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result is that she'll go to jail because she will repeat her lies and we’ll be able to prove it and she
will end up in prison for perjury.” (emphasis added). See Exhibit 1, New York Daily News, April
Filing # 25919336 E-Filed 04/09/2015 05:23:25 PM
IN THE CIRCUIT COURT OF THE 171!
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIVIL DIVISION
BRADLEY J. EDWARDS, and CASE NO. CACE 15-000072
BACKGROUND
The underlying action before this Court is a defamation case filed by a former federal
judge, Paul Cassell, and his colleague Brad Edwards, who represent various sexual trafficking
victims
Accordingly, Dershowitz requests that the Court modify the Confidentiality Order to
confirm that Dershowitz’s counsel may disclose Ms. Roberts’s testimony as they deem necessary
in their professional
Paul Cassell
From: Paul Cassell
Sent: Saturday, January 3, 2015 11:14 AM
To: Paul Blake
Subject: RE: questions for Dershowitz
Questions for Alan Dershowitz
1. Have you ever met a young girl, unde
8. The U.S. Attorney’s Office gave Epstein a non-prosecution agreement that extended immunity from federal
prosecution not only to Epstein but also “any potential co-conspirator”. Isn’t it normal prac
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let me clear all of that misunderstanding up.
You know, that's -- frankly, if I had gotten
something like that, that's what I
Case 1:15-cv-07433 Document1 Filed 09/21/15 Page 5 of 12
21. To avoid her deposition, Maxwell claimed that her mother fell deathly ill and that
consequently she was leaving the United States for Lond
Case 1:15-cv-07433 Document1 Filed 09/21/15 Page 4 of 12
15. Rather than confer with the victims about the NPA, the U.S. Attorney’s Office
and Epstein agreed to a “confidentiality” provision in the A
Case 1:15-cv-07433 Document1 Filed 09/21/15 Page 3 of 12
PARTIES
6. Plaintiff Giuffre is an individual who is a citizen of the State of Colorado.
7. Defendant Maxwell, who is domiciled in the Souther
woven into his performances. But as clubs became increasingly afraid to
hire him, he devoted more and more time and energy to the law.
In less than two years, Lenny was arrested 15 times. Club owners
intended to become an underground abortion referral service, but it
wasn't going to stop just because in the next issue of 7he Realist | would
publish an interview with somebody else.
A few years lat
wears glasses. Sometimes while the commercial is on, the actors have
reconciliation. It is a real fun show.
Mommy and Daddy live in New York State. To get a divorce there,
one of them has to commit a
Could U.S. case against sex offender Jeffrey Epstein be reopened?
2 of 4
case to any victim,” they wrote, urging him to uphold the provisions of the 13-year-old federal law.
At the same time, the s
Could U.S. case against sex offender Jeffrey Epstein be reopened? http://www.mypalmbeachpost.com/news/crime--law/fight-reopen-teen-s...
Wellington home with flowers, balloons and a gun, and killed 40
Starr later defended Blackwater against wrongful deaths suit initiated by the families of the 2004
Fallujah Ambush victims - "In October 2006, Blackwater hired one of the nation’s heaviest-hitting
law
Could U.S. case against sex offender Jeffrey Epstein be reopened?
lof 4
C3t°
wm
ay
Fight to reopen teen sex case
against Jeff Epstein may set
precedent
LOCAL By Jane Musgrave - Palm Beach Post S
before they set off at marine base Camp Fallujah. But the men kept their distance from the
leathernecks. Had they spoken to the marines, the Blackwater team might have learned that the
Americans were
Case 9:0@-ase8D TSécK AWA 3B AR BGenDs6edmémieieh bh ALB De/dk4i 04/BAGH15 oP&ébe 9 of 10
id. at 10). Petitioners do not contend that Jane Doe 3 and Jane Doe 4’s “participation in this
case” can only
Case 9:08 aé807E5-d0A07 4 oR niLeeuinteniteréd -49 FES@ DGCkét104/P7dge15 ofPidge 7 of 10
issue, the Court finds that its action of striking the lurid details from Petitioners’ submissions is
sanctio
My Tae Was fC WITN EM oamassMment OUT I TSIC LINGEr IMMENse pressure ta wiease
them, she told the Mailon Sunday
“The whole lime ibwas ceing on, they were pramising me the world, thet trevel
weith Jel
Case 9:0&aé807E5-d0A07 4 oR nilketinteniteréd -49 FES@ DGCkét104/7dge15 ofPidge 1 of 10
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.:08-CV-80736-KAM
JANE DOE | and JANE DOE 2,
Troubled teenager: Virginia en the billionaire's Zone ranch in New Mexico in 2001
The prince was also al a Manhattan cocktail party thrown that year by Miss Wexwel)
which was fillec with young Russia
Case 1:15-cv-07433-RWS Document 751-10 Filed 03/17/17 Page 4 of 4
"Given what he knows and has seen, | was hoping that he would simply voluntarily tell the truth about everything."
