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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 9:08-cv-80736-KAM 
JANE DOE #1 and JANE DOE #2, 
Petitioners, 
vs. 
UNITED STATES OF AMERICA. 
Respondent. 
/ 
PLAINTIFFS RESPONSE TO MOTION FOR 
LIMITED INTERVENTION BY ALAN M. DERSHOWITZ 
COME NOW petitioners Jane Doe No. I and Jane Doe 2, as well as rnavants Jane Doe 
No. 3 and Jane Doe No. 4 ("the victims" I), to respond in opposition to Mr. Dershowitz's motion 
for limited intervention (DE 282). Dershowitz moves to intervene to strike a proffer made by 
Jane Doe No. 3 of facts that support her pending motion to join this action. The Court should 
deny the motion. Dershowitz has not established any direct interest in this Crime Victims' 
Rights Act (CVRA) action that would entitle him to intervene as of right under Fed. R. Civ. P. 
24(a). Nor has he met Rule 24(b)'s standards for discretionary intervention for four reasons: 
First Dershowitz has another forum in which to litigate and defend his reputational interests — a 
pending defamation action regarding this very case: second, Dershowitz (and other persons Jane 
Doe No. 3 specifically alleged abused her) have not availed themselves of other opportunities to 
defend their reputational interests: third. Dershowitz lacks any basis to strike allegations that are 
directly relevant to pending issues in this case; and fourth and finally, Jane Doe No. 3 attests in a 
As promised in their motion to join (DE 280). Jane Doe No. 3 and Jane Doe No. 4 do not seek to expand 
the number of pleadings filed in this case. If albwed to join this action, they would simply support the 
pleadings already being filed by Jane Doe No. I and Jane Doe No. 2 — including this opposition. 
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sworn affidavit (attached as Exhibit I) that all her allegations are true — an affidavit consistent 
with compelling corroborating evidence. 
BACKGROUND AND COURSE OF PROCEEDINGS 
Because this case has been proceeding for more than six-and-a-half years, it is useful to 
summarize some of the events pertinent to Dershowitz's intervention motion and Jane Doe No. 
3's related and pending motion for joinder. As the Court is aware, on July 7, 2008, a young 
woman identified as Jane Doe No. I filed an emergency petition to enforce her rights under the 
Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, alleging that the Government had failed 
to provide her rights with regard to a plea arrangement it was pursuing with Jeffrey Epstein. Tlx 
Court rapidly held a hearing. During that hearing, victim's counsel (having previously made a 
proffer of the relevant circumstances to Government counsel) orally moved to have Jane Doe 
No. 2 added into the case as another "victim" under the CVRA. Government counsel had no 
objection to adding her to the case, apparently believing that, in light of the sexual abuse 
perpetrated against her, she met the "victim" definition in the statute. DE 15 (Tr. July 11, 2008) 
at 14. 
The Court then instructed the parties to attempt to reach a stipulated set of facts. Over the 
next several years. the Government took conflicting positions on whether it would stipulate to 
facts provided by Jane Doc No. I and Jane Do. 2, ultimately refusing to stipulate to any facts. 
See generally DE 225-I at 2-4. Unable to obtain stipulations by the Government, in 2011 the 
victims filed a summary judgment motion alleging 53 proposed undisputed facts (DE 48), along 
with a motion to have the Court accept those facts because of the Government's failure to contest 
them (DE 49). On September 26, 2011, the Court allowed the case to move forward. DE 99. 
The Court, however, declined to accept victims' argument that it should simply accept their facts 
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because of the Government's failure to contest their facts, directing instead that discovery should 
proceed. Id. at 11. 
In light of the Court's direction, on October 11, 2011, the victims filed discovery requests 
with the Government, including requests specifically seeking information about Dershowitz, 
Prince Andrew. and others. Further efforts from the Government to avoid any discovery 
followed (see generally DE 225-I at 4-5),2 ultimately leading to a further Court ruling in June 
2013 that the Government should produce documents. DE 189. The Government then produced 
about 1.500 pages of irrelevant materials to the victims (DE 225-I at 5), while simultaneously 
submitting 14,825 pages of relevant materials under seal to the Court. The Government claimed 
that these pages were "privileged" for various reasons, attaching an abbreviated privilege log. 
Jane Doe No. 1 and Jane No. 2 objected to those claims of privilege, see generally DE 225 and 
DE 265, and also to the Government's failure to specify in its privilege log the names of all the 
persons involved in the materials (DE 265 at 1-2). These issues remain pending today.' 
In the summer of 2014, undersigned counsel for Jane Doe No. I and Jane Doe No. 2 
contacted Government counsel to request their agreement to add an additional victim to this case.: 
a young woman Jeffrey Epstein sexual abused when she was under age. On August 20, 2014. 
counsel sent a letter to U.S. Attorney Wilfredo Ferrer requesting the Government's consent to a 
stipulated motion to simply add her into the case (as had been done earlier with Jane Doe No. 2). 
