EFTA01111154

Filing # 38774829 E-Filed 03/08/2016 07:20:19 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. 
OPPOSITION TO DEFENDANT'S MOTION TO CONTINUE 
HEARING AND MOTION TO STRIKE MOTION OF NON-PARTY VIRGINIA 
ROBERTS' MOTION FOR SANCTIONS 
Non-Party 
y and through undersigned counsel, hereby responds to 
Defendant's Motion to Continue Hearing and Motion to Strike Motion of Non-Party 
Motion for Sanctions and states as follows: 
MIll 
ROM C FION 
Dcrshowitz has had it his mission to publically disgrace 
-- who was a 
victim of sexual trafficking when she was a minor -- calling her, among other things, a 
"prostitute" and a "bad mother" during his press conferences. See Affidavit of Sigrid McCawley 
("McCawIcy Affidavit") at Exhibit I, Local 10 News, January 22. 2015. Dershowitz has 
subpoenaed Ms. 
cstitnony in this matter and engaged in confidential settlement 
discussions with her lawyers. He then, knowingly, wrongfully and willfully, revealed those 
confidential settlement discussions to the New York Times for purposes of inflicting harm to 
character by callously misrepresenting those confidential settlement 
*** FILED: BROWARD COUNTY. FL HOWARD FORMAN. CLERK 3/8/2016 7:20:19 PM 
EFTA01111154

discussions 
ounsel immediately filed an emergency motion with the Court 
asking the Court to seal the offending affidavit that he filed with this Court and that had been 
intentionally leaked to the press. The Court granted Ms.notion 
to Seal and resented 
ruling on her Motion to Strike and for Sanctions to allow counsel for Dershowitz time to 
respond. Dershowitz's counsel agreed that the matter would be heard at the Special Set Hearing 
on March 11, 2016. Now, just days before the special set hearing. Dershowitz has hired yet 
another set of new lawyers who he contends have a conflict with the March 11, 2016 date and 
therefore, asks the Court to cancel the Special Set Hearing. Dershowitz is clearly misstating his 
ability to have counsel present at this Friday's hearing because he testified that he has an attorney 
client relationship with over 35 lawyers. See McCawley Affidavit at Exhibit 2 (Dershowitz's 
Deposition Transcript at pgs. 24-42). Surely one of his able counsel can be present at the hearing 
on the date they specifically agreed to. See McCawley Affidavit at Exhibit 3. E-mail 
Correspondence confirming the March 1 l'h Special Set Hearing date. 
What Dershowitz is really trying to do here is find a way to stall the sanctions hearing 
because he knows his conduct was in clear bad faith in two ways — first by intentionally 
revealing and misrepresenting confidential settlement discussions to the Court. public and press, 
and, second, even after the Court made a finding that the discussions were confidential and 
scaled the affidavit, Dershowitz directly violated that order by again misrepresenting those 
confidential settlement discussions at his deposition. Dershowitz knows he has no valid basis to 
avoid being sanctioned by this Court for his flagrant bad faith litigation conduct, so he is 
grasping for a way to try to avoid having the motion to strike and for sanctions heard. 
Dershowitz's eleventh hour attempt to avoid having the sanctions motion heard is his 
unsupported argument that M =vho 
was subpoenaed by him in this case and clearly 
injured by his conduct, does not have standing to seek recourse for Dershowitz's wrongful 
2 
EFTA01111155

