid substantial injury to innocent third parties; 
(vi) 
Avoid substantial injury to a party by disclosure of matters protected by a 
common law or privacy right not generally inherent in the specific type of 
proceeding sought to be closed; 
(vii) 
Comply with established public policy set forth in the Florida or United 
States Constitution or statutes or Florida rules or case law . 
Fla. R. Jud. Admin. 2.420(c)(9) (codifying the holding in Barron v. Florida Freedom 
Newspapers, Inc., 531 So.2d 113 (Fla. 1988)). The only exception that seems to even arguably 
apply here is exception vi, which itself specifically provides that confidentiality is appropriate 
only where disclosure is "not generally inherent in the specific type of proceeding sought to be 
closed" (emphasis added). Of course, this lawsuit is a defamation action — involving 
a defamation claim 
by 
Edwards 
and 
Cassell 
and 
a defamation counterclaim 
by 
Dershowitz. Disclosure, discussion, and debate about the defamatory statements at issue lies at 
the heart of the case. Accordingly, disclosure of these materials is "inherent" in the case itself. 
The principle that defamatory material in a defamation case cannot be sealed is recognized 
in Carnegie v. Tedder, 698 So.2d 1310 (2d DCA 1997). Carnegie involved a claim and 
counterclaim between two parties (Carnegie and Tedder), one of whom alleged that disclosure of 
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Edwards, Bradley vs. Dershowitz 
Case No.: CACE I5-000072 
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
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the 
materials 
in 
the 
records 
would 
be 
harmful 
to 
his 
professional 
reputation. Carnegie recited subsection vi's restriction on release of materials involving a 
privacy right, but noted that "statements Tedder alleged were defamatory and damaging were 
allegations 
in 
Camegie's 
counterclaim 
for 
which 
she seeks damages. 
These matters were not peripheral to the lawsuit; they were inherent to it." Id. at 1312. Of 
course, exactly the same principle applies here: 
Edwards and Cassell for their client M 
e not peripheral to this lawsuit — they 
are inherent to it. 
To see how "inherent" the sexual abuse allegations are to this lawsuit, the Court need 
look no further than Dershowitz's counterclaim in this case. Count I of Dershowitz's 
Counterclaim (styled as "False Allegations in the Joinder Motion") contends that Edwards and 
Cassell should pay him damages because they "filed a pleading in the Federal Action titled `Jane 
Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in Action' . . . ." Dershowitz 
Counterclaim at ¶ 14. Dershowitz's Counterclaim then goes on to quote at length from the 
Joinder Motion. His counterclaim contains, for example, this paragraph recounting the 
allegations: 
The Joinder Motion then goes on to allege — without any supporting evidence — as 
follows: 
sexual abuse allegations filed by attorneys 
One such powerful individual that Epstein forced then-minor Jane Doe #3 to 
have sexual relations with was former Harvard Law Professor Alan 
Dershowitz, a close friend of Epstein's and well-known criminal defense 
attorney. Epstein required Jane Doe #3 to have sexual relations with 
Dershowitz on numerous occasions while she was a minor, not only in Florida 
but also on private planes, in New York, New Mexico, and the U.S. Virgin 
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Edwards, Bradley vs. Dershowitz 
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Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
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Islands. In addition to being a participant in the abuse of Jane Doe #3 and other 
minors, Dershowitz was an eye-witness to the sexual abuse of many other 
minors by Epstein and several of Epstein's coconspirators. Dershowitz would 
later play a significant role in negotiating the [Non-Prosecution Agreement] on 
Epstein's behalf. Indeed, Dershowitz helped negotiate an agreement that 
provided immunity from federal prosecution in the Southern District of Florida 
not only to Epstein, but also to "any potential coconspirators of Epstein." Thus, 
Dershowitz helped negotiate an agreement with a provision that provided 
protection for himself against criminal prosecution in Florida for sexually 
abusing Jane Doe #3. Because this broad immunity wouldhave been 
controversial if disclosed, Dershowitz (along with other members of Epstein's 
defense team) and the Government tried to keep the immunity provision secret 
from all of Epstein's victims and the general public, even though such secrecy 
violated the Crime Victims' Rights Act. 
Dershowitz Counterclaim at 1115 (quoting Joinder Motion at 4). 
