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Case 9:08-cv-80736-KAM is..n.ument 291-10 Entered on FLSD 
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Edwards and Cassell 
Dershowitz 
Complaint 
14. 
In fulfillment of their obligations to two Epstein-victim clients, BRADLEY J. 
EDWARDS and PAUL G. CASSELL filed and have been aggressively prosecuting a legal 
action in the Federal District Court as previously described in Paragraph 6. 
15. 
BRADLEY J. EDWARDS and PAUL G. CASSELL on behalf of two additional 
Epstein-victim clients sought the agreement of the federal government to permit those clients to 
intervene in the already pending CVRA action. The government declined to agree to the 
intervention, thus requiring EDWARDS and CASSELL to file legal pleadings seeking a Court 
Order permitting intervention on the basis of specifically alleged factual allegations. 
16. 
Among the factual allegations made by EDWARDS and CASSELL were 
allegations that Defendant, DERSHOWITZ, had knowledge of and participation in Epstein's 
criminal conduct. 
17. 
Immediately following the filing of what the Defendant, DERSHOWITZ, knew to 
be an entirely proper and well-founded pleading, DERSHOWITZ initiated a massive public 
media assault on the reputation and character of BRADLEY J. EDWARDS and PAUL G. 
CASSELL accusing them of intentionally lying in their filing, of having leveled knowingly false 
accusations against the Defendant, DERSHOWITZ, without ever conducting any investigation of 
the credibility of the accusations, and of having acted unethically to the extent that their willful 
misconduct warranted and required disbarment. 
18. 
The details of Defendant, DERSHOWITZ'S character assassination of 
BRADLEY J. EDWARDS and PAUL G. CASSELL are typified by the contents of the CNN 
interview available to be accessed on the intemet at: 
4 
EFTA00188848

Case 9:08-cv-80736-KAM 1.,,....ument 291-10 Entered on FLSD L_ _..et 01/21/2015 Page 6 of 7 
Edwards and Cassell 
Dershowitz 
Complaint 
http://www.enn.comhoic/o1/05/europe/prince-andrew-sex-abuse-allegationsfindex.htmlit 
That interview is incorporated herein by reference. 
19. 
The same or substantially identical accusations of deliberate misconduct and 
unethical behavior warranting disbarment of the Plaintiffs were repeated by the Defendant, 
DERSHOWITZ, in multiple nationally televised interviews, in statements to and repeated by 
national and international print news sources, and various other forms nationally and 
internationally. 
20. 
The Defendant, DERSHOWITZ'S statements were false and known by him to be 
false at the time they were made. DERSHOWITZ was speaking from his Miami residence at the 
time he made the false and defamatory statements. 
21. 
Alternatively, DERSHOWITZ made the statements in reckless disregard of their 
truth or falsity, intending that the statements would provide support for DERSHOWITZ'S false 
protestations of his own innocence and direct attention away from DERSHOWITZ'S personal 
knowledge of and involvement in Epstein's criminal conduct and the subsequent cover up of that 
misconduct. 
22. 
DERSHOWITZ'S statements were and are defamatory per se directly attacking 
the fitness of the Plaintiffs to engage in the honored profession of the practice of law. 
23. 
DERSHOWITZ acted in willful, wanton, reckless, and intentional disregard of the 
rights of the Plaintiffs and under such circumstances as to warrant the imposition of punitive 
damages. 
5 
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Case 9:08-cv-80736-KAM Lnicument 291-10 Entered on FLSD 
01/21/2015 Page 7 of 7 
Edwards and Cassell 
Dershowitz 
Complaint 
24. 
As the statements made by DERSHOWITZ are defamatory per se, injury to the 
Plaintiffs is presumed as a matter of law. 
WHEREFORE, Plaintiffs demand judgment against the Defendant, ALAN M. 
DERSHOWITZ, for compensatory damages, costs, pre and post-judgment interest, and such 
other and further relief as the Court may deem appropriate under the circumstances. Plaintiffs 
reserve the right to assert claims for punitive damages upon satisfying the applicable statutory 
prerequisites. 
Plaintiffs further demand trial by jury. 
Dated this  
r 
day of January, 2015. 
Attorneys for Plaintiffs 
Scarola Barnhart & Shipley, P.A. 
6 
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I
I
 