Counsel attached a draft proposed motion that would have blandly recounted that she was 
similarly situated to Jane Doe No. I and Jane Doe No. 2. See Exhibit 2. The proposed motion 
2 JelTrey Epstein also attempted to block discovery of materials in this case, leading to an Eleventh Circuit 
ruling that the victims' discovery efforts were proper. Dori Epstein, 749 F.3d 999 (11th Cir. 2014). 
3 Remarkably, even though the Court directed the Government to begin producing discovery in June 
2013. the Government has yet to finish that production some 19 months later. 
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did not include any of the facts surrounding her abuse, relying instead on a stipulation to secure 
the Court's anticipated approval. 
Three months later, having received no response from the Government, victims' counsel 
sent an additional letter to Mr. Ferrer. requesting agreement to add an additional victim to the 
case — a young woman identified in current pleadings as Jane Doe No. 34: 
Dear Mr. Ferrer: 
I sent you a letter in August requesting your office's stipulation to our 
adding Jane Doe #[4] in this case. Unfortunately. we did not receive a response 
from your office. We are hopeful that your lack of a response was simple 
oversight. 
In addition to following up on the August letter, we are now requesting 
your Stipulation to the adding of Jane Doe #[3] as well. Her true name is 
[redacted].... As we expressed in our personal meetings a couple years ago. we 
don't understand the tactical decision to be adversarial to victims of known sexual 
abuse on every point in this litigation. Now that many of those issues we 
discussed have been resolved in our favor, it seems to make even more sense to 
avoid engaging in unnecessary battles that could only serve the purpose of 
delaying the victims' rights to have this case resolved on its merits. 
As I indicated in my August letter requesting your stipulation to the 
adding of Jane Doe #[4], adding Jane Doe #131 will also not delay matters, so long 
as we can stipulate to her being added. 
Without a stipulation, we foresee 
litigation over this point, which will produce nothing but additional delay — and 
further question about your Office's commitment to full protection of victims' 
rights under the Crime Victims Rights Act. 
Your office is very familiar with [redacted] and her circumstance. She 
was sexually trafficked and abused by Mr. Epstein (and others at the direction of 
Mr. Epstein) not only in this jurisdiction but throughout the United States and 
beyond. . . . 
. . . [E]ven if you were to object and prevail on the motion to add her to 
the current litigation, the only consequence would be that Ms. [name redacted] 
would then file a separate CVRA lawsuit, something she is entitled to do because 
the CVRA contains no time limit. . . .We have, throughout this case, consciously 
avoided filing anything that would unnecessarily cast your office in a bad light, 
and it is again with that in mind that we request your stipulation here. We need 
this stipulation by December 10, 2014 to avoid delaying any other aspects of this 
case. We will not file any pleadings on this subject before that date. 
4 In the letter to Mr. Ferrer. the woman identified in current court pleadings as Jane No. 3 is referred to as 
"Jane Doe No. 4." For consistency with the court pleadings, the designations in correspondence have 
been modified here - as indicated by brackets - to track the current designation in the pleadings. 
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See Exhibit 3. Weeks went by and the Government — once again -- did not respond to counsel's 
request for a stipulation. This prompted a further email from counsel to the AUSA's handling 
this matter to inquire about the status of request: 
When we spoke a few months ago, I told you that we represented [Jane 
Doe No. 3] and were considering adding her to this suit. At the time of our call 
we asked if you would agree to our adding her, and I understood that you would 
have to check with others. Consequently, I sent a couple of letters to Mr. Ferrer 
that I have attached to this email. I was hoping for a response letting me know 
that the Office would not oppose the amendments adding Doe 3 and 4... . I realize 
our 11/19 letter asked for a response by the 10th. However, I was hoping you 
could give me some indication whether we will get an answer before the 10th 
(and perhaps what that answer will be), because if there will not be an agreement 
to adding these Plaintiffs then I want to get the Motion prepared. 
See Exhibit 4; see also Exhibit 5 (short response regarding trying to get an answer). 
On December 10. 2014, despite having had four months to provide a position, the 
Government responded by email to counsel that it was seeking more time. indicating that the 
Government understood that victims' counsel might need to file a motion with the court on the 
matter immediately: "The U.S. Attorney is on travel and I do not have an answer for you on 
whether the government will agree to the addition of two new petitioners. I appreciate you not 
filing your motion until December [15], 2014. If you need to file the motion. we understand. 
Thanks." See Exhibit 6. 
Rather than file a motion immediately, victims' counsel waited and continued to press the 
Government for a stipulation. See Exhibits 7, 8, and 9. Finally, on. December 23, 2014 — more 
than four months after the initial request for a stipulated joinder into the case — the Government 
tersely indicated its objection, without indicating any reason: "Our position is that we oppose 
adding new petitioners at this stage of the litigation." See Exhibit 10. 