Remarkably, having quoted at length from the Joinder Motion in his Counterclaim in this 
case, Dershowitz now seeks to have that very same language from the Joinder Motion deemed 
"confidential" and sealed. Compare Counterclaim at ¶15 (block quotation above) with Motion to 
Determine Confidentiality, Exhibit A at 4 (composite exhibit with proposed "confidential" 
document that includes paragraph beginning "[o]ne such powerful individual that Epstein forced 
then-minor Jane Doe #3 to have sexual relations with was former Harvard Law Professor Alan 
Dershowitz, a close friend of Epstein's . . . ."). Dershowitz cannot come before this Court and 
file a counterclaim seeking damages from Edwards and Cassell for alleged defamatory 
statements and then ask to have those very same statements placed under seal as 
"confidential." See Barron v. Florida Freedom Newspapers, 531 So.2d at 119 ("although 
generally protected by one's privacy right, medical reports and history are no longer protected 
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Edwards, Bradley vs. Dershowitz 
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Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
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when the medical condition becomes an integral part of the civil proceeding, particularly when 
the condition is asserted as an issue by the party seeking closure" (emphasis added)). 
H. 
JUDGE MARRA'S ORDER IN HIS CASE DOES NOT REQUIRE THAT 
THE RECORDS BE SEALED IN THIS CASE. 
Dershowitz also appears to contend that Judge Marra's order striking some of the 
materials from the records at issue somehow requires that these stricken materials be kept 
confidential in this case. Dershowitz's argument misunderstands both the scope of Judge 
Marra's order and its effect in this case. His argument rests on a truncated — and misleading --
description of the events surrounding Judge Marra's ruling striking certain documents. A more 
complete description makes clear that Judge Marra has not determined the documents are 
somehow "confidential" even in the federal Crime Victims' Rights Act case — much less in this 
separate state defamation action. 
Edwards and Cassell filed the federal case pro bono on behalf of two young women who 
were sexually abused as underage girls by Dershowitz's close personal friend — Jeffrey 
Epstein. In 2008, Edwards and Casell filed a petition to enforce the rights of "Jane Doe No. 1" 
and "Jane Doe No. 2" under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, alleging 
that the Government had failed to provide them rights with regard to a plea arrangement it was 
pursuing with Epstein. Jane Doe No. 1 and Jane Doe No. 2 v. United States, No. 9:08-cv-80736 
(S.D. Fla.). In the course of that case, 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 
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Edwards, Bradley vs. Dershowitz 
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followed (see generally Docket Entry or "DE" 225-1 at 4-5), 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 largely 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. 
While these discovery issues were pending, in the summer of 2014, Edwards and Cassell, 
contacted Government counsel to request their agreement to add two additional victims to the 
case, including Ms. 
who was identified in court pleadings as "Jane Doe No. 
3"). Edwards and Cassell sought to have her added to the case via stipulation, which would have 
avoided the need to include any detailed facts about her abuse. Weeks went by and the 
Government — as it had done on a similar request for a stipulation to add another victim — did not 
respond to counsel's request for a stipulation. Finally, 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. DE 291 at 3-5. Rather than file a 
motion immediately, victims' counsel waited and continued to press the Government for a 
stipulation. See id. at 5. 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 DE 291 at 5. 
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Edwards, Bradley vs. Dershowitz 
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Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
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Because the 
Government 
now contested 
the joinder 
motion, Edwards and 
Cassell prepared a more detailed pleading explaining the justification for granting the 
motion. One week after receiving the Government's objection, on December 30, 2014, Ms. 
i.e., 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. (Note: DE 280 is the first of the three documents 
Dershowitz seeks to have declared "confidential" in this case.) Uncertain as to the basis for the 
Government's objection, the motion briefly proffered the circumstances that would qualify 
the two women as "victims" eligible to assert rights under the CVRA. See 18 U.S.C. 3771(e) 
(defining "crime victim" protected under the Act). With regard to Ms. 
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.ctui.com/2015/0 I /06/us/dershowitz-sex-allegationt 
Dershowitz also 
repeatedly called Edwards and Cassell "two sleazy, unprofessional, disbarable lawyers." Id. On 
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Edwards, Bradley vs. Dershowitz 
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Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
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January 5, 2015, Dershowitz filed a motion to intervene to argue to have the allegations 
stricken. DE 282. Dershowitz also argued that Ms. 
