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then. Plaintiffs alleged that Mr. Reinhart gave "at least the improper appearance" of having made 
a decision in Mr. Eptsein's favor in his own self-interest, specifically to obtain "favorable 
employment" from Mr. Epstein in the future as an attorney in private practice. Mr. Reinhart 
moved to intervene for purposes of seeking sanctions against Plaintiff for this accusation. (See 
DE 79.) 
This Court held that intervention for purposes of filing a motion for sanctions was 
denied, finding that it "cannot permit anyone slighted by allegations in court pleadings to 
intervene and conduct mini-trials to vindicate their reputation. Absent some other concrete 
interest in these proceedings, the Court does not believe that the allegations here are 
sufficiently harmful to justify permissive intervention." (DE 99 at 13 (emphasis added).) 
Apparently. counsel for Plaintiffs have taken this Court's order denying intervention as to 
Mr. Reinhart to mean that defamatory and unsupportable allegations can be made in court papers 
in this action with complete impunity. Counsel for Plaintiffs have scandalously and improperly 
published falsehoods, abusing the litigation privilege, as well as this Court's rulings. But the 
docket sheets and courtrooms of the United States District Court for the Southern District of 
Florida should not be used as a bulletin board to which irrelevant, baseless, and ill-willed 
reputational attacks can be tacked up without consequence. 
Moreover, contrary to what Plaintiffs and their counsel appear to think, this situation is 
fundamentally distinguishable from that presented by the Reinhart motion, simply by virtue of 
the harmfulness of the allegations made. Few accusations, if any, can launch such an immediate 
sensation as well as an enduring taint, notwithstanding their utter falsity and the impeccable 
reputation of the accused. And, in contrast to the Reinhart motion, which presented a potential 
intervenor who had previously had the opportunity to defend his reputation "in this docket" and 
before this Court, no such opportunity has yet been afforded Prof. Dershowitz. 
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Additionally, unlike Mr. Reinhart, who sought to add the fact-driven dynamics of Rule II 
to this case, Prof. Dershowitz seeks simply to end the potential license for character assassination 
created by the continued dwelling of those allegations in this Court's filings. If allowed to 
intervene, Prof. Dershowitz would seek to strike the outrageous allegations based on this Court's 
authority to strike material that is "scandalous, immaterial or redundant." Asay I Hallmark 
Cards, Inc., 594 F.2d 692, 697 n.2 (8th Cir. 1978) (citing Skolnick' Hallett, 350 F.2d 861 (7th 
Cir. 1975). In fact, the Court has the authority to strike such material on its own. Fed. R. Civ. P. 
12(f)(l). Alternatively, if intervention were granted, he would request that the Court grant 
intervention for purposes of submitting a request for a show cause order to Plaintiffs' counsel 
with respect to their investigation of and justification for including the allegations against Prof. 
Dershowitz in the Joinder Motion. In sum, Prof. Dershowitz submits that the remedy to be 
afforded a leading public figure deeply maligned by the under-handed techniques employed by 
Plaintiffs' counsel in this case should not be limited to wounded resignation and public denials. 
Intervention is due here. 
WHEREFORE Alan M. Dershowitz respectfully requests that the Court enter an order 
granting his limited motion to intervene for such purposes as may be appropriate including 
submitting a motion to strike the allegations made against him and requesting the issuance of a 
show cause order against Plaintiffs' counsel, and awarding such other relief that the Court deems 
just and proper under these unfortunate circumstances. 
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Respectfully submitted, 
Thomas Scott Fla. Bar No. 149100 
COLE, SCOTT & KISSANE, P.A. 
-and-
/s/ 
Kendall Coffey 
Kendall Coffey, Fla. Bar No. 259681 
Benjamin H. Brodsky, Fla. Bar No. 73748 
Counsel for Prof Alan Al. Dershowiiz 
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CERTIFICATE OF REASONABLE CONFERRAL 
WITH COUNSEL FOR THE PARTIES 
I hereby certify that counsel for the movant has made reasonable efforts to confer with all 
parties who may be affected by the relief sought in the motion—including phone calls and emails 
on today's date. Counsel for Plaintiffs have indicated that they do not oppose movant's 
intervention in the case, but that their non-opposition is "limited" and "does not extend to the 
merits of any arguments on procedural or substantive issues in the case." Counsel for Defendant 
have not responded to movant's request for consent to his proposed intervention. 