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Because the Government now contested the joinder motion, undersigned counsel 
prepared a more detailed pleading explaining the justification for granting the motion. One week 
after receiving the Government's objection, on December 30, 2014, Jane Doe No. 3 and Jane 
Doe No. 4 filed a motion (and later a corrected motion) seeking to join the case. DE 279 and DE 
280.5 Uncertain as to the basis for the Government's objection, the motion briefly proffered the 
circumstances of Jane Doe No. 3 and Jane Doe No. 4 that would qualify them as "victims" 
eligible to assert rights under the CVRA. See 18 U.S.C. 377I(e) ("For the purposes of this 
chapter, the term 'crime victim' means a person directly and proximately harmed as a result of 
the commission of federal offense . . .."). With regard to Jane Doe No. 3, the motion indicated 
that when she was a minor, Jeffrey Epstein had trafficked her to Dershowitz and Prince Andrew 
(among others) for sexual purposes. Jane Doe No. 3 stated that she was prepared to prove her 
proffer. See DE 280 at 3 ("If allowed to join this action, Jane Doe No. 3 would prove the 
following . ... "). The motion also provided specific reasons why Jane Doe No. 3's participation 
was relevant to the case, including the pending discovery issues regarding Dershowitz and Prince 
Andrew. DE 280 at 9-10 (explaining several reasons participation of new victims was relevant 
to existing issues). 
After the motion was filed, various news organizations published articles about it. 
Dershowitz also made numerous media statements about the filing, including calling Jane Doe 
No. 3 "a serial liar" who "has lied through her teeth about many world leaders." 
http://www.cnn.com/2015/01/06/usidershowitz-sex-allegation/. 
Dershowitz also repeatedly 
Dershowitz argues that Jane Doe No. 3 violated Local Rule 15.1 by failing to attach a proposed 
amended complaint. DE 282 at 2. But Jane Doe No. 3 was simply following the same approach that Jane 
Doe No. 2 had taken earlier, by filing a motion to join rather than a proposed amendment to pleadings. 
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called undersigned legal counsel for Jane Doe No. 3 "two sleazy, unprofessional, disbarable 
lawyers." Id. On January 5. 2015. Dershowitz filed the pending motion to intervene. DE 282. 
DISCUSSION 
Dershowitz's motion to intervene relies on Fed. R. Civ. P. 24(a) (mandatory intervention) 
and 24(b) (permissive intervention). Neither argument for intervention is well-founded. 
I. 
DERSHOWITZ'S ALLEGED "REPUTATIONAL" INTERESTS DO NOT 
SATISFY RULE 24(A)'S REQUIREMENTS FOR INTERVENTION AS OF 
RIGHT. 
Dershowitz first claims that he meets Rule 24(a)'s requirements for mandatory 
intervention. Rule 24(a) requires that the Court allow a person to intervene in a case if that 
person "claims an interest relating to the property or transaction that is the subject of that action 
and is so situated that disposing of the action may as a practical matter impair or impede the 
movant's ability to protect his interest, unless existing parties adequately represent that interest." 
Dershowitz contends he meets Rule 24(a)'s requirements because he has a "reputational" interest 
in the matter, specifically an interest in contesting Jane Doe No. 3's allegation that Jeffrey 
Epstein trafficked her to Dershowitz for sexual purposes. 
Numerous courts have declined to allow a mere "reputational" interest to justify 
mandatory intervention. For example, Calloway'. Westinghouse Elea Corp., 115 F.R.D. 73 
(M.D. Ga. 1987). denied a motion to intervene where the alleged interest was a doctor's "own 
reputation and academic credibility." Id. at 74. The court denied intervention because "a 
witness' interest in his reputation alone . . . does not constitute the required 'interest relating to 
the property or transaction which is the subject of the present action' necessary to allow 
intervention as a matter of right. To find otherwise would invite intervention every time a court 
is required to determine the credibility of a witness." Id. Similarly, Flynn'. Hubbard, 82 F.2d 
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1084, 1093 (1st Cir. 1986), affirmed the denial of the Church of Scientology's request for 
intervention in part because "the church "merely claim[ed] a generalized injury to reputation 
[that] identifies no legal detriment arising from a default judgment against Hubbard." Id. at 1093 
(Coffin. J.. concurring). See also Edmondson. Stale of Neb. ex. rel. Meyer. 383 F.2d 123, (8th 
Cir. 1967) ("The mere fact that Edmondson's reputation is thereby injured is not enough [to 
support intervention]. Edmondson's representative has pointed to no legal detriment flowing 
from this possible finding of the trial court, and we can find none."); Forsyth County. U.S. 
Army Corps of Engineers, No. 2:08-CV-0126—RWS, 2009 WL 1312511, at *2 (N.D. Ga. May 
8, 2009) (denying intervention because an "interest in protecting its reputation . . . is not direct, 
substantive, or derived from a legal right").6
The Court has previously considered — and rejected — a similar effort to intervene on a 
"reputational" claim. That claim was made by Bruce Reinhart who — like Dershowitz — had 
previously represented Jeffrey Epstein's interests in related litigation. Reinhart moved to 
intervene in this case to contest the victims' allegations that Reinhart (a former prosecutor in the 
U.S. Attorney's Office investigating Epstein) received confidential, non-public information 
about the investigation. The victims specifically alleged that Reinhart had "joined Epstein's 
payroll shortly after important decisions were made limiting Epstein's criminal liability" and that 
Reinhart had gone on to improperly represent Epstein-related witnesses in various civil suits. 