actions against her. This argument is a red herring and indeed Dershowitz's own counsel stated 
that Ms. ad 
standing to participate and object in this proceeding. See McCawley 
Affidavit at Exhibit 2 (Dershowitz Deposition at 95). Dershowitz's other argument that is 
equally baseless is that he contends the parties may be settling, and therefore, he is intentionally 
stalling this hearing in the hopes of arguing that the Court would be divested of jurisdiction to 
hear this issue if the parties entered a voluntary dismissal. The Court can obviously retain 
jurisdiction over certain matters even if the parties did submit a stipulated dismissal to this Court 
— but more importantly — no such dismissal has been submitted. 
ARGUMENT 
1. 
Dershowitz's Is Repeatedly Engaging In Bad Faith Litigation Conduct And He 
Should Be Sanctioned. 
Mr. Dershowitz brings this motion in bad faith: it is a transparent attempt to avoid this 
Court's imposition of sanctions for his violation of this Court's Order and other behavior in 
contravention of Florida law'. By his own sworn testimony, Mr. Dershowitz is represented by 
35 attorneys. lie neither alleges that they no longer represent him, nor that they are unable to 
represent him competently in Friday's hearing. Indeed, it would be hard to find a party with 
more capable or plentiful representation. Instead, he has suddenly, allegedly, decided upon new 
counsel on the eve of his sanctions hearing. Conveniently, neither of those attorneys are 
available for the March I I, 2016 Special Set Hearing that Dershowitz's other counsel agreed to. 
(Defendant's Motion to Continue at 2). 
The motion for sanctions arises, in part, over Mr. Dershowitz's flagrant violation of this 
Dershowitz had full opportunity to brief these issues in response to Ms. 
Motion to Seal and his 
mos 
otion to Strike is simply an effort to try to supplement his prior response without allowing 
Ms. 
counsel sufficient time to respond in advance of the hearing. Accordingly, to the extent the 
Court moves the hearing to a later date, counsel for Ms 
reserves her right to supplement this 
filing. 
3 
EFTA01111156

Court's Order. This Court should not countenance Mr. Dershowitz's continued flouting of this 
Court's authority by allowing him to avoid the hearing on sanctions based on a bad faith 
maneuver to delay. "A trial court has broad discretion to impose sanctions on litigants for their 
conduct before the court," Riley v. Associates Home Equity Serve.. Inc., and this bad faith motion 
to avoid his hearing on the same constitutes additional grounds to grant the motion for sanctions. 
850 So. 2d 661, 663 (Fla. Dist. Ct. App. 2003).2
2. 
Ms
lHas Standing to Seek Redress for Dershowitz's Bad Faith 
Litigation Conduct as She is the Party Who Suffered iniury From That 
Conduct 
a. 
Ms. =Bias 
Suffered an Injury in Fact and has Standing Seek Relief 
from the Court for Her injuries 
Individuals have standing to vindicate their own legal rights. A person has standing to 
redress a harm when they have "more than an indirect or inconsequential interest in the case." 
See Sweetwater Country Club Homeowners Association Inc. v. Husker Co., 613 So.2d 936 (Fla. 
I' DCA finding that country club had standing to seek redress in the action where its interest in 
the property could be affected). Nonparties have standing if their rights are adversely affected. 
See In re Piper Funds, Inc., 71 F.3d 298, 301 (8th Cir.1995). See also Stoppa v. Hal Harbour 
VW., 385 F. App'x 932, 934 (1 1th Cir. 2010) (" A non-party has standing to challenge a 
judgment on certain grounds if his "rights [are] directly compromised by the final judgment."): 
Kern MM. Corp. v. Wilder. 817 F.2d 1517, 1521 (11th Cir.1987) ("A non-party has standing to 
challenge a judgment on certain grounds if his "rights fare] directly compromised by the final 
2 With respect to Defendant's request for a continuance, Ms. Cs
 not agree to a continuance for 
the reasons outlined in this brief in that Ms 
tly believes it is simply a delay tactic being 
employed intentionally by Dershowitz. Ho I. v ,
undersigned counsel conferred with the Judge's JA, 
and through an administrative error, the Special Set Hearing was canallecSt) Defendant's notice and was 
not re-set in accordance with the Special Set Revised Notice that Msaled 
with the Court 
(McCawley Affidavit at Exhibit 4. Re-Notice of Special Set Hearing) and the Court cannot hear the 
matter on Friday at 10:00 am. The undersigned counsel is seeking alternative dates of the earliest 
possible special set time and will circulate those dates to counsel as soon as they arc provided. 
4 
EFTA01111157

