EFTA01078855

Filing # 25919336 E-Filed 04/09/2015 05:23:25 PM 
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR 
BROWARD COUNTY, FLORIDA 
CIVIL DIVISION 
BRADLEY J. EDWARDS, and 
CASE NO. CACE 15-000072 
PAUL G. CASSELL, 
Plaintiffs, 
v. 
ALAN DERSHOWITZ, 
Defendant. 
 
I 
MOTION TO QUASH OR FOR PROTECTIVE ORDER REGARDING 
SUBPOENA SERVED ON NON-PARTY JANE DOE NO. 3 
Non-party Jane Doe 3, by and through undersigned counsel and pursuant to Florida Rules 
of Civil Procedure 1.410(c)(1)1, hereby moves for an order quashing the subpoena duces tecwn 
served on her by Defendant, or alternatively, pursuant to Florida Rules of Civil Procedure 1.280(c) 
for issuance of a protective order sharply limiting the scope of the subpoena. 
INTRODUCTION 
This Court should quash the subpoena issued to non-party Jane Doe No. 3 as it is 
unreasonable and oppressive. The Defendant is abusing the subpoena power in an effort to 
intimidate, harass and cause undue burden to a non-party. Indeed, Defendant - just days ago - 
publicly admitted that his goal of deposing Jane Doe No. 3 has nothing to do with this Florida 
Defamation Action; rather, he is trying to find a way to send this victim of sexual trafficking to 
"jail." "She was hiding in Colorado...but we found her and she will have to be deposed. The end 
' For the limited purpose of the Motion to Quash or for Protective Order and resolving the scope of the 
subpoena and any enforcement issues, Jane Doe No. 3 voluntarily submits herself to this Court's 
jurisdiction. 
EFTA01078855

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 
7, 2015. Defendant has subjected Jane Doe No. 3 to horrific public attacks including publicly 
calling her a "prostitute" and a "bad mother" to her three minor children. See Exhibit 2, Local 10 
News, January 22, 2015. 
Defendant has gone on a media blitz campaign against this non-party for statements she 
made under oath in a federal action: "The end result of this case should be she (Jane Doe No. 3J 
should go to jail, the lawyers should be disbarred and everybody should understand that I am 
completely and totally innocent." (emphasis added). See Exhibit 3, CNN International, New Day, 
January 6, 2015. "My goal is to bring charges against the client and require her to speak in 
court." (emphasis added). See Exhibit 4, Australian Broadcasting System (ABC), January 6, 
2015. Defendant also stated, in an interview in Newsmax, that he is "considering" bringing a 
lawsuit against Jane Doe No. 3. "And we're considering suing her for defamation as well, but 
right now she was trying to hide in Colorado and avoid service, but we found her and we served 
her and now she'll be subjected to a deposition." (emphasis added). See Exhibit 5, Newsmax, 
April 8, 2015. 
Defendant's own words demonstrate that he is abusing the subpoena power of this Court to 
try to get discovery that is irrelevant to this case, in the hopes of being able to intimidate Jane Doe 
No. 3 with the press and generate a claim against her. Considering the extensive abuse that Jane 
Doe No. 3 suffered as a minor child, and Defendant's threats and intimidation, it would be both 
unreasonable and oppressive to require this non-party to comply with this subpoena duces tecum. 
Accordingly, Defendant's subpoena should be quashed. See Exhibit 6, Defendant's Subpoena to 
Jane Doe No. 3. 
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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 in a case pending in the Southern District of Florida, specifically case no. 08-cv-80736-
KAM, hereinafter ("CVRA case"). As a result of an affidavit filed in the CVRA case, Defendant 
went on a national media defamation campaign calling, among other things, former federal judge 
Paul Cassell and attorney Brad Edwards, "unethical lawyers" who should be "disbarred". See 
Exhibit 7, Today Show, January 5, 2015. In response to this national slander campaign by the 
Defendant, Paul Cassell and Brad Edwards filed a defamation case against Defendant in the 
Circuit Court of the Seventeenth Judicial Circuit for Broward County, Case No. CACE 15-
000072, hereinafter "Florida Defamation Action"). 