See DE 99 at 12 (discussing DE 48 at 23). Reinhart filed a sworn affidavit admitting that he had 
represented Epstein-related clients, but claiming that he did not possess any such confidential 
information. He sought to intervene to challenge the victims' arguments. 
6 Dershowitz cites dicta in Sackman 
Liggett Grp.. Inc.. 167 F.R.D. 6, 20-21 (E.D.N.Y. 1996). that a 
reputational interest can support intervention. But Sockman did not analyze the issue: rather it simply 
cited another case, Penthouse Ins?, Lid. P. Playboy Emerprise.v. Inc.. 663 F.2d 371, 373, 392 (2d Cir. 
1981), which in turn contains no analysis of the issue or any such holding. 
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After a hearing, the Court denied Reinhart's motion, finding that his interest in litigating 
the validity of the victims' allegations was too attenuated to support intervention. DE 99 at 13.7
The Court's rationale applies equally here and should lead the Court to deny Dershowitz's 
motion. Dershowitz claims that his situation is distinguishable in view of how "harmful" (DE 
282 at 6) he believes the current allegations are. But the degree of indignation at allegations is 
not a sound basis for allowing intervention. As the Court previously explained, it "cannot permit 
anyone slighted by allegations in court pleadings to intervene and conduct mini-trials to 
vindicate their reputation." DE 99 at 13. 
Dershowitz does have an alternative ground he could try to advance for intervention. As 
Jane Doc No. 3 pointed out in her motion to join the case, Dershowitz personally helped to 
negotiate the non-prosecution agreement (NPA) at issue in this case, which bars his prosecution 
in the Southern District of Florida as a "potential co-conspirator of Epstein." DE 280 at 4 
(quoting NPA at 5). The Court has previously allowed Epstein to prospectively intervene in any 
proceedings that might involve invalidating the NPA. DE 246. Dershowitz can make a similar 
motion if he identifies himself as a potential co-conspirator involved in crimes covered by the 
NPA. 
But lacking such an allegation, his existing motion does not allege any concrete 
impairment of his interests supporting mandatory intervention. 
H. 
DERSHOWITZ HAS NOT SHOWN THAT THE COURT SHOULD ALLOW 
PERMISSIVE INTERVENTION UNDER RULE 24(B). 
7 During the hearing on Reinhart's intervention motion, the Government stood silent about the accuracy 
of Reinhart's affidavit. Much later, after the Court had denied the motion, the Government admitted that 
it possessed information contradicting Reinhart's sworn affidavit. See DE 225-I at 9-10, 
43-45 ("in 
answering the victims' Requests for Admissions, the Government has admitted that it possess information 
that Reinhart learned confidential non-public information about the Epstein case and he discussed the 
Epstein case with other prosecutors."). 
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Dershowitz also contends that the Court should exercise its discretion to allow permissive 
intervention in this case under Fed. R. Civ. P. 24(b). The rule grants discretion to the court to 
allow intervention by a person who has "a claim or defense that shares with the main action a 
common question of law or fact." Fed. R. Civ. P. 24(b); accord Mt. Hawley Ins. Co. 
Sandy 
Lake Properties, Inc., 425 F.3d 1308, 1311 (1Ith Cir. 2005) (permissive intervention allowed 
only where "a claim or defense and the main action have a question of law or fact in common 
and the intervention will not unduly prejudice or delay the adjudication of the rights of the 
original parties."). A district court's ruling on such intervention is reviewed only for abuse of 
discretion. Stone'. First Union Corp.. 371 F.3d 1305, 1309 (1Ith Cir. 2004); see also AT&T 
Corp. '. Sprint Corp., 407 F.3d 560, 561-62 (2nd Cir. 2005) ("[a] denial of permissive 
intervention has virtually never been reversed" because of the considerable discretion afforded to 
district courts). 
In ruling on a motion for permissive intervention, the Court must consider all relevant 
factors, including "the nature and extent of the intervenor's interest." Percy'. Proposition 8 
Wield Proponents. 587 F.3d 947, 955 (9th Cir. 2009). Here, Dershowitz lacks a "claim or 
defense" in common with the CVRA action. Instead, Dershowitz intends to advance satellite 
arguments, including raising questions about the credibility of crime victims that the 
Government apparently does not intend to present." Allowing his intervention would thus create 
a clear risk of adding undue delay to what is already a long-running case. Cy: id. (affirming 
district court decision to deny intervention that would "consume additional time and resources of 
For example, in the media Dershowitz has called Jane Doe No. 3 — an alleged victim of international sex 
trafficking while she was a minor — "a serial perjurer, serial liar, serial prostitute." Washington Post, 
Morning 
Mix. 
http://www.wash i n gtonpost.com/new s/morn in g-m ix/wp/20 I 5/0 I /06/a lan-de rshow it z-
takes- lega l- act ion-a fier-be i n g-nam ed- w ith- prince- andrew- in-sex-ring-case/ . 
