EFTA01111095

Filing it 35180835 E-Filed 12/04/2015 03:19:02 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, 
Plaintiffs, 
vs. 
ALAN M. DERSHOWITZ, 
Defendants. 
PLAINTIFFS, BRADLEY I EDWARDS AND PAUL CASSELL'S 
MOTION FOR SUMMARY JUDGMENT ON LIABILITY 
Plaintiffs, Bradley J. Edwards, Esq. and Paul G. Cassell, Esq., by and through their 
undersigned counsel and pursuant to Rule 1.510, Florida Rules of Civil Procedure, hereby move 
for (I) partial summary judgment on the issue of the false and defamatory nature of the 
statements at issue in this defamation case, as well to the presumed damages from those 
statements, with respect to both of claims against the Defendant, Alan Dershowitz, and (2) final 
summary judgment as to Dershowitz's First Amended Counterclaim against them, and in support 
thereof state as follows: 
I. 
INTRODUCTION 
As the Court is well aware, this case involves a defamation action filed by two attorneys: 
Edwards and Cassell. They contend that the defendant, Alan Dershowitz, defamed them by 
repeatedly claiming in worldwide media broadcasts and other widely-disseminated statements 
that they had engaged in conspiring with their client to make up sexual abuse allegations against 
Dershowitz. The pleadings and discovery taken to date show that there is no genuine issue as to 
*** FILED: BROWARD COUNTY. FL HOWARD FORMAN. CLERK 12/4/2015 3:19:02 PM.**** 
EFTA01111095

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Edwards and Cassells Motion for Summary Judgment on Liability 
Page 2 of 20 
any material fact that these statements were false and defamatory. Moreover, Edwards and 
Cassell are entitled to litigation privilege for the statements they filed in court on behalf of their 
client. Accordingly, Edwards and Cassell are entitled to partial summary judgment on their 
complaint and final summary judgment on Dershowitz's First Amended Counterclaim. 
With regard to their complaint, Edwards and Cassell are entitled to partial summary 
judgment on the specific issue of the false and defamatory nature of the statements made against 
them. They have provided ample evidence that they had a powerful basis for believing their 
client's sexual abuse allegations — and were accordingly justified in filing a legal document on 
their client's behalf which contained those allegations. As a result, the undisputed record 
evidence establishes that Dershowitz waged a baseless international media assault on the 
honesty, integrity, and professionalism of Edwards and Cassell. In particular, Dershowitz went 
so far as to repeatedly accuse Edwards and Cassell of criminal misconduct in actively suborning 
perjury and fabricating the allegations of misconduct against him — acts that would warrant their 
disbarment from the legal profession. The undisputed record evidence supports the conclusion 
that Edwards and Cassell reasonably believed the sexual assault allegations against Dershowitz 
to be true, which is all that is required for the court to enter partial summary judgment here. Put 
simply, Dershowitz has made highly defamatory allegations that have no basis in fact. Indeed, 
his lawsuit was merely a desperate measure by a child abuser to avoid the stigma of the 
disclosure of his misconduct. Dershowitz's charges against Edwards and Cassell were and are 
nothing short of a far-fetched fictional fairy-tale — a preposterous claim lacking any factual 
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Edwards, Bradley vs. Dershowitz 
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Edwards and Cassells Motion for Summary Judgment on Liability 
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support. And the statements that he made attack the chosen profession of Edwards and Cassell — 
the practice of law — and therefore carry with them a presumption of damages suffered. 
Accordingly, the court should grant plaintiffs' motion for partial summary judgment on the 
issues of the false and defamatory nature of Dershowitz's statements, as well as the issue of the 
presumed damages that flowed from those statements. 
With regard to the First Amended Counterclaim, the undisputed material facts establish 
that Dershowitz's counterclaims against the Plaintiffs are barred by the absolute litigation 
privilege. 
The conduct of the attorneys Edwards and Cassell that forms the basis for 
Dershowitz's counterclaim for defamation is nothing more than filing a well-founded motion in 
pending federal court proceedings on behalf of pro bono clients. In his recent deposition, 
Dershowitz has conceded that the allegations were relevant to the federal court proceedings. As 
a result, that filing is indisputably protected by Florida's broad and absolute litigation privilege. 