Defendant's statements against Paul Cassell and Brad Edwards are statements about their 
character as lawyers and do not directly involve non-party Jane Doe No. 3. Despite this fact, 
Defendant is abusing the subpoena power in this case by seeking documents from a non-party that 
are irrelevant to the defamation issue before this Court. Defendant is determined to find a way to 
harm non-party Jane Doe No. 3 and anyone who braves to represent her. Jane Doe No. 3 has good 
cause to be fearful of the Defendant in this matter based on Defendant's repetitive threats. See 
Exhibit 8, Affidavit of Jane Doe No. 3. This Court should not allow Defendant to abuse the 
subpoena power to further abuse this non-party. Florida Rules of Civil Procedure provide a 
vehicle for this Court to protect a non-party from a harassing, burdensome and unnecessary 
subpoena. As explained below, non-party Jane Doe No. 3 should be protected from having to be 
deposed in this matter or produce documents. Defendant's campaign of threats and intimidation 
should not be condoned by this Court and Defendant's subpoena should be quashed in its entirety. 
3 
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ARGUMENT 
1. This Court Should Quash Defendant's Abusive Subpoena In Its Entirety. 
Florida Rule of Civil Procedure 1.410(c)( I) provides that the Court may "quash or modify 
the subpoena if it is unreasonable and oppressive." Id. The Court has discretion to evaluate the 
circumstances in determining whether the subpoena is "unreasonable and oppressive." Matthews 
v. Kant, 427 So. 2d 369, 370 (Fla. 2d DCA 1983). "The sufficiency thereof is a factual 
determination for the trial judge who is vested with broad judicial discretion in the matter, and 
whose order will not be overturned absent a clear showing of abuse of discretion." Id.; see also 
Sunrise Shopping Center, Inc. v. Allied Stores Corp., 270 So. 2d 32 (Fla. 4th DCA 1972) (Fourth 
DCA quashing lengthy subpoena served on non-party who was not in control of documents as 
being "oppressive and unreasonable."). It is undisputed that Jane Doe No. 3 was sexually 
trafficked as a minor child by Jeffrey Epstein and he was sentenced for his crimes. Allowing the 
Defendant in this case to force this non-party to provide discovery on this highly sensitive topic 
would be both oppressive and unreasonable and serves no purpose other than to foster Defendant's 
publicly admitted and utterly baseless campaign to try to send Jane Doe No. 3 to "jail." 
The documents requested in Defendant's subpoena demonstrate the oppressive and 
unreasonable nature of the requests. Defendant, for example, seeks highly personal and sensitive 
information from this victim of sexual trafficking, including requesting her personal diary during 
the time when she was being sexually abused as a minor child. See Exhibit 6, Request no. 16. 
Defendant also demands that this non-party produce photographs and videos of her as a minor 
child while she was being sexually trafficked by convicted sex offender Jeffrey Epstein. See 
Exhibit 6, Request nos. 2, 3, 4 and 10. Defendant's unreasonable subpoena even includes a 
demand for this non-party's personal cell phone records for more than a three (3) year period 
during the time when she was a minor child being sexually trafficked. See Exhibit 6, Request no. 
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15. Defendant also demands items like personal financial documents from this non-party 
including payments she received from convicted sex offender Jeffrey Epstein and the men he 
"lent" this minor child out to from 1999 — 2002. See Exhibit 6, Request no. 20. It is without 
question that Defendant is abusing the subpoena power in this case to conduct a fishing expedition 
in an effort to intimidate and harass this victim and to try to dig up information he can use in his 
openly stated "goal" to send this non-party to "jail." 
Jane Doe No. 3 is rightfully fearful of Defendant as he is an incredibly powerful individual 
and the legal counselor to convicted Jeffrey Epstein who sexually trafficked Jane Doe No. 3 for 
years when she was a minor child. See Exhibit 8, Affidavit of Jane Doe No. 3. Jane Doe No. 3 
believes Defendant's goal is to abuse the subpoena power to get her into a deposition so he can 
harass and intimidate her by forcing her to discuss the abuse she had to withstand as a minor child. 
See Exhibit 8, Affidavit of Jane Doe No. 3. None of that childhood abuse is relevant to this case 
which involves the narrow issue of whether Defendant defamed two lawyers. Defendant's 
subpoena is both unreasonable and oppressive and should be quashed. See Matthews v. Kant, 427 
So. 2d 369, 370 (Fla. 2d DCA 1983). 
2. The Court Should Quash The Subpoena In Its Entirety. But At A Minimum, It 
Should Severely Limit The Production Requirements. 