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both the Court and the parties that have a direct stake in the outcome of the proceedings"). 
Moreover, several other important factors weigh against allowing intervention. 
A. DERSHOWITZ CAN LITIGATE HIS REPUTATIONAL INTERESTS IN A 
PENDING DEFAMATION ACTION IN BROWARD COUNTY CIRCUIT 
COURT. 
In the opening paragraph of his court pleading, Dershowitz claims he has "no remedy" to 
defend his reputation. DE 81 at I. And yet, in his statements to the media, Dershowitz has made 
clear that he intends to defend his reputational interests in a pending defamation action. The 
Court need not allow duplicative litigation on the same reputational issues. 
After Jane Doe No. 3 filed her motion to intervene, Dershowitz attacked her in the media 
as a "serial perjurer." He also repeatedly named and attacked her attorneys — i.e., undersigned 
legal counsel Edwards and Cassell — branding them, among other disparaging names. "two 
sleazy. unprofessional. disbarable lawyers." Dershowitz repeated his attacks on numerous 
worldwide media outlets, saying such things as victims' counsel "are prepared to lie, cheat and 
steal. These are unethical lawyers" (CNN Program "The World Right Now with Hala Gorani." 
Jan. 5, 2015) and that counsel "willfully and deliberately made this up in order to gain a 
litigation advantage, [to] line their pockets with money" (The Last Word with 
O'Donnell — MSNBC (Jan. 8, 2015). 
Following these statements, on January 6, 2015, attorneys Edwards and Cassell. 
represented by Jack Scarola, Esq.. filed a defamation action in Broward County Circuit Court. 
See Exhibit II at ¶ 17 (alleging Dershowitz has "initiated a massive public media assault on the 
reputation and character" of undersigned counsel, by "accusing them of intentionally lying in 
their filings, of having leveled knowingly false accusations against [Dershowitz], without ever 
conducting any investigation of the credibility of the accusations"). The attorneys also served 
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discovery requests on Dershowitz, as well as a notice of deposition. Dershowitz has yet to agree 
to a deposition date. 
Faced with a defamation action against him, Dershowitz stated that he was "thrilled" by 
the development because it "gives me a chance to litigate the case. I can expose their corruption. 
I can show how fraudulent the allegations are. This makes my day?' Wall St. Journal Law Biog. 
http://blogs.wsj.comnaw/2015/0 I/06/jane-doe-lawyers-sue-dershowitz-for-defamation/ (Jan. 6, 
2015); see also UMAR News, 
(Jan. 4, 2015) 
("I just need a legal proceeding... to call witnesses ... to prove my case" (emphasis added)). 
Given that Dershowitz has the opportunity to litigate his concerns in the other case, this 
Court need not — and should not — allow permissive intervention in this one. See. e.g., Morgan'. 
Sears, Roebuck & Co., 124 F.R.D. 231 (1988) (declining intervention in one case where 
litigation on a similar issue was already underway elsewhere). Permissive intervention in this 
case would, for example. presumably lead to Dershowitz (and, in turn, undersigned legal 
counsel) seeking duplicative discovery to that which is already being sought in Broward County 
Circuit Court. One forum is enough to litigate reputations] issues. 
B. DERSHOWITZ SHOULD NOT BE ALLOWED TO INTERVENE IN THIS 
ACTION WHEN HE HAS DECLINED TO DEFEND HIS REPUTATION IN 
OTHER ACTIONS. 
Dershowitz also claims that he has not been given an opportunity to address his 
connection to Epstein's sex trafficking. DE 282-I at 3. This is untrue. Indeed. Dershowitz has 
been given (at least) three separate opportunities to provide information concerning his 
involvement in Epstein's offenses. Because Dershowitz has not availed himself of any of those 
prior opportunities, the Court should deny his motion to intervene now. 
2009 
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On about September 17, 2009, one of undersigned counsel (Brad Edwards) arranged to 
have Dershowitz served with a subpoena for deposition in connection with a civil case brought 
by one of the underage females who had sued Epstein (Doe. Epstein, No. 9:08-cv-80893-KAM 
(S.D. Fla.)). At that point. Dershowitz understood that counsel for many of Epstein's victims 
believed that mounting evidence pointed toward his role extending beyond merely being an 
attorney for Epstein. That deposition ultimately did not occur, and Dershowitz made no effort to 
provide information about his knowledge of relevant information. 
201 1 
In 2011. in the state case of Epstein'. Edwards (No. 502009CA040800XXXXMBAG 
(Palm Beach Cty. Cir. Ct.)), counsel for Edwards (Jack Scarola, Esq.) contacted Dershowitz to 
seek his cooperation in answering questions about his knowledge of Epstein's sex trafficking. 
