EFTA01116468

the same subject matter. Moreover, Plaintiffs — a 
ounsel — have likewise waived the 
attorney-client privilege by filing this litigation and placing at issu=k 
Ilegations against 
Dershowitz and their investigation of same. Discovery has already shown that Plaintiffs will rely 
on their communications with
stablish their claims and defeat Dershowitz's defenses. 
For the same reasons, Plaintiffs also have waived their right to rely on the work product doctrine. 
In any event, Dershowitz has met his burden of establishing that the work product doctrine 
should be overcome in these circumstances. Allowing Plaintiffs to rely on the work product 
doctrine and/or the attorney-client privilege in these circumstances would result in nothing more 
than the concealment of the truth and deny Dershowitz access to information that is vital to his 
defense. 
Dershowitz is entitled to a complete production of responsive information. Plaintiffs' 
general and broad references to public documents filed in other litigation in response to specific 
discovery requests are improper. Plaintiffs cannot compel Dershowitz to go on a fishing 
expedition. Also, discovery directed at Plaintiffs' and = 
bias, intent, motivation, and 
credibility are directly relevant and subject to production. Plaintiffs' arguments fail. 
WHEREFORE, 
Defendant/Counterclaim 
Plaintiff, 
ALAN 
M. 
DERSHOWITZ, 
respectfully requests this Honorable Court enter an Order (a) overruling Plaintiffs' objections to 
Dershowitz's discovery requests; (b) compelling Plaintiffs to produce all documents responsive 
to Dershowitz's First, Second and Third Sets of Document Requests in a timely manner, and 
state in any amended response when complete; (c) compelling Plaintiffs to provide complete 
responses to Dershowitz's First Sets of Interrogatories in a timely manner, and again, state in any 
amended response when complete; and (d) such other and further relief as this Court deems just 
and proper. 
21 
EFTA01116488

Respectfully submitted, 
/s/ Thomas E. Scott 
Thomas E. Scott, Esq. 
Florida Bar No. 149100 
Florida Bar No. 057028 
Dadeland Centre II, 14th Floor 
9150 South Dadeland Boulevard 
Richard A. Simpson (pro hac vice) 
ary . or apro ac vice) 
Ashley E. Eiler (pro hac vice) 
WILEY REIN LLP 
1776 K Street, NW 
Washin ton. DC 20006 
Counsel for Alan M. Dershowitz 
22 
EFTA01116489

CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that a copy of the foregoing has been furnished by electronic mail 
(email) 
at 
email 
address: 
1
m to: Jack Scarola, Esq, Searcy Denney Scarola Bamhart & Shipley, 
P.A., Counsel for Plaintiff, 2139 Palm Beach Lakes Blvd., West Palm Beach, Florida 334O9, and 
I electronically filed the foregoing with the Clerk of Broward County by using the Florida Courts 
eFiling Portal this 27th day of October, 2015 . 
Is/ Thomas E. Scott 
Thomas E. Scott, Esq. 
23 
EFTA01116490

EXHIBIT A 
EFTA01116491

Filing # 31978452 E-Filed 09/11/2015 04:30:17 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, 
Plaintiff, 
vs. 
ALAN M. DERSHOWITZ, 
Defendant. 
FIRST PRIVILEGE LOG REGARDING DEFENDANT DERSHOWITZ'S FIRST SET 
OF DOCUMENT REOUESTS TO BRADLEY J. EDWARDS AND PAUL G. CASSELL 
Plaintiffs, Bradley J. Edwards and Paul G. Cassell, by and through their undersigned 
attorneys and pursuant to Rule 1.280, Florida Rules of Civil Procedure, as well as other 
applicable Rules (including Florida State 90.502 and associated Rules of Evidence) hereby file 
this First Privilege Log to Defendant, Alan M. Dershowitz's, First Set of Document Requests 
dated February 11, 2015 to as follows: 
2. 
All Documents Concerning Dershowitz's alleged "participation in Epstein's 
criminal conduct" referenced in paragraph 16 of the Complaint. 
Mr. Edwards and Professor Cassell are asserting attorney-client privilege and the work 
product doctrine to withhold (or redact) responsive documents and communications that involve 
this action and Does et al. v. United States, Case No. 9:08-cv-80736-KAM (S.D. Fla.), as well as 
civil actions (filed or contemplated) in which they represented victims of Epstein and 
Dershowitz's sexual abuse, including women (who were minors at the time of the abuse) who 
will be identified in this pleading as Jane Doe 1, Jane Doe 2, Jane Doe 3, Jane Doe 4, and Jane 
Doe 5. Because this litigation involves multiple lawsuits that have spanned more than seven 
years, Mr. Edwards and Professor Cassell will not be logging these extensive communications 
and/or documents because doing so would be unduly burdensome and because the log itself 
would, in some cases, disclose the privileged or protected information. 
Mr. Edwards and Professor Cassell are also asserting attorney-client privilege and the 
work product doctrine and the common interest privilege -- involving Mr. Edwards, Mr. Cassell, 
Jane Doe 1, Jane Doe 2, Jane Doe 3, Jane Doe 4, and Jane Doe 5 and/or one or more of the 
following individuals: (1) Jack Scarola and others at his firm involved in the rendition of legal 
EFTA01116492