In addition to its power to quash the subpoena, Florida Rule of Civil Procedure 1.280(c) 
also allows the Court to protect a non-party from discovery that would result in "annoyance, 
embarrassment, oppression or undue burden or expense..." Allstate Ins. Co. v. Langston, 655 So. 
2d 91, 94 (Fla. 2003) (Florida Supreme Court overturning denial of protective order and holding 
that "[d]iscovery of certain kinds of information `may reasonably cause material injury of an 
irreparable nature.") (internal quotations omitted). Matthews v. City of Maitland, 923 So. 2d 591, 
595 (Fla. 5th DCA 2006) (quashing discovery order where "[t]he compelled disclosure... would 
create a chilling effect on [petitioners] rights..."). The Court may determine that "the discovery 
5 
EFTA01078859

not be had" or that "the discovery may be had only on specified terms and conditions...". Fla. R. 
Civ. P. 1.280(c). 
Defendant issued a vastly overbroad subpoena to this non-party which included 25 
separate document requests, many with subparts. In addition to placing an undue burden on this 
non-party to have to search for the broad scope of materials requested, the document requests seek 
information that is irrelevant to the Florida Defamation Action and clearly intended to "embarrass 
and oppress" this non-party. Fla. R. Civ. P. 1.280(c). Defendant's overly broad subpoena to non-
party, Jane Doe No. 3, goes so far as to seek documents relating to former President, Bill Clinton 
and former Vice President, Al Gore, which, even if such documents existed, would be absolutely 
irrelevant to the Florida Defamation Action. See Toledo v. Public Super Markets, Inc., 30 So. 3d 
712 (Fla. 4ih DCA 2010). 
Defendant's requests can be grouped into four key categories: (1) documents that contain 
highly personal and sensitive information sought only to harass, embarrass and intimidate the non-
party; (2) documents unrelated to this action and, instead, intended to gain discovery relating to 
Defendant's admitted "goal" of putting this non-party in "jail," bringing a new case against Jane 
Doe No. 3, or related to the federal action; (3) documents that contain personal financial or other 
confidential information; and (4) privileged communications between the non-party and her 
lawyers. Non-party, Jane Doe No. 3, has filed specific objections as to each request sought in 
Defendant's subpoena as set forth in Exhibit 9. Here, Jane Doe No. 3 provides the Court with a 
sampling of the oppressive nature of the subpoena that is the subject of her detailed objections. 
a. Category 1 — Overly Broad Subpoena Requests Intended Solely to Harass. Embarrass 
and Intimidate the Non-Party by Seeking Highly Personal and Sensitive Information 
It is clear from the Defendant's requests that his intent is to intimidate and harass this non-
party by seeking highly sensitive personal information that is irrelevant to this action. For 
example, Request no. 16 seeks "Any diary, journal or calendar concerning your activities between 
6 
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January 1, 1999 and December 31, 2002." Defendant is seeking personal diary information during 
the time this non-party was a minor child and a victim of sexual trafficking. There is no reason 
this non-party should be forced to produce her diary from when she was a child. See Peisach v. 
Anton, 539 So. 2d 544 (Fla. 3rd DCA 1989) (court of appeal holding that trial court departed 
from the essential requirements of law by granting deposition of party's gynecologist which was 
only meant to invade privacy and intimidate and harass the party). 
Defendant also has a number of requests (Request nos. 2, 3, 4, 10 and 19) that seek 
"photographs" and "videos" of this non-party when she was a minor child and during the time she 
was the subject of sexual abuse. Photographs of Jane Doe 3 when she was a minor child are 
completely irrelevant to the matter before this Court. Defendant served this subpoena demand 
solely to intimidate, harass and embarrass this non-party and the Court should preclude this type 
of discovery set forth in Request Nos. 2, 3, 4, 10, 15, 16, 19 and 21. See Citimortgage, Inc. v. 
Davis, No. 50 2009 CA 030523, 2011 WL 3360318 (Fla. 15th Cir. Ct. April 4, 2011) (trial court 
granting protective order precluding a deposition noting "this deposition request is mere 
harassment" and had no relevance to the underlying dispute where the party was wrongfully using 
the discovery process for personal gain). 
b. Category 2 — Clear Abuse of the Subpoena Power By Seeking Documents Unrelated 
to this Action and Intended Instead to Provide Discovery for Other Actions 
Defendant is abusing the subpoena power of this Court by issuing subpoena requests that 
are intended to obtain discovery for the development of other actions against this non-party and 
are unrelated to the instant case. See Exhibit 5, Newsmax Interview ("And we're considering 
suing her for defamation as well, but right now she was trying to hide in Colorado and avoid 
service, but we found her and we served her and now she'll be subjected to a deposition."). 