On August 15, 2011, Dershowitz indicated that he wanted more information before would decide 
whether to cooperate: "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." See Exhibit 12 (emphasis 
added). 
On August 23, 2011, Scarola sent a letter to Dershowitz, explaining that there was no 
intent to inquire about attorney-client information, but adding: "[w]e 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 these observations.- See 
Exhibit 13. Dershowitz declined to cooperate. so on September 7, 2011. Scarola again sent a 
letter to Dershowitz, noting that while there was "no obligation" to disclose the basis for wanting 
a deposition, the reason was that "'[m]ultiple individuals have placed you in the presence of 
Jeffrey Epstein on multiple occasions and in various locations when Jeffrey Epstein was in the 
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company of underage females subsequently identified as victims of Mr. Epstein's criminal 
molestation. This inlbrmation is derived from both sworn testimony and private interviews." 
Exhibit 14. Despite providing Dershowitz with the basis for wanting his deposition, and the 
assurance that questions regarding privileged information would not be asked, Dershowitz did 
not cooperate. 
2015 
After Jane Doe No. 3 moved to intervene in this case. Dershowitz said "what they 
[victims' counsel] have done is so under-handed . . . not giv[ing] me an opportunity to disprove 
it. That's Kafkaesque." 
UMAR News, 
Following public statements such as these, on January 3, 2015, attorney Jack Scarola 
immediately sent an e-mail to Dershowitz, requesting an opportunity to take his deposition: 
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.... Thank 
you for your anticipated cooperation. 
Exhibit IS. As of the date of this filing, Dershowitz has completely ignored this request. while 
simultaneously continuing to publicly protest his inability to challenge the allegations against 
him inn legal proceeding. 
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In light of these opportunities that have been extended to Dershowitz previously to 
answer any questions about his knowledge of (and even participation in) Epstein's sex 
trafficking, his claim that he needs a forum in this Court to defend his reputation rings hollow.9
For the sake of completeness — and to show a sinister pattern — it is also worth noting that 
each of the other four individuals Jane Doe No. 3 identified by name in her motion (Jeffrey 
Epstein. Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have also all been afforded 
opportunities to explain themselves — and all four have declined to take them. 
Epstein. The Court is familiar with Jeffrey Epstein's repeated invocations of the Fifth 
Amendment when asked questions about his sexual abuse of young girls. including Jane Doe No. 
I. Jane Doe No. 2, and Jane Doe No. 3. See generally Exhibit 16 at 1-7. 
Maxwell. In 2009, undersigned counsel (Brad Edwards) served Ghislaine Maxwell with 
a subpoena for a deposition in a civil case against Jeffrey Epstein. After extensive discussion 
and coordinating a convenient time and place, as well as ultimately agreeing to a confidentiality 
agreement prepared by Maxwell's attorney, at the eleventh hour Maxwell's attorney informed 
the undersigned that Maxwell's mother was very ill and that consequently Maxwell was leaving 
the country with no plans to return. The deposition was cancelled. Yet a short time later. 
Maxwell was photographed at Chelsea Clinton's wedding in Rhinebeck, New York, confirming 
the suspicion that she was indeed still in the country and willing to say anything to avoid her 
deposition. 
9 The difficulty in scheduling this deposition also fits into a pattern for Dershowitz. In around 2005 to 
2006. Dershowitz was Jeffrey Epstein's "primary" lawyer. When the Palm Beach Police Department 
tried to interview Epstein. Dershowitz pretended that Epstein was willing to answer 
uestions. 
Dershowitz set up. then cancelled, Epstein interviews with the police "several times." See. 
Epstein, 
No. 502008CA037319XXXX MB AB. Depo. of Police Chief Michael Reiter at 80 (Palm Beach Cty. Cir. 
Ct. Nov. 23. 2009). 
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Brunel. In 2009. undersigned counsel (Brad Edwards, representing Jane Doe) served 
Jean Luc Brunel with a subpoena for a deposition before this court in Doe'. Epstein, No. 9:08-
cv-80119-KAM (S.D. Fla.). Brunel's attorney asked counsel for Jane Doe to postpone the 
scheduled deposition date. Jane Doe's counsel agreed, and then Brunel's attorney cancelled the 
rescheduled deposition date. Brunel's counsel represented that Brunel was outside the country 
and thus unavailable. But later sworn deposition testimony revealed that Brunel was actually 
inside the country at this time — indeed, he was hiding at Epstein's Palm Beach home. All this 
was brought to the Court's attention via a motion for sanctions. Dr. 483. This is just another 
example of the inner circle of Epstein's friends refusing depositions to answer questions. 