Consequently, plaintiffs' motion for summary judgment as it relates to the pending counterclaim 
against them should also be granted. 
ARGUMENT 
II. 
EDWARDS AND CASSELL ARE ENTITLED TO PARTIAL SUMMARY 
JUDGMENT ON THE PENDING PRIMARY CLAIM BECAUSE THERE 
ARE NO MATERIAL DISPUTED FACTS AND THE UNDISPUTED FACTS 
ESTABLISH THAT DERSHOWITZ REPEATEDLY BROADCAST FALSE 
AND DEFAMATORY STATEMENTS ABOUT THEM. 
A. 
The Summary Judgment Standard. 
Rule 1.510(c), Florida Rules of Civil Procedure, provides that a court may enter summary 
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Edwards and Cassells Motion for Summary Judgment on Liability 
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judgment when the pleadings, depositions and factual showings reveal that there is no genuine 
issue of material fact and that the moving party is entitled to judgment as a matter of law. See 
Snyder v. Cheezem Development Corp., 373 So. 2d 719, 720 (Fla. 2d DCA 1979); Rule 1.510(c), 
Fla. R. Civ. P. Once the moving party conclusively establishes that the nonmoving party cannot 
prevail, it is incumbent on the nonmoving party to submit evidence to rebut the motion for 
summary judgment. See Holl v. Talcott, 191 So. 2d 40, 43 (Fla. 1966). It is not enough for the 
opposing party merely to assert that an issue of fact does exist. Fisel v. Wynns, 667 So.2d 761, 764 
(Fla.1996); Landers v. Milton, 370 So.2d 368, 370 (Fla.1979) (same). 
Moreover, it is well-recognized that the non-moving party faced with a summary judgment 
motion supported by appropriate proof may not rely on bare, conclusory assertions found in the 
pleadings to create an issue and thus avoid summary judgment. Instead, the party must produce 
counter-evidence establishing a genuine issue of material fact. See Bryant v. Shands Teaching 
Hospital and Clinics, Inc., 479 So.2d 165, 168 (Fla. 1st Dist. Ct. App. 1985); see also Lanzner v. 
City of North Miami Beach, 141 So.2d 626 (Fla. 3d Dist Ct. App. 1962) (recognizing that mere 
contrary allegations of complaint were not sufficient to preclude summary judgment on basis of 
facts established without dispute). Where the nonmoving party fails to present evidence rebutting 
the motion for summary judgment and there is no genuine issue of material fact, then entry of 
judgment is proper as a matter of law. See Davis v. Hathaway, 408 So. 2d 688, 689 (Fla. 2d Dist. 
Ct. App. 1982); see also Holl, 191 So. 2d at 43. 
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Edwards, Bradley vs. Dershowitz 
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Edwards and Cassel Is Motion for Summary Judgment on Liability 
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B. Dershowitz's Statements Concerning Edwards and Cassell Were False and 
Defamatory and Have Absolutely No Factual Basis. 
In support of this motion, Edwards and Cassell incorporate each of the attached Exhibits 
— notably including attached Exhibit 1, which is a summary of some of the most important 
evidence; Exhibit 2, which is a sworn affidavit from their client, Ms. Giuffre; and Exhibit 3, 
which is deposition testimony from Cassell. These extensive materials establish the considerable 
support upon which Edwards and Cassell relied to file allegations on behalf of their client, Ms. 
Nevertheless, this is not a complicated case for granting partial 
summary judgment. To the contrary, this is a simple case for partial summary judgment because 
each and every one of Dershowitz's verbal attacks against Edwards and Cassell lacks any merit 
whatsoever and is defamatory per se. 
Of course, one element that a defamation plaintiff must establish under Florida law is an 
"unprivileged publication (to a third party) of a false and defamatory statement concerning 
another." Mile Marker, Inc. v. Petersen Publishing, L.L.C., 811 So.2d 841, 845 (Fla. Dist. Ct. 
App. 4th 2002). Mother element that a defamation plaintiff must establish is damage to the 
person that ensued from the publication of the false or defamatory statement. Id. 