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EXHIBIT 12 
EFTA00188852

Case 9:08-cv-80736-KAM L....cument 291-11 Entered on FLSD D. _Ket 01/21/2015 Page 2 of 2 
ALAN M. DERSHOWITZ 
1575 MASSACHUSETTS AVENUE 
CAMBRIDGE • MASSACHUSETTS • 02138 
August 15, 2011 
Jack Scarola, Esq. 
Searcy Denney Scarola Barnhart & Shipley 
Re: Edwards adv. Epstein 
Dear Mr. Scarola: 
As you may know, I was Jeffrey Epstein's attorney when he submitted his guilty plea. 
Accordingly, "any knowledge" I may have in connection with that plea is privileged information. 
If you would let me know what non-privileged information you would seek from me, I would 
then be able to decide whether to cooperate. 
Sincerely, 
Alan 
ershowitz 
EFTA00188853

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EXHIBIT 13 
EFTA00188855

Case 9:08-cv-80736-KAM DL, _anent 29SrArno 
FLSD 
DENNEY 
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August 23, 2011 
Alan M. Dershowitz, Esquire 
Re: 
Edwards adv. Epstein 
Our File No.: 291874 
Dear Mr. Dershowitz: 
at 01/21/2015 Page 2 of 2 
Oral I 411ASSPF 
• 
THE TOWLE HOUSE 
We do not intend to inquire about any privileged communications or attorney work 
product. We do, however, have reason to believe that you have personally observed 
Jeffrey Epstein in the presence of underage females, and we would like the 
opportunity to question you under oath about those observations. 
Thank you for your anticipated cooperation. 
Bradley J. Edwards, Esq. 
(850) 224-7000 
141004142-7011 
WWW.S ARCYLAW COM 
EFTA00188856

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EXHIBIT 14 
EFTA00188858

Case 9:08-cv-80736-KAM a 
Jment 29t
AtEryan 
FLSD C. 
.;et 01/21/2015 Page 2 of 2 
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VIA EMAIL AND U.S. MAIL 
dersh@law.harvard.edu 
September 7, 2011 
Alan M. Dershowitz, Esquire 
Re: 
Edwards adv. Epstein 
Our File No.: 291874 
Dear Mr. Dershowitz: 
dG adi 
DUI 'AMASS °MCA' 
While we are certainly under no obligation to disclose either the basis for our wanting 
to depose you or the subject matter of our intended inquiry, we are willing to respond 
to your request as a matter of professional courtesy. 
Multiple individuals have placed you in the presence of Jeffrey Epstein on multiple 
occasions and in various locations when Jeffrey Epstein was in the company of 
underage females subsequently identified as victims of Mr. Epstein's criminal 
molestations. This information is derived from both sworn testimony and private 
interviews. Your personal observations regarding such circumstances would clearly 
not involve any privileged communications, and it is those observations that will be 
the primary focus of our questioning. 
Please let us know when and where you will be available. 
Sincerely, 
Dictated But Not Signed By 
Jack Scarola To Expedite Delivery 
JACK SCAROLA 
JS/mep 
cc: 
Bradley J. Edwards, Esquire 
WWW.SEARCYLAWCOM 
EFTA00188859

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EXHIBIT 15 
EFTA00188861

Case 9:08-cv-80736-KAM L.,%;ument 291-14 Entered on FLSD D. xet 01(21/2015 Page 2 of 2 
Subject: 
FW: Bradley Edwards'. Epstein 
 