Roberts and anothe
Case 1:15-cv-07433-RWS Document 751-9 Filed 03/17/17 Page 3of3
The women have objected to how U.S. prosecutors handled Epstein's case, and want authorities to reconsider a
plea deal that allowed Epste
aleeany Case 1:15-cv-074331 RWS. Dersenieane PSsEx FaveeRa goes /ERFAEM Page 3 of 3
The FBI case revealed sexual allegations by at least 20 girls, however, Epstein struck a deal with
prosecutors and s
9/2/2016 Case 1:15-cteOa BB-FRWESby PaMeNhinsiTeyABLa2 evEdieguGay M7EITet BD SWyto’s of 8
investigate the backgrounds of the girls.Detectives painstakingly built a case which they believed showed
tha
Case 9:Gase-bdpaevOKS ERR cReguMenhese® of HEGOLINGLE: age Aiof Ibage 9 of 10
id. at 10). Petitioners do not contend that Jane Doe 3 and Jane Doe 4’s “participation in this
case” can only be achieved
Case 9:08aSe- dOFSO KAAS BEA er? QoumentiaaSdonted 9 Heeket oP age28 of 1 Page 7 of 10
issue, the Court finds that its action of striking the lurid details from Petitioners’ submissions is
sanction e
Case 1:15-cv-07433-RWS Document 539-1 Filed 01/06/17 Page 4 of 9
6/14/2016 Case 1:15°Oe Ose Riv’. Dercuerret neig toBileid (G94 HM PalPyg@ningf 9
Manhattan.
The photograph that appeared last weekend
Case 9:6ase-doFeeKarAsBSbiVd eR aaumentieaadoniied 9 Heeldet oFage2 26 1 Page 1 of 10
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.:08-CV-80736-KAM
JANE DOE 1 and JANE DOE 2,
Pe
6/15/2016
Epstein’s many Hollywood pals include Matt Groening, creator of The Simpsons.
‘Jeffrey once had me give Matt a foot massage when he was flying on the jet with us,’ Virginia says.
‘He laughed
Tuesday, December 13, 2016
VIRGIN ISLANDS
Prosecutors: white powder
letters contained hoodoo curse
By SUZANNE CARLSON
Daily News Staff
A woman facing federal criminal
charges for mailing letters c
Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 9 of 34
Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Plaintiffs’ Motion to Compel Production of Documents
FAC
98 CASSELL ET AL. [Vol. 104
the criminal justice process.*'* Moreover, every state has adopted a statute
that either enforces its constitutional amendment or creates independent
statutory rights for c
100 CASSELL ET AL. [Vol. 104
Other states also expressly extend nghts before the filing of charges.
Colorado guarantees rights at “all critical stages of the criminal justice
process|,]” which includ
96 CASSELL ET AL. [Vol. 104
reasonable efforts to notify identified victims of, and consider victims’
views about, prospective plea negotiations, even prior to the filing of a
charging instrument wit
92 CASSELL ET AL. [Vol. 104
of court hearings and to attend those hearings.'*’ So it is instructive to
notice that the Justice Department policy is to extend certain rights to
suspected criminals duri
2014] CRIME VICTIMS’ RIGHTS 89
felony offenses, broadly extending its protections to victims of any federal
offense.'”’ Thus, under OLC’s interpretation that the filing of a complaint
does not trigge
2014] CRIME VICTIMS’ RIGHTS 93
victims to those who have been “directly and proximately harmed.”!*?
Finally, the formulation requires some federal officer or employee to
evaluate the evidence and reac
2014] CRIME VICTIMS’ RIGHTS 91
it has extended many rights to victims before the formal filing of criminal
charges as a matter of internal policy.'** This approach appears to be
workable, as a number
88 CASSELL ET AL. [Vol. 104
crime victims to assert CVRA rights “in the district court in which a
defendant is being prosecuted for the crime or, if no prosecution is
underway, in the district court
2014] CRIME VICTIMS’ RIGHTS 85
More importantly, extending the nght in this fashion will not be
unduly burdensome for federal prosecutors. After the OLC memorandum
was made public, the Department ame
84 CASSELL ET AL. [Vol. 104
the victim has an opportunity to be heard by the court, and by the
Government, before the court accepts the plea.”!*
But OLC failed to recognize that its interpretation o
82 CASSELL ET AL. [Vol. 104
Manson case>.”!?”? Thus, Black’s Law Dictionary does not help resolve the
dispute as to which of the two meanings should be used, as there are clearly
differing meanings.
2014] CRIME VICTIMS’ RIGHTS 75
Perhaps the most extensive discussion of this issue has come from the
Epstein case discussed earlier.’”? Overruling the Government’s argument
that the CVRA only applies
74 CASSELL ET AL. [Vol. 104
applicability to other situations), the government should have fashioned a reasonable
way to inform the victims of the likelihood of criminal charges and to ascertain the
76 CASSELL ET AL. [Vol. 104
invokes the CVRA’s definition of crime “victim,” its legislative intent, and
its structure, a closer reading of each demonstrates little support for the
notion that crime
2014] CRIME VICTIMS’ RIGHTS 73
C. COURTS RECOGNIZE THAT CRIME VICTIMS HAVE CVRA RIGHTS
BEFORE CHARGING
Because crime victims lack a right to appointed counsel, many victims
have difficulty litigatin
68 CASSELL ET AL. [Vol. 104
criminal charges? Or do they attach at some earlier point in the process?
Does v. United States, a federal case in the U.S. District Court for the
Southern District of Flo