While Edwards and Cassell are entitled to summary judgment on other aspects of their 
claims, in this pleading it is only these two elements on which Edwards and Cassell are seeking 
summary judgment. 
As the undisputed facts establish, Cassell and Edwards received a well-founded 
allegation that Dershowitz had sexually abused Ms. Roberts. They then filed those allegations - 
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Edwards, Bradley vs. Dershowitz 
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Edwards and Cassells Motion for Summary Judgment on Liability 
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on her behalf — in a pending case where those allegations were pertinent. Dershowitz then went 
on a worldwide media rampage, claiming that the allegations were so unsupported that, by 
merely filing them in court for their client, Edwards and Cassell's demonstrated that they lacked 
fitness to engage in their chosen profession: the practice of law. Dershowitz's allegations are 
clearly and indisputably false, as established below. 
And it takes no real effort to understand that Dershowitz's statements (recounted in 
Exhibit #1 and elsewhere) are obviously and indisputably defamatory. 
Dershowitz had 
repeatedly said, for example, the Edwards and Cassell have conspired to create false charges 
against him and should be disbarred. Because these defamatory statements involve the conduct 
of two attorneys in their chosen profession, Dershowitz had committed defamation per se and 
damage is presumed. It is well settled in Florida that defamation "is actionable per se is, without 
a showing of special damage-if it imputes to another . . . conduct, characteristics, or a condition 
incompatible with the proper exercise of his lawful business, trade, profession, or office . . . ." 
Campbell v. Jacksonville Kennel Club, 66 So. 2ed 495, 497 (Fla. 1953) (citing Restatement, 
Torts, Section 570). 
Because this case involves defamation per se, "liability itself creates a conclusive legal 
presumption of loss or damage. Therefore a finding of liability for [defamation] per se, coupled 
with an express finding that the [defamation] was intended to injure plaintiff and did in fact 
cause injury, authorizes the jury to consider and assess punitive damages without any finding of 
a specific amount of compensatory damages." Lawnwood Med. Cm. Inc. v. Sadow, 43 So. 3d 
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Edwards, Bradley vs. Dershowitz 
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Edwards and Cassel Is Motion for Summary Judgment on Liability 
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710, 729 (Fla. 4th DCA 2010). Accordingly, for purposes of summary judgment, there need be 
no record evidence of any specific loss attributable to Dershowitz's tortious conduct Edwards 
and Cassell are automatically entitled to summary judgment on that aspect of their claim. 
THE RECORD EVIDENCE 
In light of the foregoing principles, three kinds of evidence are relevant to Edwards and 
Cassell's motion for partial summary judgment First, Edwards and Cassell must establish the 
absence of any dispute that their profession is the legal profession. Second, Edwards and Cassell 
must establish the absence of any dispute that Dershowitz has imputed conduct inconsistent with 
the proper exercise of their legal duties. And third, Edwards and Cassell must establish the 
absence of any dispute that Dershowitz's statements were false and defamatory. Ample and 
unrebutted evidence supports each of these three points, which is summarized in the 
accompanying video presentation (Exhibit #1), the contents of which are incorporated herein by 
reference. 
Edwards and Cassell's Chosen Profession is the Law 
Edwards and Cassell are both attorneys. In answering the complaint, Dershowitz appears 
to concede this fact See Defendant Dershowitz's Answer to Complaint at ¶¶ 2-6 (conceding 
Cassell is counsel in a Florida victims' rights case and has held other legal positions); id at ¶¶ 6-
10 (conceding the same as to Edwards). 
Mr. Edwards has established by affidavit (see Exhibit #14) that he is a named partner in 
the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman and a Board Certified Civil 
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Trial Attorney. He has tried more than 75 jury trials. He has been profiled in The Best Lawyers 
in America, recognized by the National Trial Lawyers Association's "Top 40 Under 40," and by 
the National Academy of Personal Injury Attorney's "Top 10 Under 40." In 2015 the National 
Association of Distinguished Counsel selected Mr. Edwards as one of the nation's "Top One 
Percent." Mr. Edwards is rated AV by his professional peers through the Martindale-Hubbell 0 
Peer Review Rating system. Before entering private practice, Mr. Edwards was a trial attorney 
at the Broward County State Attorney's Office, prosecuting many violent criminals. In his 
private practice, he has handled numerous cases on behalf of victims of sexual abuse and other 
crimes, including a number of pro bono cases. 