Defendant has admitted that his "goal" is to put Jane Doe No. 3 in "jail" and he is using this 
Court's subpoena power to go on a fishing expedition in the hopes of fulfilling his ultimate stated 
7 
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"goal." See Toledo v. Publix Super Markets, Inc., 30 So. 3d 712 (Fla. 4th DCA 2010) (court of 
appeal quashing discovery order where party sought law firm client file relating to a different 
matter holding that "curiosity" about a law firm's records does not satisfy the relevance 
requirement and explaining that the contents of the "subpoena is a classic `fishing expedition' and 
the trial court's order departs from the essential requirements of the law."); Calvo v. Calvo, 489 
So. 2d 833, 834 (Fla. 3d DCA 1986) (quashing subpoena served on wife's bank for financial 
records finding them irrelevant: "indeed, the husband has failed to demonstrate what possible 
relevance the records might have in the proceeding below other than to harass the wife."). 
(emphasis added). 
Defendant's incredibly broad and unrelated demands include, for example, Request no. 24: 
"All documents concerning, relating or referring to your assertions that you met former President 
Bill Clinton, Former Vice President Al Gore and/or Mary Elizabeth "Tipper" Gore on Little Saint 
James Island in the U.S. Virgin Islands." See Exhibit 6, Request no. 24. Whether or not Jane Doe 
No. 3 met any of these individuals has absolutely nothing to do with the action before this Court. 
See Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 2003) (Florida Supreme Court holding 
that "we do not believe a litigant is entitled carte blanch to irrelevant discovery" and "`It is 
axiomatic that information sought in discovery must relate to the issues involved in the litigation, 
as framed in the pleadings.") (internal citations omitted). Defendant's Request demonstrates a 
blatant example of abuse of the subpoena power. 
Indeed, the face of many of Defendant's subpoena demands demonstrate that he is using 
the subpoena power of this Court to obtain discovery for the federal action. Request nos. I, 5, 6 
and 9 all reference the "federal action" or specifically cite the declaration and case number "OS-
SO736-CIV-MARRA/JOHNSON. Request no. 1, for example, demands: "All documents that 
reference by name, Alan M. Dershowitz, which support and/or confirm the allegations set forth in 
Paragraphs 24-31 of your Declaration dated January 19, 2015 and/or Paragraph 49 of your 
8 
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Declaration dated February 5, 2015, which were filed with the United States District Court for the 
Southern District of Florida, in Jane Doe #1 and Jane Doe #2 v. United States of America Case 
No. OS-S0736-CIV-MARRA/JOHNSON, [ECF No. 291-1] (the "Federal Action")." Defendant 
should not be using the subpoena power of this Court to issue a non-party subpoena for documents 
sought for a federal action.2
c. Category 3 — Documents that Contain Personal Financial Information Completely 
Irrelevant to this Action 
Defendant also wrongfully abuses the subpoena power to seek personal financial 
information from this non-party. See Woodward v. Berkery, 714 So. 2d 1027, 1034-38 (Fla. 4th
DCA 1998) (quashing lower court's discovery order and finding irreparable harm to husband in 
disclosure of private financial information when wife's clear purpose was to wrongfully disclose 
the financial information to the press) (emphasis added); see also Granville v. Granville, 445 So. 
2d 362 (Fla. I DCA 1984) (court of appeal overturning denial of protective order and finding that 
private financial information should have been protected from disclosure). 
The requests are clearly meant to intimidate and harass her by, for example, seeking 
information during the time she was the subject of sexual trafficking by Jeffrey Epstein. Request 
no. 20 seeks "All documents showing any payments or remuneration of any kind made by Jeffery 
Epstein or any of his agents or associates to you from January 1, 1999 through December 31, 
2002." Whether Jeffrey Epstein paid minor children that he sexually trafficked has absolutely 
nothing to do with the action before this Court and there is no basis to force a non-party who was 
subject to this abuse to comply with a production demand on this topic. The subpoena also 
includes request for financial information relating to the media. Apparently, Defendant believes 
Jane Doe No. 3 has a book "deal" in the works. For example, Request no. 18 seeks: "All 
documents concerning any monetary payments or other consideration received by you from any 
2 The requests relevant to this category are nos.: I, 5, 6,7, 8, 9, 12, 13, 14, 22, and 24. 
9 
EFTA01078863

media outlet in exchange for your statements (whether "on the record" or "off the record") 
regarding Jeffrey Epstein, Alan M. Dershowitz, Prince Andrew, Duke of York, and/or being a sex 
slave." Whether Jane Doe No. 3 has interacted with the media has nothing to do with the Florida 
Defamation Action. As explained above, a non-party's personal financial information and other 
confidential information is subject to protection by this Court. See Woodward v. Berkery, 714 So. 