M
 
had not provided a sworn affidavit 
attesting to the truth of her allegations. On January 21, 2015, Edwards and Cassell filed a 
response for Mad 
Jane Doe No. 4. DE 291. (Note: This is the second of the three 
documents Dershowitz seeks to have kept under seal here.) The response enumerated nine 
M
s
specific reasons why Ms. 
pecific allegations against Dershowitz were relevant to the 
case, including the fact that Ms
eeded to establish that she was a "victim" in the case, 
that pending discovery requests concerning Dershowitz-specific documents were pending, and 
that Dershowitz's role as a defense attorney in the case was highly relevant to the motive for the 
Government and defense counsel to conceal the plea deal from the victims. DE 291 at 17-26 & 
n.17. The response included a detailed affidavit from Ms=lo
 ut the sexual abuse she had 
suffered from Epstein, Dershowitz, and other powerful persons. DE 291-1. On February 6, 
2015, Edwards and Cassell filed a further pleading (and affidavit from Ms 
ee DE 291-
1) in support of her motion to intervene. (Note: this affidavit is the third of the three documents 
Dershowitz seeks to have declared confidential.) 
On April 7, 2015, Judge Marra denied Ms. Giuffre's motion to join the case. Judge 
Marra concluded that "at this juncture in the proceedings" details about the sexual abuse she had 
suffered was unnecessary to making a determination "of whether Jane Doe 3 and Jane Doe 4 
should be permitted to join [the other victims'] claim that the Government violated their rights 
under the CVRA. The factual details regarding with whom and where the Jane Does engaged in 
sexual activities are impertinent to this central claim (i.e., that they were known victims of Mr. 
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Edwards, Bradley vs. Dershowitz 
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Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
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Epstein and the Government owed them CVRA duties), especially considering that the details 
involve non-parties who are not related to the respondent Government." DE 324 at 5 (emphasis 
in original). While Judge Marra struck those allegations, he emphasized that "Jane Doe 3 is free 
to reassert these factual details through proper evidentiary proof, should [the victims] 
demonstrate a good faith basis for believing that such details are pertinent to a matter presented 
for the Court's consideration. Judge Marra then denied Motion
to join the case, 
a
but allowed her to participate as trial witness: "The necessary 'participation' of [ 
. 
in this case can be satisfied by offering . . . properly supported — and relevant, admissible, and 
non-cumulative — testimony as needed, whether through testimony at trial . . . or affidavits 
supported in support [of] the relevancy of discovery requests." DE 324 at 8 (emphasis 
deleted). In a supplemental order, Judge Marra stated that the victims "may re-refile these 
documents omitting the stricken portions." DE 325. The victims have recently refiled the 
documents. 
In light of this history, Dershowitz is flatly incorrect when he asserts that "Judge Marra's 
Order appropriately precludes the unredacted documents from being re-filed in this case on the 
public docket." Confidentiality Motion at 3. To the contrary, the Order specifically permits 
factual details about Dershowitz's sexual abuse of MMD 
be presented in regard to 
pertinent matters in the federal CVRA case. And certainly nothing in Judge Marra's Order could 
render those documents confidential in this state defamation case, where the central issues swirl 
around Edwards and Cassell's good faith basis for filing the allegations. Indeed, the order is not 
binding in any way in this case, because it is res judicata only as to Ms. 
moving 
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Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
Page I I of 20 
party in that case), not as to her attorneys Edwards and Cassell. See Palm AFC Holdings, Inc. v. 
Palm Beach County, 807 So.2d 703 (4'h DCA 2002) ("In order for res judicata to apply four 
identities must be present: (1) identity of the thing sued for; (2) identity of the cause of action; 
(3) identity of persons and parties; and (4) identity of the quality or capacity of the persons for or 
against whom the claim is made."). 
III. 
EDWARDS AND CASSELL WILL BE PREJUDICED IF THEY ARE 
BARRED FROM QUOTING FROM THE RECORD WHILE 
DERSHOWITZ IS PERMITTED TO FREELY REFER TO THEM 
WHENEVER HE FINDS IT CONVENIENT. 
Dershowitz is also incorrect when he asserts that no prejudice will befall Edwards and 
Cassell if the records are placed under seal. To the contrary, placing the documents under seal 
would permit Dershowitz to continue to misrepresent and distort what is contained in those 
records while preventing Edwards and Cassell from correcting those misrepresentations. 