Professor Paul G. Cassell has established by affidavit (see Exhibit #15) that he is the 
Ronald N. Boyce Presidential Professor of Criminal Law at the S.J. Quinney College of Law at 
the University of Utah. He graduated from Stanford Law School, where he served as President 
of the Stanford Law Review. He clerked for then-Judge Antonin Scalia when Scalia was on the 
U.S. Court of Appeals for the D.C. Circuit and then for the Chief Justice of the United States, 
Warren Burger. Cassell then served as an Associate Deputy Attorney General with the U.S. 
Justice Department and as an Assistant U.S. Attorney for the Eastern District of Virginia. Cassell 
then joined the faculty at the College of Law, where he taught full time until he was sworn in as 
a U.S. District Court Judge for the District of Utah in 2002. In 2007, he resigned his judgeship to 
return full time to the College of Law, to teach, write, and litigate on issues relating to crime 
victims' rights. He is a co-author of the law school casebook, Victims in Criminal Procedure 
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Edwards and Cassells Motion for Summary Judgment on Liability 
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(Carolina Academic Press 3d ed. 2010). Cassell has handled pro bono numerous Crime Victims' 
Rights Act cases in district and appellate courts across the country, including a recent pro bono 
case he argued to the U.S. Supreme Court for a crime victim (Paroline v. U.S.). He is a member 
in good standing of the Utah bar and handles legal cases on a paid and pro bono basis in Utah 
and elsewhere. 
Dershowitz Has Made Defamatory Statements Alleging Conduct Incompatible with Proper 
Exercise of Edwards and Cassell's Profession. 
As established beyond dispute from reviewing the first few video clips in the attached 
presentation, Dershowitz has defamed Edwards and Cassell by repeatedly alleging "conduct, 
characteristics, or a condition incompatible with the proper exercise of [Edwards and Cassell's] 
lawful business, trade, and profession." Among other things, Dershowitz alleged that Edwards 
and Cassell failed to minimally investigate the allegations they advanced on behalf of their client 
and even that they sat down with her to contrive the allegations. The attached video clips 
provide some illustrations of the assault on the Plaintiff? professional fitness, but other 
statements Dershowitz has made in prominent national and international media including equally 
disparaging false statements: 
"[Edwards and Cassell] are lying deliberately, and I will not stop until they're 
disbarred . . . . 
New York Times — January 3, 2015 
"[Edwards and Cassell] manipulated a young, suggestible woman who was 
interested in money. 
This is a disbarable offense, and they will be 
disbarred. They will rue the day they ever made this false charge against me." 
Miami Herald — January 3, 2015 
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Edwards, Bradley vs. Dershowitz 
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"They [Edwards and Cassell] are lying deliberately, and I will not stop until 
they're disbarred," 
Boston Globe — January 4, 2015 
"If they [Cassell and Edwards] had just done an hours' worth of work, they would 
have seen she is lying through her teeth. . . . They're prepared to lie, cheat, and 
steal. These are unethical lawyers. This is Professor Cassell who shouldn't be 
allowed near a student. . . . He is essentially a crook. He is essentially somebody 
who's distorted the legal system. . . Why would he charge a person with a 
sterling reputation for 50 years on the basis of the word alone of a woman who is 
serial liar. . . If they just checked the records, they could have known from 
themselves that she was lying about me. . . . So we can prove it without any 
doubt. That's what's so absurd. That's what's so strange why two experienced 
lawyers would file this kind of statement knowing it was untrue. These [Cassell 
and Edwards] are virtually the equivalent of perjurers and they have to be taken 
out of the legal profession. They can't be allowed to have a bar card to victimize 
more innocent people." 
Halts Gorani — CNN Live (Jan. 5, 2015) 
"There was no contact, no contact whatsoever. And I will prove it conclusively, 
and then I will bring disciplinary charges and prove that these lawyers knew that 
this was false, could easily have checked, and didn't. And the end result will be 
that these lawyers will be disbarred." 