judgment."); Dunlop v. Pan Ana. Workl Airways. Inc., 672 F.2d 1044. 1052 (2d Cir.1982) 
(holding a non-party must be "sufficiently connected and identified with the ... suit to entitle 
[him) to standing to invoke Rule 60(b)(6)"). 
The First Circuit has held that a non-party witness had standing to bring Rule II 
sanctions against a party. Jyrer v. Winterthur International, 290 F.3d 456, 460 (1" Cir. 2002). 
As in Nyer, there is no one situated in these proceedings to vindicate Ms 
rights except 
for herself, the person who was injured. Indeed, Mr. Dershowitz names no other person with 
standing who could seek redress for her injuries, and therefore. his standing argument is merely 
an attempt to violate her rights with impunity. 
M
I
Ms 
as been injured in this action and she is entitled to seek sanctions against 
Dershowitz for his conduct. CI: Nixon v. Warner Commcins. Inc., 435 U.S. 589. 599, 98 S. Ct. 
1306. 1313, 55 L. Ed. 2d 570 (1978) ("allegations of further embarrassment . . . and additional 
exploitation of materials originally thought to be confidential establish injury in fact that would 
be redressed by a favorable decision of his claim."). By extension, NMas 
standing in 
seeking redress for publication of her attornev's statements that were made during confidential 
settlement discussions. Ms.Mills 
suffered injury in fact when Mr. Dershowitz published 
and misrepresented her confidential settlement negotiations, and she, therefore, has standing to 
vindicate her rights. 
b. 
As a Witnesses in This Case Ms 
Has Standing to Seek Relief from 
the Court for Injuries She Has Su ere 
Witnesses have standing to seek redress with the Court for injuries they suffer. See 
Adamson-.lames v. Florida Dept ofrorn, No. 6:11-CV-628-ORL-35TB, 2013 WL 1703541, at 
*2 (M.D. Ha. Mar. 22, 2013) report and recommendation adopted, No. 6:11-CV-628-ORL-36, 
2013 WL 1703520 (M.D. Fla. Apr. 19, 2013) (holding that "[ilf there was evidence that 
5 
EFTA01111158

Defendants were intimidating witnesses then those witnesses would have to seek the protection 
of the Court."). citing Refoule v. Ellis, 74 F.Supp. 336, 343 (N.D.Ga.1947) ("If [the witnesses'] 
civil rights have been violated, they may institute proper proceedings to protect themselves, but 
such rights are not personal to plaintiff."). See also Foster v. Pall Aeropower Corp., I 1 1 F. 
Supp. 2d 1320, 1322-23 (M.D. Fla. 2000) ("The Eleventh Circuit has permitted witnesses to 
pursue claims pursuant to the second clause of section 1985(2)"). 
In Westmoreland v CBS, Inc. 770 F.2d 1168 (D.C. Cir. 1985), a nonparty witness sought 
redress for defense counsel's failed contempt proceedings against him. The D.C. Circuit Court 
of Appeals remanded the case to the district court for the imposition of Rule 11 sanctions against 
the party based upon the nonparty witness's motion. Similarly, here. Mr. Dershowitz brought 
Ms 
into this action by issuance of his subpoena. Mr. Dershowitz violated her rights and 
injured her by revealing, and then miseharacterizing, confidential settlement discussions to the 
public, in contravention of this Court's Order. Mr. Dershowitz has caused Ms.a) 
starer 
an injury to her rights through these proceedings, and therefore may seek sanctions against Mr. 
Dershowitz. Both common sense and the law dictate that Ms 
can seek redress from this 
Court for her injuries. 
c. 
As an Affected Non art
 Rule 2.420, Florida Rules of Judicial 
Administration, Ms 
has Standing to Seek Redress for Her Injuries 
Dershowitz lists a lot of things that Ms. 
c not, but fails to light upon what she is. 
Under the Rule 2.420(b), Florida Rules of Judicial Administration. Ms=s 
an "affected 
non-party," as she is "a non-party identified by name in a Court record that contains confidential 
information pertaining to that non-party." This Court established her identity as such when ruled 
on her motion to make her deposition testimony sealed and confidential pursuant to Rule 2.420, 
Florida Rules of Judicial Administration. "Affected non-parties" have rights in the 
6 
EFTA01111159