Dershowitz has repeatedly referred to details in the records when he has found it convenient to 
do so — treating the records as not confidential in any away. One clear example comes from 
Dershowitz's recent deposition, where he gratuitously injected into the record a reference to a 
portion of Msedavit 
about him watching a 
perform oral sex on 
Epstein. And then, having injected that gratuitous reference into the record, he proceeded to try 
to rebut the reference with confidential settlement discussions — but did so by mispresenting what 
another attorney (David Boies) had said during the settlement discussions. So that the Court may 
have the full flavor of the exchange, the narrow question to Dershowitz (by attorney Jack 
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Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
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Scarola) and Dershowitz's extended answer are quoted in full — including Dershowitz's 
reference to the oral sex allegation that he now argues this Court should treat as "confidential": 
Q. 
[Y]ou [are] aware that years before December of 2014, when the 
CVRA pleading was filed, that your name had come up repeatedly in 
connection with Jeffrey Epstein's abuse of minors, correct? ... 
A. 
Let me answer that question. I am aware that never before 2014, 
end of December, was it ever, ever alleged that I had acted in any 
way inappropriately with regard to 
at I ever 
touched her, that I ever met her, thatilir 
atwit
ter. I was 
completely aware of that. 
There 
had 
never 
been 
any 
allegation. She claims under oath that she told you that secretly in 
2011, but you have produced no notes of any such conversation. 
You, of course, are a witness to this allegation and will be deposed 
as a witness to this allegation. I believe it is an entirely false 
allegation that she told you in 2011 that she had had any sexual 
contact with me. I think she's lying through her teeth when she 
says that. And I doubt that your notes will reveal any such 
information. 
But if she did tell you that, she would be absolutely, categorically 
lying. So I am completely aware that never, until the lies were put 
in a legal pleading at the end of Dece 
never alleged that I had any sexual contact wi 
I know that it was alleged that I was a witness to e ey pstein's 
alleged abuse and that was false. I was never a witness to any of 
Jeffrey Epstein's sexual abuse. And I wrote that to you, something 
that you have falsely denied. And I stand on the record. The record 
is clear that I have categorically denied I was ever a witness to 
any abuse, that I ever saw Jeffrey Epstein abusing anybody. 
And and the very idea that I would stand and talk to Je 
Epstein while he was receiving oral sex fro 
which she swore to under oath, is so outrageous, so preposterous, 
that even David Boies said he couldn't believe it was true. 
MS. McCAWLEY: I object. I object. I'm not going to allow you to reveal 
any conversations that happened in the context of a settlement discussion. 
THE WITNESS: Does she have standing? 
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Edwards, Bradley vs. Dershowitz 
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Edwards and Cassel Is Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
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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 standing in this deposition? 
MR. SCOTT: Let's take a break for a minute, okay? 
THE WITNESS: I'm not sure she has standing. 
MR. SCAROLA: Are we finished with the speech? 
MR. SCOTT: No. If he --
MR. SCAROLA: I'd like him to finish the speech so that we can get to my 
question 
and then we can take a break. 
A. So the question -- the answer to your question is --
MR. SIMPSON: Wait a minute. Wait a minute. Wait a minute. Please don't 
disclose something that she has a right to raise that objection if she wants to. 
MR. SCOTT: Exactly. 
Deposition of Alan Dershowitz (Oct. IS, 2015) at 93-95 (attached as Exhibit 1); see 
Sir
as
also Deposition f A
Dershowitz (Oct. 16, 2016) (attached 
Exhibit 2) (also containing 
discussion of Ms 
ffidavit). 
The Court should be aware that within approximately two hours of this exchange, Ms. 
McCawley (David Boies' law partner) released a statement on his behalf, which stated that 
Dershowitz was misrepresenting what happened: "Because the discussions that Mr. Boies had 
with Mr. Dershowitz were expressly privileged settlement discussions, Mr. Boies will not, at 
least at this time, describe what was actually said. However, Mr. Boies does state that Mr. 
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Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15.000072 
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
Page 14 of 20 
Dershowitz description of what was said is not true." Statement of Ms. McCawley on Behalf of 
David Boies (Oct. 15, 2015). 
More broadly, the Court can readily see from this passage how Dershowitz is willing to 
inject into the record a part of Ms. Affidavit 
whenever it serves his purpose — and, 
indeed, to characterize the part of the affidavit as "preposterous." But then he asks this Court to 
place the underlying affidavit under seal, so that the Edwards and Cassell stand accused having 
filed a "preposterous" affidavit without anyone being able to assess the validity of Dershowitz's 
attack. 
Dershowitz has referred to the court records that he now wishes to have the Court declare 
confidential not only in his deposition, but also in his widely-broadcast media attacks on 
Edwards and Cassell. For example, Dershowitz appeared on the British Broadcasting 
Corporation (the BBC) and was asked about the allegations: 
Well, first of all they were made in court papers that they don't even ask for a hearing 
to try to prove them. They put them in court papers in order to immunize themselves 
from any consequences from a defamation suit. The story is totally made 
up, completely out of whole cloth. 