Vice News — January 5, 2015 
So they [Edwards and Cassell] and the woman got together and contrived and 
made this up. They have been talking to the woman for years. She never alleged 
me before. She never made any mention. Many of the others were mentioned 
before. 
First time my name was mentioned was a week ago. . . . I've never 
seen two lawyers like Paul Cassell and Brad Edwards engage in such unethical, 
disbarrable 
conduct. And I am accusing them on your show of unethical 
conduct." 
CNN Tonight — Jan. 5, 2015. 
"Dershowitz told Reuters Monday that he would file a defamation lawsuit based 
on the lawyers' public statements about the case. He also plans to file complaints 
with their respective states' disciplinary boards asking that they be disbarred." 
Reuters — January 7, 2015 
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Edwards and fl ccells Motion for Summary Judgment on Liability 
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They will be proved -- all of them [i.e., Cassell, Edwards, and Jane Doe No. 3] —
to be categorically lying and making up this story. And it will be a terrible thing 
for rape victims. They have put rape victims in a terrible position. Because when 
I unequivocally that they sat down and made this all up, tragically it will hurt all 
rape victims. . . The lawyers are lying through their teeth when they say I've 
refused to be deposed. . . . We [Epstein and Dershowitz] had an academic 
relationship. I was never in the presence of a single, young, under-aged woman. 
When I was with him, it was with prominent scientists, prominent academics. 
And they're just — again — lying about this 
Today Show — Jan. 22, 2015. 
"Now, your own rules of the profession, which I read coming in this morning, 
include as a professional I will always avoid personal criticism of another 
lawyer. And yet these two lawyers — Brad Edwards, from, whose partner 
Rothstein is now in jail for 50 years for a Ponzi scheme involving the same case, 
and a guy named Cassell — filed this . . . allegation again me in passing without 
doing even the most minimal of investigation, which would have proven 
conclusively that I not only didn't, but couldn't have, possibly done it." 
Speech to Dade County Bar Association, Feb. 20, 2015. 
Clearly Dershowitz has attacked Edwards and Cassell's conduct as attorneys and even their 
fitness to continue to be members of their respective bars. 
Dershowitz's Statements Were False 
The record evidence eliminates all doubt that Dershowitz's statements were false. The 
sworn affidavit of 
(identified previously as Jane Doe #3), attached and 
incorporated herein as Exhibit #2, unequivocally contradicts Alan Dershowitz's protestations of 
innocence and his malicious statements made against Edwards and Cassell. 
However, 
Dershowitz has denied the accuracy of Ms. 
charges against him. While at trial, 
Dershowitz will be proven to be a liar, at this stage summary judgment could not be granted if 
the truthfulness of Ms. Giuffre's charges were a material element of the claims on which 
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Edwards and Cassells Motion for Summary Judgment on Liability 
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Edwards and Cassell are seeking summary judgment. But while Edwards and Cassell will 
establish the truthfulness of Ms. 
charges at trial, this is not an issue that the court need 
reach to before granting the summary judgments that Edwards and Cassell seek in this pleading. 
The central issue upon which Edwards and Cassell's complaint rests is not whether Ms. 
claims were true, but instead whether Dershowitz lacked any basis whatsoever to 
support his claims that Edwards and Cassell not only knew that her statements were false but 
indeed actively participated in fabricating false statements. The record is completely devoid of 
evidence to support the existence of any such basis. 
As to the counterclaim the central issue upon which summary judgment turns is whether 
the Plaintiffs'/counter-defendants' filing of 
Giuffre's affidavit in the Crime 
Victim's Rights Act cases had any reasonable relationship to the issues in that federal 
proceeding. That issue has been expressly conceded by Dershowitz. 
MS. 
SWORN CLAIMS 
Ms. 
has submitted a sworn affidavit, not only attesting to the truthfulness of her 
allegations against Dershowitz but also about the fact that she told her lawyers about these 
claims. With regard to her allegations, Ms. 
explains that: 
Harvard law professor Alan Dershowitz was around Epstein frequently. 
Dershowitz was so comfortable with the sex that was going on and that he 
observed me in sexual activity with Epstein. 