„A< 
c# 
c# 
er# 
st 
<Q44 
legal proceedings in which their information is involved" Rule 2.420(d)(2)(A).3 Indeed, the 
•*••• 
4e 
Florida Rules of Judicial Administration endow "affected nonparties" with a number of rights, 
st, and nothing in these Rules at all indicates that an affected non-party would not have standing to 
seek sanctions when a party willfully violates the confidentiality and protections these Rules 
' 
a 
%cis.. 
t
., - 
were designed to provide. Such an argument is contrary to public policy. 
44(
Comparably, under the Florida Rules of Criminal Procedure, a nonparty to a judicial 
aOS 
4 .3 
%St- 
proceeding has standing to challenge the release of discovery materials related to the proceeding. 
' Times Pub. Co. v. State, 903 So. 2d 322, 326 (Fla. Dist. Ct. App. 2005), Fla. R. Crim. P. 3.220. 
Similarly, this Court should find that a nonparty in a civil case has standing to challenge the 
si 
release of confidential settlement negotiations, particularly in this case, when those materials 
N.4 4
 contain evidence of sexual crimes committed against her as a minor child. Allowing the release 
of this type of sensitive information related to an affected non-party victim of a crime to go 
unchallenged undermines the purpose of Fla. R. Crim. P. 3.220. 
d. 
Mr. Dershowitz's Arguments Fail 
4 
N-4 
Unsurprisingly, Dershowitz has cited to no case in any jurisdiction where a court has 
found that an affected nonparty, or a nonparty witness, does not have standing to seek redress for 
injury they directly suffered by a party's conduct. This Court has already adjudicated Ms. 
rivacy rights in this case when it ordered her testimony about the sexual abuse she 
suffered as a minor child to be scaled under Rule 2.420, Fla. R. Jud. Admin., and found Ms. 
4 3 "For example, affected non-parties have standing to file a Notice of Confidential Information within 
-$,>•
C'ourt Filing if the document was not initially filed in that manner." Rule 2.4200)(2)(M. 
4 
4,c, 
st, if party moves to affect the confidentiality of an affected non-party, they must serve the affected non-
party with notice of any such motions that would affect their confidential information. See 2.420 (d)(4). 
(05). 
4  
Similarly. parties cannot make an oral motion to determine the confidentiality of trial court records unless 
"affected non-panics" arc present or properly noticed. Rule 2.420 (h00 )(8). 
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EFTA01111160

settlement
negotiations to be confidential. See McCawley Affidavit at Exhibit 5, 
December 18. 2015, Emergency Motion to Seal Hr. Tr. at 23:11-25:8. It is this non-party, Ms. 
who suffered injury in tact when Mr. Dershowitz intentionally, willfiilly and wrongfully 
disclosed confidential settlement discussions, and, therefore, she has standing to seek redress. 
CONCLUSION 
WHEREFOREME 
espeetfully requests that this Court deny Defendant's 
Motion to Continue Hearing and Deny His Motion to Strike Non-Part 
Motion for Sanctions. 
Dated: March 8, 2016 
Respectfully submitted, 
BOIES, $CHILLER & FLEXNER LLP 
401 East Las Olas Boulevard, SUite 1200 
Fort Lauderdale, Florida 33301 
By: /s/Sigrid S. McCawlev 
Sigrid S. McCawley, Esq. 
Florida Bar No. 129305 
Attomey. for Non-Party Virginia Giuffre 
8 
EFTA01111161