Original Message 
From: Jack Scarola 
Sent: January 03, 2015 6:19 PM 
To: Alan Dershowitz 
Cc: Paul Cassell; William B. King; Brad Edwards; Mary E. Pirrotta 
Subject: Bradley Edwards I. Epstein 
Dear Mr. Dershowitz: 
Statements attributed to you in the public media express a willingness, indeed a strong 
desire, to submit to questioning under oath regarding your alleged knowledge of Jeffrey 
Epstein's extensive abuse of underage females as well as your alleged personal participation 
in those activities. As I am sure you will recall, our efforts to arrange such a deposition 
previously were unsuccessful, so we welcome your change of heart. Perhaps a convenient time 
would be in connection with your scheduled appearance in Miami on January 19. I assume a 
subpoena will not be necessary since the deposition will be taken pursuant to your request, 
but please let us know promptly if that assumption is inaccurate. Also, note that the 
deposition will be video recorded. 
Kindly bring with you all documentary and electronic evidence which you believe tends to 
refute the factual allegations made concerning you in the recent CVRA proceeding as well as 
passport pages reflecting your travels during the past ten years and copies of all 
photographs taken while you were a traveling companion or house guest of Jeffrey Epstein's. 
Thank you for your anticipated cooperation. 
Sincerely, 
Jack Scarola 
****4 
******* 
#4.44,**4.4*****ii#4.***************************.$4
, titialMfi*********4..*******## 
Privileged and Confidential Electronic communication is not a secure mode of communication 
and may be accessed by unauthorized persons. This communication originates from the law firm 
of Searcy Denney Scarola Barnhart & Shipley, P.A. and is protected under the Electronic 
Communication Privacy Act, 18 U.S.C. 52510-2521. The information contained in this E-mail 
message is privileged and confidential under Fla. R. Jud. Admin. 2.420 and information 
intended only for the use of the individual(s) named above. If the reader of this message is 
not the intended recipient, you are hereby notified that any dissemination, distribution, or 
copy of this communication is strictly prohibited. Personal messages express views solely of 
the sender and shall not be attributed to the law firm. If you received this communication in 
error, please notify the sender immediately by e-mail or by telephone at (800) 780-8607 and 
destroy all copies of the original message. Thank you. 
l***************iiki*ii**************44,404***************************************4.0#4,*****.li 
EFTA00188862

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40 
EXHIBIT 16 
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EXHIBIT C 
Epstein vs. Edwards 
Undisputed Statement of Facts 
EFTA00188865

Case 9:08-cv-807aUty:.3a3sEmt
2Doc T6Q 
3erFledn047(Jts/T'IooPage-Zoygg15 Page 3 of 
IN THE CIRCUIT COURT OF THE 15TH 
JUDICIAL CIRCUIT IN AND FOR PALM 
BEACH COUNTY, FLORIDA 
Case No.: 50 2009 CA 0408003OOOCMBAG 
JEFFREY EPSTEIN, 
Plaintiff, 
vs. 
SCOTT ROTHSTEIN, individually, and 
BRADLEY J. EDWARDS, individually, 
Defendants, 
STATEMENT OF UNDISPUTED FACTS 
Defendant Bradley J. Edwards, Esq., offers the following specific facts as the undisputed 
material facts in this case. Each of the following facts is numbered separately and individually to 
facilitate Epstein's required compliance with Fla. R. Civ. P. 1.510(c) ("The adverse party shall identify 
. . . any summary judgment evidence on which the adverse party relies."). 
Sexual Abuse of Children By Epstein 
1. 
Defendant Epstein has a sexual preference for young children. Deposition of Jeffrey 
Epstein, Mar. 17, 2010, at 110 (hereinafter "Epstein Depo.") (Deposition Attachment #1).1
2. 
Epstein repeatedly sexually assaulted more than forty (40) young girls on numerous 
When questioned about this subject at his deposition, Epstein invoked his Fifth Amendment right to remain 
silent rather than make an incriminating admission. Accordingly, Edwards is entitled to the adverse inference 
against Epstein that, had Epstein answered, the answer would have been unfavorable to him. "[I]t is well-settled 
that the Fifth Amendment does not forbid adverse inferences against parties
 civil actions when they refuse to 
testify in response to mobative evidence offered against them." Baxter 
Pahnigiano, 425 U.S. 308, 318 
(1976); accord Vasquez'. Slate, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical 
and utilitarian. A party may not trample upon the rights of others nd then escape the consequences by invoking 
a constitutional privilege — at least not in a civil setting." Fraser.. Security and Inv. Corp., 615 So.2d 841, 842 
(Fla. App. 1993). 
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occasions between 2002 and 2005 in his mansion in West Palm Beach, Florida. These sexual assaults 
included vaginal penetration. Epstein abused many of the girls dozens if not hundreds of times. 
Epstein Depo. at 109 ("Q: How many times have you engaged in oral sex with females under the age 
of 1ST' A: [Invocation of the Fifth Amendment]); Deposition of Jane Doe, September 24, 2009 and 
continued March 11, 2010, a15 
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