I had sexual intercourse with 
Dershowitz at least six times. The first time was when I was about 16, early on in 
my servitude to Epstein, and it continued until I was 19. 
The first time we had sex took place in New York in Epstein's home. It 
was in Epstein's room (not the massage room). I was approximately 16 years old 
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Edwards, Bradley vs. Dershowitz 
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Edwards and Cassells Motion for Summary Judgment on Liability 
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at the time. I called Dershowitz "Alan." I knew he was a famous professor. The 
second time that I had sex with Dershowitz was at Epstein's house in Palm Beach 
I also had sex with Dershowitz at Epstein's Zorro Ranch in New Mexico 
in the massage room off of the indoor pool area, which was still being painted. 
We also had sex at Little Saint James Island in the U.S. Virgin Islands. 
Mother sexual encounter between me and Dershowitz happened on 
Epstein's airplane. Mother girl was present on the plane with us. 
I have recently seen a former Harvard law professor identified as Alan 
Dershowitz on television calling me a "liar." He is lying by denying that he had 
sex with me. That man is the same man that I had sex with at least six times. 
Since I filed my motion in the Jane Doe 1 and Jane 2 case, my credibility 
has been attacked, including attacks from Alan Dershowitz on me and on my 
attorneys who believed in me. I am telling the truth and will not let these attacks 
prevent me from exposing the truth of how I was trafficked for sex to many 
powerful people. These powerful people seem to think that they don't have to 
follow the same rules as everyone else. That is wrong. 
Sworn affidavit of 
(Exhibit #2), at ¶¶ 24-31, ¶ 71. 
The assertions of sexual abuse are more than adequately corroborated by compelling 
circumstantial evidence which is detailed at length by Cassell in his deposition. However, the 
Court (like the jury who will ultimately hear this case) need not ever decide whether Dershowitz 
sexually abused Ms. 
to rule in Edwards and Cassell's favor in this motion. Regardless of 
whether Dershowitz sexually abused Ms. 
, Edwards and Cassell clearly had a good faith 
basis for relying on the sworn representations of their client — and Dershowitz had absolutely no 
basis for repeatedly asserting on numerous worldwide media platforms that Edwards and Cassell 
got together with their client "and contrived and made this up." In addition, Edwards and Cassell 
had clearly conducted extensive investigation into the basis for Ms. 
allegations — and 
Dershowitz absolutely had no basis for repeatedly asserting that if they "had just done an hours' 
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Edwards and Cassells Motion for Summary Judgment on Liability 
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worth of work, they would have seen she is lying through her teeth." Accordingly, regardless of 
what happened between Dershowitz and Ms. 
inside of Jeffrey Epstein's mansions, on his 
jets, and on Epstein's exclusive private island, the undisputed record evidence establishes that 
Edwards and Cassell had every right following their detailed investigation to rely on Ms. 
credibility. Even more significantly, there is no record evidence contradicting the 
Plaintiffs' assertions that they did not fabricate Ms. 
sworn account of her interactions 
with the defendant Dershowitz. 
The good faith basis for Edwards and Cassell's reliance on Ms. 
allegations is 
laid out in detail by Professor Cassell in more than 50 pages of sworn testimony during his 
deposition. See Depo. of Paul Cassell (Oct. 16 & 17, 2015), at 61-117 (Exhibit #3). Some of 
Professor Cassell's significant testimony is included in the PowerPoint presentation included as 
part of the record in support of this Motion. Cassell's testimony includes the following 
information that he and Edwards relied upon in believing the truth of 
allegations: 
• 
The Palm Beach Police Department put together an 87-page report based on 
witness interviews and other evidence documenting sexual abuse of dozens of 
minor girls occurring in Epstein's Florida mansion — a location where Ms. Giuffre 
said Dershowitz had abused her (see Exhibit #4); 
• The Palm Beach police report showed the sexual abuse was occurring on a daily 
basis and, indeed, in some cases as much as two or three times in one day in 
circumstances that would have made it obvious to a visiting guest that young girls 
were coming to the home for sexual purposes; 
• 
Flight logs for Epsteiz
ivate jet showed that Epstein (accompanied by Ms. 