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Revised Answers To Defendant Dershowitz's First Set Of Document Requests 
to Edwards and Cassell 
services; (2) David Boies and Sigrid McCawley and others at their firm involved in the rendition 
of legal services; (3) Joni Jones and Joel Ferre and others in the Utah Attorney General's Office 
involved in the rendition of legal services; (4) John Morris, General Counsel at the University of 
Utah, and others at the University of Utah involved in the rendition of legal services. Mr. 
Edwards and Professor Cassell will not be logging these extensive communications and/or 
documents because doing so would be unduly burdensome and because the log itself would, in 
some cases, disclose the privileged or protected information. 
The preparation of this privilege log has been hampered by the vagueness in the request, 
as well as by Dershowitz's failure to completely and timely produce information to which 
Edwards and Cassell are entitled which would help clarify the nature of the requests. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
Attorney-Client; Work Product 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
Attorney-Client; Work Product 
10. All Documents Concerning drafts of any declaration or affidavit of Jane Doe #3. 
2 
EFTA01116493

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Revised Answers To Defendant Dershowitz's First Set Of Document Requests 
to Edwards and Cassell 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
Attorney-Client; Work Product 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
Attorney-Client; Work Product 
14. All Documents Concerning Jane Doe #3's presence at the various locations 
named in Paragraphs 24-31 of the 2015 Jane Doe #3 Declaration on the particular dates 
and times when Dershowitz was also present. 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or Attorney-Client; Work Product 
3 
EFTA01116494

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Revised Answers To Defendant Dershowitz's First Set Of Document Requests 
to Edwards and Cassell 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
Attorney-Client; Work Product 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
Attorney-Client; Work Product 
15. All Documents Concerning whether Dershowitz was present at the various 
locations named in Paragraphs 24-31 of the 2015 Jane Doe #3 Declaration on the particular 
dates and times when Jane Doe #3 alleges to have been present. 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or Attorney-Client; Work Product 
4 
EFTA01116495

Edwards, Bradley vs. Dershowitz 
Case No.: CACE I5-000072 
Revised Answers To Defendant Dershowitz's First Set Of Document Requests 
to Edwards and Cassell 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
Attorney-Client; Work Product 
16. All statements, written or recorded, that Plaintiffs or Jane Doe #3 have provided 
to anyone that reference Dershowitz by name. 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
Attorney-Client Work Product 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
5 
EFTA01116496

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Revised Answers To Defendant Dershowitz's First Set Of Document Requests 
to Edwards and Cassell 
8/10-present 
Communications to/from either Edwards or Attorney-Client; Work Product 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
4/08-present 
Communications to/from either Edwards or Attorney-Client; Work Product 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
19. All Documents Concerning communications between You or anyone acting on 
Your behalf and anyone from, or acting on behalf of, any media outlet Concerning 
Dershowitz or this action, whether or not such communications were "on the record" or 
"off the record." 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
Attorney-Client; Work Product 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
Attorney-Client; Work Product 
6 
EFTA01116497

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Revised Answers To Defendant Dershowitz's First Set Of Document Requests 
to Edwards and Cassell 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
20. All Documents Concerning any press release Concerning this action, the Joinder 
Motion, or Dershowitz, or Jane Doe #3. 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
Attorney-Client; Work Product 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
Attorney-Client; Work Product 
7 
EFTA01116498