CERTIFICATE OF SERVICE \‘'" 
I HEREBY CERTIFY that on March 8, 2016, a true amfeorrect copy dtthe foregoingP 
was served bitlectronic Mail to the individuals identified bow. 
By: /s/Sigrid S. McCawley 
Sigrid S. McCawley 
Thomas E. Scott 
im 
ra 
teven . a 
IIIIIIIIMM. 
A. 
9150 S. Dadeland Blvd., Suite 1400 
Miami, Florida 33156 
Counsel for Alan Dershowitz 
Richar A. Sim son 
• 
_ 
WILEY REIN, LLP 
1776 K Street NW 
Washington, D.C. 20006 
Counsel for Alan Dershowitz 
Charles H. Lichtman, Esq. 
Bruce S. Rogow, Esq. 
BERGER SINGERMAN LLP' 
BRUCE S. ROGOW, P.A. 
---" 
350 E. Las Olas Blvd. 
100 NE 3rd Avenue, Suite 1000 
Suite 1000 
Fort auderdale FL 33301 
Fort Lauderdale, FL 33301 
Email: 
Counsellor Alan Dershowitz 
Kenneth A. Sweder, Esq. 
Jack Scarola 
SWEDER & ROSS, LLP 
SEARCY DENNEY SCAROLA BARNHART 
131 Oliver Street 
& SHIPLEY, P.A. 
Boston, MA 02110 
iIIIIIIIes Blvd. 
West Palm Beach, FL 33409-6601 
Counsel for Alan Dershowitz 7
Attorney for Plaintiffs 
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EFTA01111162

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. 
' 
' 16121D S. NIcCAWLEY IN SUPPORT OF 
OPPOSITION TO DEFENDANT'S MOTION 
NTINUE AND MOTION TO 
1, Sigrid S. McCawley, declare that the below is true and correct to the best of my 
knowledge, as follows: 
1. 
I am a partner with the law firm of Boies, Schiller & Flexner la and duly licensed 
to practice in Florida. 
2. 
I respectfully submit this Affidavit in support 
Opposition to 
Defendant Alan Dershowitz's Motion to Continue and Motion to Strike. 
3. 
Attached hereto as Exhibit I, is a true and correct copy of the January 22, 2015 
Local 10 News Article. 
4. 
Attached hereto as Exhibit 2, is a true and correct copy of Excerpts from the 
October 15, 2015 Deposition of Alan Dershowitz. 
5. 
Attached hereto as Exhibit 3, is a true and correct copy of the February 16, 2016 
Email Correspondence from to/from Sigrid McCawley. 
EFTA01111163

6. 
Attached hereto as Exhibit 4, is a true and correct copy of the Re-Notice of Special 
Set llearing for March 11, 2016. 
7. 
Attached hereto as Exhibit 5, is a true and correct copy of Excerpts from the 
December 18, 2015 11 caring Transcript. 
declare under penalty of perjury that the foregoing is true and correct. 
igrid 
McC wley. Esq. 
2 
EFTA01111164

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Alan Dershowitz: 'Sex slave' accuser is serial liar, prostitute I News - Home 
Page I of 3 
Local 
.com 
Alan Dershowitz: 'Sex slave' accuser is serial liar, prostitute 
Famed attorney slams woman who claims he had underaged sex with her 
Author: Bob Norman, Reporter, hnorman@ Local to.com 
Published On: Jan 22 2015 06:03:14 PM EST Updated On: Jan 22 2015 06:20:00 PM EST 
PEMBROKE PARK, Fla. -
Well-known attorney and Miami Beach resident Alan Dershowitz emphatically denied allegations made i❑ 
newly!fited court papers th at he had sex six times with an underage girl who at the time was serving 
as a "sex slave" for wealthy financier -- and convicted sex offender -- Jeffrey Epstein. 
Related: Billion aitel.; tt:ex slave'. details allegations against Prince Andrew, Dershowitz 
"This is a woman who is a serial liar," Dershowitz told Local to News reporter Bob Norma 
"She's lied, lied, 
lied, lied." 
"But she wasn't lying about being sexually abused by Jeffrey Epstein," said Norman. 
"That is a different issue," said Dershowitz. "That is between her and Jeffrey Epstein." 
http://www.Iocal 0.comMewsialan-dershowitz-sex-slave-accuser-is-serial-liar-prostitute/3... 
211912015 
EFTA01111167