I don't know this woman. I was not at the places at the times. It is part of a pattern of 
made up stories against prominent people and world leaders. And the lawyers in 
recent statement challenged me to deny the allegations under oath. I am doing that. I 
am denying them under oath, thus subjecting me to a perjury prosecution were I not 
telling the truth. Jam now challenging them to have their client put these charges 
under oath and for them to put them under oath. I am also challenging them to repeat 
them outside of the context of court papers so that I can sue them for defamation. . . . 
And I will prove beyond any doubt not only that the story is totally false, but it was 
knowingly false: that the lawyers and the client conspired together to create a false 
story. That is why I am moving for their disbarment in challenges to be provided to 
the disciplinary committee. 
BBC Radio 4 - Sarah Montague (Jan. 3, 2015) (httn://www.bbc.co.uk/nrogrammes/p02a7qbc).
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Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
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Similarly, Dershowitz appeared on NBC's Today Show the morning after Edwards and 
Cassell made a filing for Mslay 
that the Edwards and Cassell — and 
were all "lying" in the court documents: 
Question from Savannah Guthrie: In legal papers from the lawyers, they say you've 
had, in fact, the opportunity to be deposed. 
Answer from Alan Dershowitz: They're lying. They're lying. 
Question: They show letters in which they offered to depose you. 
Answer: And they didn't show my letters in response saying, (a), if you ask me about 
my legal relationship with Epstein and I'll be happy to answer. . . . And I responded 
that I would be happy to be deposed if you could give me any indication that 1 would 
be a relevant witness . . . . They will be proved — all of them (i.e., Cassell, Edwards, 
and Ms. 
to be categorically lying and making up this story. And it will be a 
terrible thing or rape victims. . . . We [Epstein and Dershowitz] had an academic 
relationship. I was never in the presence of a single, young, underaged 
woman. When I was with him, it was with prominent scientists, prominent 
academics. And they're just — again — lying about this. I never saw him doing 
anything improper. I was not a participant. I was not a witness. 
Today Show, Jan. 22, 2015 (emphases added). 
As another example, in Miami Herald, Dershowitz called the Joinder Motion that he 
seeks to have sealed "the sleaziest legal document I have ever seen. They [Edwards and 
Cassell] manipulated a young, suggestible woman who was interested in money. This is a 
disbarrable offense, and they will be disbarred. They will rue the day they ever made this false 
charge against me" — i.e., Edwards and Cassell will "rue the day" they ever filed the Joinder 
Motion. Miami Herald (Jan. 3, 2015). 
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Edwards, Bradley vs. Dershowitz 
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Edwards and CasselIs Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
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Most remarkably, Dershowitz took the public airwaves to represent that he wanted all of 
the information surrounding the allegations to "be made public," while implying that Edwards 
and Cassell had something to hide. For example, on the BBC he claimed that he 
wanted"everything to be made public": 
Q: 
Would you encourage that it now be made public? 
A: 
Of course, of course. I want everything to be made public. I want 
every bit of evidence in this case to be made public. I want every 
allegation to be made public. I want to know who else she's accused of 
these horrible crimes. We know that she accused Bill Clinton of being on 
Jeffrey Epstein's island and participating in sex orgy with underage 
girls. The records of the Secret Service will prove that President Clinton 
never set foot on that island. So that she lied. Now it's possible to have a 
case of mistaken identification with somebody like me. It's impossible to 
have a case of mistaken identification with Bill Clinton. 
My only feeling is that if she has lied about me, which I know to an 
absolute certainty she has, she should not be believed about anyone 
else. She's lied clearly about me, she's lied clearly about Bill 
Clinton. We know that. We know that she's lied about other public 
figures, including a former prime minister and others who she claims to 
have participated in sexual activities with. So I think it must be presumed 
that all of her allegations against Prince Andrew are false as well. 
I think he [Prince Andrew] should clear the air as well. 
If you're squeaky clean and if you have never done anything like this, you 
must fight back with all the resources available to you. And that's what I 
will do. I will not rest or stop until the world understands no only that I 
had nothing to do with any of this, but that she deliberately, with the 
connivance of her lawyer, lawyers, made up this story willfully and 
knowingly. 