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15.000072 
Revised Answers To Defendant Dershowitz's First Set Of Document Requests 
to Edwards and Cassell 
21. All Documents Concerning any assertion that Dershowitz was a "co-
conspirator" with Epstein. 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
Attorney-Client; Work Product 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
Attorney-Client; Work Product 
22. All Documents Concerning any assertion that Dershowitz negotiated the NPA 
for his own benefit. 
See answer to request #2 above. 
8 
EFTA01116499

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Revised Answers To Defendant Dershowitz's First Set Of Document Requests 
to Edwards and Cassell 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
Attorney-Client; Work Product 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
Attorney-Client; Work Product 
23. All Documents Concerning any actions allegedly taken by Prince Andrew, Duke 
of York, to influence the terms of the NPA. 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
Attorney-Client; Work Product 
9 
EFTA01116500

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Revised Answers To Defendant Dershowitz's First Set Of Document Requests 
to Edwards and Cassell 
of legal services to Jane Doe #2 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
Attorney-Client; Work Product 
24. All Documents Concerning any request for the deposition of Dershowitz. 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
Attorney-Client; Work Product 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
Attorney-Client; Work Product 
10 
EFTA01116501

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Revised Answers To Defendant Dershowitz's First Set Of Document Requests 
to Edwards and Cassell 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
Attorney-Client Work Product 
25. All Documents Concerning any investigation of Dershowitz. 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
Attorney-Client; Work Product 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
Attorney-Client; Work Product 
26. All notes of any investigation of Jane Doe #3's allegations against Dershowitz. 
I1 
EFTA01116502

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Revised Answers To Defendant Dershowitz's First Set Of Document Requests 
to Edwards and Cassell 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
Attorney-Client; Work Product 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
Attorney-Client; Work Product 
29. All Documents Concerning any actual or potential book, television, movie or 
other media deals Concerning Jane Doe #3's allegations about being a sex slave. 
Preparation of this answer has been hampered by the exceedingly vague terms "potential" 
and "deal." Counsel are not aware of any actual book, television, movie or other media deals 
concerning Jane Doe #3's allegations about being a sex slave. Of course, any time anyone has 
had life experiences, it might be possible for them to write a book about it at some point in their 
life. In that light, 
12 
EFTA01116503

Edwards, Bradley vs. Dershowitz 
Case No.: CACE I5-000072 
Revised Answers To Defendant Dershowitz's First Set Of Document Requests 
to Edwards and Cassell 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
Attorney-Client; Work Product 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
Attorney-Client; Work Product 
30. All Documents Concerning Your retainer agreement with Jane Doe #3. 
See answer to request #2 above. 
13 
EFTA01116504

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Revised Answers To Defendant Dershowitz's First Set Of Document Requests 
to Edwards and Cassell 
Description 
Privileges Asserted 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
31. All Documents Concerning any investigation of Jane Doe #3. 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
Attorney-Client; Work Product 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
Attorney-Client; Work Product 
14 
EFTA01116505

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Revised Answers To Defendant Dershowitz's First Set Of Document Requests 
to Edwards and Cassell 
33. All Documents Concerning Your claim for damages in this action. 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
1/15-present 
Communications to/from 
Edwards and 
Cassell with Jack Scarola and with others 
made in furtherance of the rendition of legal 
services to Edwards and Cassell 
Attorney-Client; Work Product 
34. All Documents referred to or relied upon by Plaintiffs to prepare "Jane Doe #3 
and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in Action," which was filed in 
the Federal Action as Docket Entry #279. 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
Attorney-Client; Work Product 
3/14-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
Attorney-Client; Work Product 
15 
EFTA01116506

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Revised Answers To Defendant Dershowitz's First Set Of Document Requests 
to Edwards and Cassell 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
Attorney-Client; Work Product 
35. All Documents referred to or relied upon by Plaintiffs to prepare the Complaint 
in this action. 
See answer to request #2 above. 
Dates 
Description 
Privileges Asserted 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #1 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #1 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #2 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #2 
Attorney-Client; Work Product 
3/14-present 
Communications to/from either Edwards or 
Cassell or to/from Jane Doe #3 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #3 
Attorney-Client; Work Product 
8/10-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #4 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #4 
Attorney-Client; Work Product 
4/08-present 
Communications to/from either Edwards or 
Cassell to/from Jane Doe #5 or to/from 
others made in furtherance of the rendition 
of legal services to Jane Doe #5 
Attorney-Client; Work Product 
16 
EFTA01116507