Prince Andrew. In 2011, Jack Scarola, representing Brad Edwards in the Epstein 
Edwards case, faced procedural impediments to obtaining a sworn deposition from a member of 
the British Royal family. Accordingly. he publicly invited the voluntary testimony of' Prince 
Andrew, explaining: "We would be very keen to speak with Prince Andrew. given his 
relationship with Jeffrey Epstein. . . . We have reason to believe that Prince Andrew has been in 
the company of Mr. Epstein while Mr. Epstein has been in the company of under-aged children." 
http://effiefol kerts.blogspoLcom/20 I 1/03/convicted-paedophile-jeffrey-epstei n-is.html. 
Prince 
Andrew never responded. 
Two weeks ago. after Jane Doe No. 3 and Jane Doe No. 4 moved to join in this action, a 
spokesperson for Prince Andrew denied Jane Doe No. 3's allegations. without providing any 
explanation of what the Prince was doing with this minor girl late at night in a private setting. 
Accordingly, on January 14, 2015, Jack Scarola sent Prince Andrew a certified letter requesting 
his voluntary cooperation in answering questions about his sexual interactions with Jane Doe No. 
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3. See Exhibit 17. The letter requested an opportunity to take a statement under oath from 
Prince Andrew. Federal Express has informed us that the letter has been refused by the recipient. 
In light of these avoided opportunities by Dershowitz — as well as Epstein, Maxwell, 
Brunel, and Prince Andrew — to answer questions under oath regarding Epstein's trafficking of 
young girls, there is no good reason that the Court should now allow a special, discretionary 
opportunity to intervene to respond to the allegations. 
C. DERSHOWITZ SHOULD NOT BE ALLOWED TO INTERVENE TO STRIKE 
ALLEGATIONS RELEVANT TO ISSUES PENDING BEFORE THE COURT. 
The Court should also deny Dershowitz's motion for intervention because it would be a 
pointless exercise. 
Citing Rule 12(f) of the Federal Rules of Civil Procedure. Dershowitz seeks to intervene 
to strike "immaterial, impertinent, or scandalous matter." DE 282 at 7. Dershowitz contends 
that Jane Doe No. 3's allegations regarding sexual contacts with him "have nothing to do with 
any relevant issues in this case." Id. at 3. Courts generally "disfavor the motion to strike . . ." 
Moore's Federal Practice § 12.37[1] (3d ed. 2014) (internal citation omitted). "Striking 
allegations from a pleading 'is a drastic remedy to be resorted to only when required for the 
purposes ofjustice.' and only when the allegations to be stricken have 'no possible relation to the 
controversy." Lutist Atlantis, Inc. 
Pac. Ins. Co., No. 10-61583-CI V, 2011 WI. 1584359 at •2 
(S.D. Fla. 2011) (quoting Augustusl. Bd. of Pub. Instruction. 306 F.2d 862. 868 (5th Cir.1962)). 
"If there is any doubt as to whether the allegations might be an issue in the action, courts will 
deny the motion." In re 2TheMart.com, Inc. Sec. Litig., 114 F. Supp. 2d 955, 965 (C.D. Cal. 
2000) (emphasis in original). Just as with a motion to dismiss for failure to state a claim, in 
ruling on a motion to strike "the Court must view the pleadings in a light most favorable to the 
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pleading party." Id. Any motion to strike by Dershowitz would be meritless, because Jane Doe 
No. 3's allegations are pertinent to at least eight pending issues. 
1. The Pending Motion to Intervene. 
Of course, the first reason that Jane Doe No. 3 made her allegations was to support her 
pending motion to join this action. As the Court has seen from the chronology recounted above, 
victims' counsel engaged in months of efforts to reach a stipulated motion for joinder by Jane 
Doe No. 3 and Jane Doe No. 4 that would not have required reciting any specific factual 
allegations. The U.S. Attorney's Office refused to provide any answer to that request, until 
finally tersely objecting (without providing any rationale). Once the joinder motion became 
contested, Jane Doe No. 3 then needed to proffer allegations supporting her entry into the case. 
To join this CVRA action, Jane Doe No. 3 must first show that she is the "victim" of a 
federal crime, IS U.S.C. § 377I(e) — and, further, that the crime is one that implicates persons 
covered by the NPA. Jane Doe No. 3 alleged that she was sexually abused by Jeffrey Epstein. 
But she also focused much of her joinder motion on the fact that she was the victim of a "sex 
trafficking scheme" organized by Epstein. DE 280 at 3. To prove she is a victim of sex 
trafficking in violation of 18 U.S.C. § 1591, Jane Doe must demonstrate that she was recruited, 
transported, or harbored while under the age of 18 and "cause[d] to engage in a commercial sex 
act." Accordingly, she briefly described the trafficking scheme, including identifying several 
persons to whom she was trafficked (i.e.. Dershowitz and Andrew).10 The fact that Dershowitz 
1° In his motion, Dershowitz alleges that Jane Doe No. 3 identified these two names solely to stir up 
media attention. DE 282 at 2. But Dershowitz does not address the obvious reasons for the identification 
- i.e., that he was an attorney who helped draft the NPA and that a sex act with Prince Andrew in London 
affected "foreign commerce" — part of a jurisdictional requirement of the statute. See 18 U.S.C. § 
I591(aX I). In addition, Jane Doe No. 3 has also alleged that she was trafficked to "many other powerful 
men, including politicians and powerful business executives." Ex. I at 1 58. The names of these persons 
could have been included in her pleading and would have created significantly more media attention than 
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(and Prince Andrew) engaged in a "sex act" with her is simply a required element of her proof 
that she is the victim of a sex trafficking crime. 