BBC Radio 4 - Sarah Montague (Jan. 3, 2015) antp://www.bbc.co.uk/programmes/p02g7lbc).
In another widely-broadcast interview on CNN, Dershowitz implied that there is no 
evidence supporting the allegations against him: 
EFTA01116708

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
Page 17 of 20 
Ask them [Edwards and Cassell] if they have any evidence . . . . They're doing it for 
money. She's getting money for having sold her story. She wants to sell the book. 
They're trying to get into this lawsuit. They see a pot of gold at the end of the 
rainbow. They're [Edwards and Cassell] prepared to lie, cheat, and steal. These are 
unethical lawyers. This is Professor Cassell who shouldn't be allowed near a 
student. This is Professor Cassell, who is a former federal judge, thank God he no 
longer wears a robe. He is essentially a crook. He is essentially somebody who's 
distorted the legal profession. . . . Why would he charge a person with a 
sterling reputation for 50 years on the basis of the word alone of a woman who is 
serial liar, who has lied about former Prime Ministers, former Presidents, has lied 
demonstrably. 
CNN Live (with Hala Gorani) (January 5, 2015). Of course, by placing "the evidence" in this 
case under seal, De 
1 be free to continue to try and insinuate that Edward and Cassell 
— and their client, 
had no evidence supporting the allegations against him, even 
though a mountain et?: ence s ongly support 
negations. See Deposition of Paul 
Cassell (Oct 16, 2015) at 61-117 (Exhibit 3); 
of Pual Cassell (Oct 17, 2015) 
(Exhibit 4). 
CONCLUSION 
The Court should deny Defendant/Counterclaim Plaintiff Alan Dershowitz's motion to 
place documents regarding Ms. 
tions against him under seal. 
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve 
to all Counsel on the attached list, this  
25r° 
 day of November, 2015. 
/s/ Jack Scarola 
Jack Scarola 
Florida Bar No.: 169440 
Attorney E-Mail(s): 
Primary E-Mail: 
Searcy Denney S 
2139 Palm Beach Lakes Boulevard 
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Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15.000072 
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
Page 18 of 20 
SEAN D. REYES 
Utah Attorney General 
By: JONI J. JONES 
JOEL A. FERRE 
Assistant Utah Attorneys General 
Bradley J. Edwards 
FARMER, JAFFE, WEISSING, 
EDWARDS, FISTOS & LEHRMAN, P.L. 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, Florida 33301 
And 
Paul G. Cassell 
Pro Hac Vice Motion Pending 
S.J. Quinney College of Law at the 
University of Utah 
383 S. University St. 
Salt Lake City, UT 84112 
Attorneys for Plaintiffs Bradley J. Edwards and Paul G. Cassell 
COUNSEL LIST 
Thomas Emerson Scott, Jr., Esquire 
Cole Scott & Kissane P.A. 
9150 S Dadeland Boulevard, Suite 1400 
Miami, FL 33156 
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Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Edwards and Cassells Response to Dershowites Motion to Determine Confidentiality of Court Records 
Page 19 of 20 
Attorneys for Defendant 
Richard A. Sim son 
ro hac vice) 
M 
E. Bor'a 
m hac vice) 
Ashley E. Eiler (pro hac vice) 
WILEY REIN LLP 
1776 K St. NW 
Washington, DC 20006 
EFTA01116711

Edwards, Bradley vs. Dershowitz 
Case No.: CACE I5-000072 
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records 
Page 20 of 20 
COUNSEL LIST 
Sigrid Stone McCawley, Esquire 
401 E Las Olas Boulevard., Suite 1200 
, Esquire 
Thomas Emerson Scott. Jr 
uire 
ole Scott & Kissane P.A. 
9150 S Dadeland Boulevard, Suite 1400 
Bradle J. Edwards 
• uire 
,... 
Farmer Jaffe Weissing Edwards Fistos & 
Lehrman, P.L. 
425 N Andrews Avenue, Suite 2 
Kenneth A. Sweder, E uire 
131 Oliver Street 
Boston, MA 02110 
ttomeys or 
an 
ers
 squire 
Ashley Eiler, Esquire 
Richard A. Simpson, Esquire 
IIIIIMIE 
1776 K Street NW 
Washin on DC 20006 
Attorneys or A an M.Ders towitz, Esquire 
Joni J. Jones, Esquire 
MIIIIIIIIIIIIIIIIL 
160 E 300 S 
Salt Lake City, UT 84114 
I 
me s or at
.IIIIPe 
I 
EFTA01116712