/s/ Kendall Coffey 
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CERTIFICATE OF SERVICE 
I hereby certify that a true and correct copy of the foregoing was served by Notice of 
Electronic Filing generated by CM/ECF, on this 5th day of January, 2015, on all counsel or 
parties of record on the Service List below. 
/s/ Kendall Coffey 
SERVICE LIST 
Bradley J. Edwards 
FARMER, JAFFE, WEISSING, 
EDWARDS, HSTOS & LEHRMAN, P.L. 
and 
Paul G. Cassell 
Pro Hac Vice 
S.J. Quinney College of Law at the 
University of Utah 
Attorneys for Jane Doe #I, 2, 3, and 4 
UNITED STATES ATTORNEY'S OFFICE 
500 S. Australian Ave., Suite 400 
West Palm Beach, FL 33401 
Attorneys for the Government 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-80736-CIV-MARRA 
JANE DOE #1 and JANE DOE #2, 
Petitioners, 
vs. 
UNITED STATES OF AMERICA, 
Respondent. 
DECLARATION OF ALAN M. DERSHOWITZ 
I. 
My name is Alan M. Dershowitz. I make this declaration on personal knowledge 
and pursuant to the provisions of 28 U.S.C. § 1746, and in response to a pleading in which the 
lawyers for Jane Doe #3, without benefit of an affidavit, leveled totally false and outrageous 
charges against me that have been reported around the world and threaten to damage my 
reputation irrevocably. 
2. 
Never under any circumstance have I ever had any sexual contact of any kind, 
which includes massages or any physical contact whatsoever, with Jane Doe #3, whose identity 
has been referenced by the BBC. (Her identity was disclosed because she "waived her anonymity 
in an interview with The Mail on Sunday in 2011.") 
3. 
Specifically, Jane Doe #3 has alleged that she had sex with me on Mr. Epstein's 
Carribean island. That is a deliberate lie. I was on that island only once in my life, for 
approximately one day. I was with my wife and daughter during the entire day. My wife, 
daughter and I slept overnight in the same room. We had dinner with Mr. Epstein and a 
distinguished professor from the Harvard Business School, his wife, her sister, brother-in-law, 
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their kids, and an older woman. During our entire stay on the island, we never saw any young 
woman that fit the description of Jane Doe #3. Indeed we do not recall seeing any young women 
during our entire visit to the island. The older woman showed us around the island. There is no 
conceivable possibility that I could have had any sexual encounter with Jane Doe #3 during that 
period. Her lawyers could have easily learned this by simply calling and asking me for the 
specifics. I would have then provided them with the names of unimpeachable witnesses who 
would have contradicted Jane Doe #3's false account. 
4. 
Second, Jane Doe #3 has alleged that she had sex with me in Mr. Epstein's house 
in New Mexico. That is a deliberate lie. I was in that house only once while it was under 
construction. My wife, daughter and I were driven there by a New Mexico businessman and his 
wife, whom we were visiting. Mr. Epstein was not there. Nor were there any young girls visible 
at any time. We were shown around the house for about an hour and then drove back with our 
friends. Jane Doe #3's lawyers could have easily learned this by simply calling and asking me 
for the specifics. I would have then provided them with the names of unimpeachable witnesses 
who would have contradicted Jane Doe #3's false account. 
5. 
Third, Jane Doe #3 has accused me of having sex with her on Jeffrey Epstein's 
plane. That is a deliberate lie. I was on that plane on several occassions as the manifests will 
show, but never tinder circumstances where it would have been possible to have sex with Jane 
Doe #3. On a couple of occassions I was on his plane with my wife and daughter. On another 
occasion, I was on the plane with my nephew and several older people going to see a launch at 
Cape Kennedy. On several other occassions, after the alleged events at issue, I was on the plane 
with members of Mr. Epstein's legal team flying down to perform legal services. Had his 
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lawyers called me, I would have provided them this information and told them to check the 
manifests. There were never any young girls on the plane during any of my trips. 
6. 
As to Mr. Epstein's homes in New York City and Palm Beach, I categorically 
state that I never had any sexual contact with Jane Doe #3. 
7. 