Alan Dershowitz: 'Sex slave' accuser is serial liar, prostitute News - Home 
Page 2 of 3 
The woman is 
ne of as many as 40 women who allege that Epstein recruited them while 
they were minors into a sex ring based at Epstein's Palm Beach mansion. 
alleges in a 14-page affidavit -- which included newly-released photos she said were taken by Epstein 
when she was is -- that Epstein groomed her as "sex slave" to gratify not only him but his powerful friends. 
She wrote that she was introduced to Epstein at the mansion by heiress Ghislaine Maxwell, the daughter of the 
late British publisher Robert Maxwell, on the pretext that she would be paid to give him a "massage," which she 
wrote was Epstein's "code word for sexual encounters." 
"From the r 
I was taken to Epstein's mansion that day, his motivations and actions were sexual, as were 
Maxwell's," 
writes in the affidavit. "My father was not allowed inside. I was brought up some stairs. 
There was a na 
guy, Epstein, on the table in the room. Epstein and Maxwell forced me into sexual activity 
with Epstein ... I was paid Szoo." 
She wrote that she then began working for Epstein, and traveling around the country and world with him. 
"Jeffrey Epstein and Ghislaine Maxwell trained me to do what they wanted, including sexual activities and the 
use of sexual toys," she wrote. 'The training was in New York and Florida at Epstein's mansions. It was 
basically every day and was like going to school... i was trained to be 'Everything a man wanted me to be.' It 
wasn't just sexual training -- they wanted me lobe able to cater to all the needs of the men they were going to 
send to me." 
In the affidavit, she alleges that Dershowitz was one of those men and that she had sex with him six times 
beginning when she was 16 at Epstein's residences, as well as on his jet and private island. She also added 
details about her allegations that Epstein -- who served 13 months in jail after being convicted of soliciting a 
minor for sex in 2008 -- ordered her to have sex on three occasions with Prince Andrew in London at the age of 
ty, paying her St5,000 after the first instance. 
Reacl the entire 14-page affidavit here. 
Dershowitz said 
her three children. 
was a prostitute and questioned whether she is now, at the age of 31, a fit mother for 
"She's now an admitted prostitute," said Dershowitz. "I can tell you she is still a prostitute: she is selling these 
false stories now for money about me. That is a form of prostitution." 
"Do you have any concern calling her a prostitute when she was victimized at such an early age by a wealthy 
man?" Norman asked. 
"She was not victimized ... she made her own decisions in life," said Dershowitz. 
"But at the age of 15 some would say ... she was taken advantage of," said Norman. 
"I'm talking about the age of 19," said Dershowitz. 
"But it started when she was 15," said Norman. 
"I am not invoked in that," he said. "I have no knowledge of that. That's between her, and the federal 
government and the people who victimized her. All I know is she has victimized me. At the age of 31 she has 
made up false allegations against me. She is a mother of three children, and she is now living a lie to her three 
children and the question is whether she is an adequate mother of her three children going around selling her 
false stories of prostitution." 
Dershowitz is an admitted long-time friend of Epstein's who frequented his homes at the time= 
and 
other young girls were in Epstein's employ. But he insisted he never saw an underage girl in Epstein's company. 
A former Epstein employee, the late Alfredo Rodriguez, testified under oath that Dershowitz was at the Palm 
Beach mansion at the same time underage girls were at the home. 
http://www.local10.com/ncws/alan-dershowitz-sex -slave-accuser-is-serial-liar-prostitute/3... 
2/19/2015 
EFTA01111168