2d 1027, 1034-38 (Ha. 4th DCA 1998). Accordingly, the requests relating to financial 
information from this non-party should be quashed;. 
d. Category 4 — Plainly Privileged Communications 
Defendant's subpoena requests seek documents that are plainly privileged. Florida courts 
are unequivocal in stating that an opposing party can never obtain attorney-client privileged 
materials. See Quarles & Brady LLP v. Birdsall, 802 So. 2d 1205, 1206 (Fla. 2d DCA 2002) 
(quashing discovery order and noting "undue hardship is not an exception (to disclosure of 
privileged material), nor is disclosure permitted because the opposing party claims that the 
privileged information is necessary to prove their case.") (internal citations omitted). Non-party, 
Jane Doe No. 3, objects to all of Defendant's subpoena requests to the extent that they seek 
documents protected by the attorney client privilege, work product doctrine, joint defense and 
common interest privileges and any other relevant privilege. Indeed, Jane Doe No. 3 should be 
protected from responding to Request no. 25 in its entirety because on its face it seeks solely 
privileged and confidential information relating to her retention of BSF.4 See Westco Inc. v. Scott 
Lewis' Gardening & Trimming, Inc., 26 So. 3d 620, 622 (Fla. 4ih DCA 2010) (court explaining 
that "[w]hen confidential information is sought from a non-party, the trial court must determine 
whether the requesting party establishes a need for the information that outweighs the privacy 
These Requests include nos. 9, 17, 18, 20 and 23. 
Specifically, Request no. 25 seeks: "All documents concerning your retention of the law firm Boies, 
Schiller & Flexner LLP, including but not limited to: signed letter of retainer, retention agreement, 
explanation of fees, and/or any documents describing the scope of retention." 
10 
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rights of the non-party."). Defendant has not established any basis for these privileged and 
confidential documents that outweighs this non-party's privacy rights. 
3. The Subpoena Should Be Quashed In Its Entirety. If the Court Will Not Take 
That Action, at a Minimum, It Should Grant a Protective Order Severely 
Limiting The Areas Of Inquiry At Deposition And Grant Protections For This 
Victim Who Is Fearful Of The Defendant. 
This Court has the power to preclude and/or limit the deposition of non-party Jane Doe No. 
3. Specifically, Florida Rule of Civil Procedure 1.280(c) allows the Court to prevent a deposition 
from going forward "to protect a party or person from annoyance, embarrassment, oppression or 
undue burden or expense that justice requires," and courts routinely enter protective orders to 
reduce the burden on subpoenaed non-parties to a case, as well as in cases where the discovery 
sough is irrelevant. See, e.g., Peisach v. Antuna, 539 So. 2d 544 (Fla. 3d DCA 1989) (holding that 
the trial judge erred in allowing the deposition of certain non-parties where evidence sought was 
irrelevant); see also Citimortgage, Inc. v. Davis, No. 50 2009 CA 030523, 2011 WL 3360318 (Fla. 
15'h Cir. Ct. April 4, 2011) (trial court granting protective order precluding a deposition noting 
"this deposition request is mere harassment" and had no relevance to the underlying dispute where 
the party was wrongfully using the discovery process for personal gain). Section 4 of Rule 1.280 
provides that the Court can also limit the areas of inquiry of a deposition providing "that certain 
matters not be inquired into, or that the scope be limited to certain matters." 
Jane Doe No. 3 contends that the subpoena for her deposition should be quashed. If the 
Court, however, is inclined to allow a deposition of Jane Doe No. 3, then she respectfully requests 
the issuance of a Protective Order modifying the subpoena as set forth below. 
a. Testimony Limitations 
Non-party Jane Doe No. 3 respectfully requests that this Court limit the deposition to 
questions directly related to Defendant's defamatory statements about Brad Edwards and Paul 
Cassell. The Court should limit Defendant's ability to engage in a "fishing expedition" of this 
11 
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victim to foster his goal of putting her into "jail" or of bringing a new action against Jane Doe No. 