In a statement issued to the press, Jane Doe #3's lawyers, Brad Edwards and Paul 
Cassell, have falsely stated that "they tried to depose Mr. Dershowitz on these subjects. although 
he has avoided those deposition requests." By using the term "these subjects" in a statement 
about the sexual abuse charges recently made against me, these lawyers have falsely implied that 
they sought to depose me on allegations regarding my own conduct. That is a total and 
categorical lie. Several years ago they wrote, asking to depose me on Jeffrey Epstein's activities 
and whether I ever witnessed any of his alleged crimes. I recall responding that I could not testify 
as to any privileged information and that I was not a witness to any alleged crimes. They did not 
follow tip with a subpoena. Any suggestion that I refused to respond to questions about any 
allegations regarding my own alleged sexual conduct is totally and categorically false. The 
lawyers know this and yet continue to perpetuate the false impression that I was somehow given 
an opportunity to respond to these false and salacious charges against me and refused to do so. 
The written record will bear out the truth of what I am declaring and demonstrate the deliberate 
falsity of what they have suggested. 
8. 
Jane Doe #3 knows that the charges she has leveled against me are totally false 
and she has alleged them with complete knowledge of their falsity. I believe and allege that her 
lawyers, Brad Edwards and Paul Cassell, also knew or could have easily learned, that I could not 
have done and did not do any of the heinous things they allege I did in the pleading. If they had 
done any reasonable investigation of their client's false allegations, they would have found 
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absolute proof that I did not. They claim in a written statement that they "investigate" before 
filing. But they did not specifically state that they investigated this claim against me before filing 
this false and scurrilous charge. They could not have, because even the most minimal of 
investigation would have proven conclusively that I could not have had sex with their client on 
Mr. Epstein's island, in New Mexico or on the airplanes; and that I did not have sex with her in 
his New York or Palm Beach homes. They would also have learned, if they did not already 
know, that Jane Doe #3 is a serial liar, whose uncorrobrated word should never be credited. She 
has claimed to have been with former President Clinton on Mr. Epstein's island. She has 
provided specific and detailed information about Mr. Clinton's activities on the island. Yet, on 
information and belief. I have been advised that Secret Service records would confirm that 
President Clinton has never set foot on that island. It has also been reported that she told her 
father that she met Queen Elizabeth. On information and belief, a check of the records of 
Buckingham Palace would disclose that Jane Doe #3 lied to her father about such a visit. On 
information and belief, she has also told lies about many world leaders. Finally, on information 
and belief, the State Attorney in Palm Beach County dropped a case that she sought to bring 
based on an assessment by the investigating detective regarding the "victim's lack of credibility." 
A copy of the letter reflecting this decision was forwarded to central records. Her lawyers knew 
or should have known about her history of lying and her utter lack of credibility before filing an 
allegedly privileged legal statement that asserts false and defamatory information about a fellow 
lawyer based on her word alone. 
9. 
I believe and allege that Jane Doe #3's lawyers deliberately inserted this false and 
defamatory charge. which they knew or should have known to be false and defamatory, in a legal 
pleading that does not seek an evidentiary hearing or provide for any other opportunity for me to 
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respond to, rebut or disprove their knowingly false charge. They placed it in a legal proceeding, 
in a public filing, in bad faith in an efthrt to have the media report it, while they attempt to hide 
behind claims of litigation and journalistic privilege. I believe and allege that their bad faith 
purpose was to have this false charge made public, while attempting to deny me any legal 
recourse. There is no realistic possibility that this pre-New Year's filing would have been picked 
up by the media had they or someone on their behalf not deliberately alerted the media to its 
existence. 
10. 
These lawyers have now repeatedly spoken to the media about their false 
allegations against me, asserting that what they alleged against me had a "factual" basis and 
providing the BBC with a list of questions they should ask me. I answered all of their questions. 
These lawyers have studiously tried to avoid repeating the specific false charges publically, in an 
attempt to shield themselves from a defamation claim. 
I. 
Again, let me assert categorically, without reservation and with full awareness of 
the risks of perjury, that I did not ever, under any circumstances, have any sexual contact of any 
kind with Jane Doe #3. 
12. 
I declare tinder penalty of perjury that the foregoing is true and correct. 
Executed this 5th day of January. 2015, in Miami Beach, Florida. 
Alan M. Dershowitz 
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