Alan Dershowitz: 'Sex slave' accuser is serial liar, prostitute News - Horne 
Page 3 of 3 
"That's not true," said Dershowitz. 
was never in Jeffrey Epstein's house or any of the houses in the presence 
of any young woman. Now were there other young women in other parts of the house giving massages when I 
wasn't around? I have no idea of that. I can only say I never sew a young underage woman. If I had 1 would 
have left the house and never come back, period? 
He told Norman that he had one massage at Epstein's home and it was with an adult woman. 
"I kept my underwear on during the massage," lie said. "I don't like massages particularly." 
One of the more salacious allegations made by 
is that Dershowitz "was so comfortable with the sex that 
was going on that he would even come and chat wit Epstein while I was giving oral sex to Epstein." Dershowitz 
called that allegation absurd. 
"Alan Dershowitz was standing there and talking about what? The weather, the stock market? It's the most 
preposterous thing imaginable," said Dershowitz. 
Dershowitz, who has issued a denial t 
basic claims in a sworn affidavit of his own, said he would 
willingly be deposed on the matter. 
attorneys have claimed that Dershowitz has refused to submit to 
deposition. 
When questioned about it, Dershowitz said he would be deposed in the case, but only after 
nd her two 
lawyers are deposed. The lawyers have sued Dershowitz for defamation after he alleged they should be 
disbarred for initially putting 
allegations in court papers. 
"I am happy today to express my willingness to be deposed after the three of them are deposed," he said. "That's 
the order it should occur because they are the accusers. I am the one who is defending myself against their 
accusations? 
Follow Local to News on Twitter tiypt.GLocaito 
Copyright 2015 by Localto.com. All rights reserved. This material may not be published, broadcast, rewritten 
or redistributed. 
2015 O 2015 
hup://www.local10.com/news/alan-dershowitz-sex-slave-accuser-is-serial-liar-prostitute/3... 2/l 9/20 IS 
EFTA01111169

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EFTA01111170

1 
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 N. DERSHOWITZ, 
Defendant. 
VIDEOTAPE DEPOSITION OF 
ALAN M. DERSHOWITZ 
VOLUME 1 
Pages 1 through 179 
Thursday, October 15, 2015 
9:31 a.m. - 4:13 p.m. 
Cole Scott a Kissane 
110 Southeast 6th Street 
Fort Lauderdale, Florida 
Stenographically Reported By: 
Kimberly Fontalvo, RPR, CLR 
Realtime Systems Administrator 
EFTA01111171

2 
1 
APPEARANCES: 
2 
On behalf of Plaintiffs: 
3 
SEARCY, DENNEY, SCAROLA 
4 
BARNHART 4 SHIPLEY, P.A. 
2139 Palm Beach Lakes Boulevard 
5 
West Palm Beach, Florida 33402-3626 
SQ. 
6 
7 
8 
On behalf of Defendant: 
9 
COLE, SCOTT & KISSANE, P.A. 
Dadeland Centre II - Suite 1400 
10 
9150 South Dadeland Boulevard 
Miami, Florida 33156 
11 
BY:aTHOMAS EMERSON SCOTT, JR., ESQ. 
12 
B : 
:SAE 
E . 
(Via phone) 
14 
SWEDER 4 ROSS, LLP 
131 Oliver Street 
15 
Boston, MA 02110 
BY: KENNETH A. SWEDER ESQ. 
16 
13 
--an 
17 
--an 
18 
WILEY, REIN 
17769 K Street NW 
19 
Washington, DC 20006 
BY: RICHARD A. SIMPSON, ESQ. 
20 
RSimpson@wileyrein.com 
BY: NICOLE A. RICHARDSON, ESQ. 
21 
22 
23 
24 
25 
EFTA01111172

3 
APPEARANCES ;Continued): 
2 
3 
On behalf of Jeffrey Epstein: 
4 
MARTIN G. WEINBERG, PC 
20 Park Plaza, Suite 1000 
S 
Boston, MA 02116 
BY: MARTIN G. WEINBERG. ESQ. (Via phone) 
6 
7 
--an 
DARREN K. INDYKE, PLLC 
575 Lexington Ave., 4th Fl. 
9 
New York, New York 
BY: DARREN K. INDYKE, ESQ. (Via phone) 
10 
11 
On behalf of Virginia Roberts: 
12 
BOIES, SCHILLER & FLEXNER, LLP 
401 E. Las Olas Blvd., Ste. 1200 
13 
Fort Lauderdale, Florida 33301 
BY: SIGRID STONE MCCAWLEY, ESQ. 
14 
15 
16 
ALSO PRESENT: 
17 
Joni Jones, Utah Attorney General Office 
18 
Travis Gallagher, Videographer 
19 
20 
21 
22 
23 
24 
25 
EFTA01111173