Sexual trafficking is not the only crime that could support Jane Doe No. 3's joinder in 
this case. There are also various federal sex offenses, such as travel with intent to engage in 
illicit sexual conduct. 18 U.S.C. § 2423(b). which Jane Doe No. Vs proffer supported. And 
perhaps most obviously, Jane Doe No. 3 was the victim of a conspiracy under 18 U.S.C. § 371. 
Dershowitz, of course, was a co-conspirator against her — thereby directly implicating the NPA. 
In her pleading. Jane Doe No. 3 alleged only the foci that a sex act took place, not the nature of 
the sex act nor any "unnecessary detail." Begay 
Public Service Co. of New Mexico, 710 
F.Supp.2d 1161 (D. N. Mex. 2010).11
2. The Pending Discovery Issues. 
Another reason Jane Doe No. 3 cited in her pleading for specifically naming Dershowitz 
(and Prince Andrew) is that the Court has before it a pending discovery dispute involving 
documents relating to these two people. See DE 280 at 10 (citing DE 225 at 7-8 (discussing DE 
48 at 16-18)). As the Court is aware, on December 1,2011, Jane Doe No. I and Jane Doe No. 2 
propounded a Request for Admission (RFA) asking the Government to admit that it possesses 
"documents, correspondence or other information reflecting contacts with the Department 
the names that she did include. If the Court would like proof of this assertion, counsel would request 
leave to provide an ex parse, sealed submission of the names of the other immediately recognizable 
persons who either observed or participated in the trafficking of Jane Doe No. 3. 
Where sexual issues are relevant to a case, they must not be stricken. See. e.g., Zdenek I. School lad. q• 
Broward County, No. 07-CV-61110, 2007 WL 4521489, at *2 (S.D. Fla. Dec. 19, 2007) ("given the 
Eleventh Circuit standards on what constitutes actionable sexual harassment, the allegations in question 
[with one exception] do not rise to the level of what is considered 'redundant, immaterial. impertinent, or 
scandalous"); Dawe I. Corr. USA, No. CIVS071790LKKEFEI, 2009 WL 2591146 at '3 (E.D. Cal. Aug. 
20, 2009) ("these statements [referring to sexual contact] are made in the . . . larger context of alleging 
that the defendants' financial misconduct stemmed in part from an intention to cover up sexual 
misconduct. As such, the court agrees that the allegations are no more scandalous than those that would 
be asserted in any cause of action relating to sexual harassment."). 
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between May 2007 and September 2008 on behalf of Jeffrey Epstein by . .. (b) Andrew Albert 
Christian Edward (a/Wa Prince Andrew, Duke of York); (c) Harvard Law Professor Alan 
Dershowitz." While the Government denied that it had documents reflecting contacts by Prince 
Andrew, it specifically admitted possessing documents reflecting contacts by Dershowitz Gov't 
Answer to RFA #6. The two victims further requested the Government admit that it possessed 
"information (including telephone logs and emails) reflecting contacts between Bruce E. 
Reinhart and persons/entities affiliated with Jeffrey Epstein (including . . . Harvard Law 
Professor Alan Dershowitz). The Government admitted this fact. Gov't Answers to RFA #I6. 
These RFA's tie into a major discovery battle that is currently before the Court. Related 
to the RFA's, on October 3. 2011. Jane Doe No. 1 and Jane Doe No. 2 propounded Request for 
Production (RFP) #8, seeking "all correspondence, documents. and other information regarding 
Epstein's lobbying efforts to persuade the Government to give him a more favorable plea 
arrangement and/or non-prosecution agreement, including efforts by . . . Andrew Albert 
Christian Edward (a/k/a Prince Andrew, Duke of York). [and] Harvard Law Professor Alan 
Dershowit7." The two victims also propounded RFP #21, requesting all documents relating to 
the NPA, including documents in the Government's possession from "defense attorneys 
representing Epstein (including . . . Alan Dershowitz)" and from "agents acting in support of 
Epstein (including .. . Andrew Albert Christian Edward (a/Wa Prince Andrew Duke of York))." 
The Government responded to these (and other RFPs) by asserting privilege over 14,825 
pages of documents that it provided to the Court. III But contrary to the Court's specific direction, 
the Government did not provide a log that "clearly identifies each document]] by author(s), 
addressee(s), recipient(s), date, and general subject matter . . . ." DE 190 at 2. Accordingly, 
11 The Government has also raised relevancy objections to producing the documents, as discussed below. 
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