3. See Peisach v. Antuna, 539 So. 2d 544 (Fla. 3d DCA 1989); see also Citimortgage, Inc. v. 
Davis, No. 50 2009 CA 030523, 2011 WL 3360318 (Fla. 15th Cir. Ct. Apr. 4, 2011). Defendant 
should be precluded from asking any questions about Jane Doe No. 3's experiences as a sexually 
trafficked minor. Defendant should be precluded from questioning Jane Doe No. 3 about 
individuals that she was sexually trafficked to or about other victims or individuals involved in the 
sexual trafficking orchestrated by Jeffrey Epstein. Defendant should be precluded from 
questioning Jane Doe No. 3 about any rapes that occurred when she was a minor child. Defendant 
should be precluded from questioning Jane Doe No. 3 about anything related to her sexual activity 
either as a minor or thereafter as these questions would only be intended to embarrass and harass 
this non-party witness. 
b. Language and Harassment Limitations 
In addition, Jane Doe No. 3 requests that the Court provide counsel with a cautionary 
notice, that counsel for Defendant may not harass the non-party victim in any way during the 
deposition. With respect to the language used at the deposition, the Defendant's counsel should be 
directed by the Court to not use any of the derogatory terms the Defendant has used in the press 
including calling Jane Doe No. 3 a "prostitute," a "liar," or a "bad mother" or any other similar 
derogatory and harassing language. 
c. Physical Location Limitations 
Non-party Jane Doe No. 3 has a valid and real basis to fear being in physical proximity of 
the Defendant. See Exhibit 8, Affidavit of Jane Doe No. 3. Accordingly, to the extent a 
deposition is to go forward, we would request that the Court direct that the Defendant not be 
present in the same room as non-party Jane Doe No. 3 and, instead, follow the testimony 
electronically from a separate location. In addition, non-party Jane Doe No. 3 respectfully 
requests that the Court hold that the physical location of the deposition should be the offices of 
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Jane Doe No. 3's attorney's Boies, Schiller & Flexner LLP. 
CONCLUSION 
WHEREFORE, non-party Jane Doe No. 3 respectfully requests that this Court grant her 
Motion to Quash, or alternatively, that the Court enter an order limiting the scope of her document 
production and deposition as set forth above. 
Dated: April 9, 2015 
Respectfully submitted, 
SHIES, SCHILLER & FLEXNER LLP 
401 East Las Olas Boulevard, Suite 1200 
Fort Lauderdale Florida 33301 
Telephone; 
Facsimile: 
By: /s/Sigrid S. McCawlev 
Sigrid S. McCawley, Esq. 
Florida Bar No. 129305 
Attorney for Non-Party Jane Doe No. 3 
13 
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CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on April 9, 2015, a true and correct copy of the foregoing was 
served by Electronic Mail to the individuals identified below. 
By:Js/Sigrid S. McCawley 
Sigrid S. McCawley 
Thomas E. Scott 
Steven R. Safra 
COLE, SCOTT & KISSANE, P.A. 
9150 S. Dadeland Blvd., Suite 1400 
Miami. Florida 33156 
Richard A. Simpson 
Mary E. Borja 
Ashley E. Eiler 
WILEY REIN, LLP 
1776 K Street NW 
Washington, D.C. 20006 
Counsel for Defendant Alan Dershowitz 
Jack Scarola 
SEARCY DENNEY SCAROLA BARNHART & 
SHIPLEY, P.A. 
2139 Palm Beach Lakes Blvd. 
West Palm Beach, FL 33409-6601 
Attorney for Plaintiffs 
14 
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EXHIBIT 1 
EFTA01078869

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Judge tosses 'sex slave' claims involving Prince Andrew - NY Daily News 
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http://www.nydailynews.com/news/national/judge-tosses-sex-slave-claims-involving-prince... 4/9/2015 
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Judge tosses 'sex slave' claims involving Prince Andrew - NY Daily News 
Page 3 of 4 
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http://www.nydailynews.comthews/national/judge-tosses-sex-slave-claims-involving-prince... 4/9/2015 
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Judge tosses 'sex slave' claims involving Prince Andrew - NY Daily News 
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