Maxwell) flew Ms. 
to the New York City area, a location where Ms. 
said Dershowitz had abused her (see Exhibit #5); 
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Edwards, Bradley vs. Dershowitz 
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Edwards and Cassells Motion for Summary Judgment on Liability 
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• 
Epstein's flight logs appeared to be disguising the identity of all of the passengers 
on Epstein's plane by using such notations as "one female." 
• 
A very well-regarded Florida lawyer (Bob Josefsberg), who was selected by the 
U.S. Government to represent the victims of Epstein's sexual abuse, had found 
Ms. 
to be credible and in 2009 filed a civil complaint for her alleging not 
only sex abuse by Epstein but also by "academicians" (see Exhibit #6) -- a group 
into which Dershowitz fell; 
• 
Shortly after Josefsberg filed the complaint for Ms. 
alleging 
"academicians" had abuse her, one of Josefsberg's partners, Ms. Ezell, began 
conducting depositions in Epstein-related cases asking about Dershowitz's 
awareness of sexual abuse; 
• 
Dershowitz showed up on flight logs for Epstein's private jet, including a flight 
with an (apparently young) woman named "Tatiana" who did not appear to serve 
any business purpose for Epstein; 
• 
When asked about Dershowitz, Epstein took the Fifth rather than indicate that 
Dershowitz was not involved in any criminal activities (see Exhibit #7) — a fact 
from which an obvious adverse inference could be drawn that Dershowitz was, 
indeed, involved in Epstein's crimes; 
• 
In moving down from the top of 
stein's criminal conspiracy to the next 
echelon 
three women 
— Sarah M, 
Adrianna Mucinska, and Nadia 
- all took the Fifth when asked about Dershowitz's awareness of 
Epstein's sexual abuse of underage girls or whether Dershowitz was involved in 
massages with young girls (see Exhibit #16); 
• 
Mucinska, and 
were all covered by a highly unusual non-
prosecution agreement (negotiated by, among others, Epstein defense attorney 
Alan Derhsowitz) that provided immunity from prosecution for sex trafficking not 
only to Epstein but also to his "potential co-conspirators"; 
• 
One of Epstein's household employees, Juan Alessi, said that Dershowitz visited 
Epstein's Palm Beach mansion four or five times a year, staying two or three da s 
when he went there — and Alessi was able to identify a photograph of Ms. 
as someone who was at the mansion as the same time as Dershowitz (see Exhibit 
#8); 
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• 
Another Epstein household employee, Alfredo Rodriguez, said that during the 
time of his employment (2005), Dershowitz visited Epstein's mansion at the same 
time as "massages" by underage girls were occurring in the mansion (see Exhibit 
#9); 
• 
When Rodriguez was arrested by the FBI trying to sell Epstein's "little black 
book" of contacts and phone numbers, he appeared to have circled the name of 
Alan Dershowitz as someone who had information about Epstein criminal 
activities (see Exhibit #17); 
• 
Dershowitz had indicated in 2003 that he was an extremely close friend of Epstein 
— indeed, that the only person outside his immediately family with whom he 
shared drafts of his books was Epstein; 
• 
Attempts had been made to depose Dershowitz or otherwise obtain information 
from him about his knowledge of Epstein's sexual abuse in 2009, 2011, 2013, and 
January 2015, and he had avoided all those efforts (see Exhibit #10); 
• 
Dershowitz had told the Palm Beach Police Department that he was going to 
make Epstein available to answer questions about sex abuse of underage girls, but 
then repeatedly rescheduled those meetings, ultimately never producing Epstein -
a pattern of deception that appeared to be designed to deliberately delay the 
investigation; 
• 
Dershowitz's pattern of avoiding depositions (and helping Epstein avoid 
questioning) was consistent with a pattern of other persons who were involved in 
Epstein's international sex trafficking organization evading efforts to obtain 
information from them; 
• 
Ms. 
had alleged abuse by other powerful friends of Epstein, including 
Prince Andrew, and there was a photograph showing Prince Andrew with his arm 
around Ms. Giuffre apparently taken in London (where she said the sex abuse had 
taken place) (see Exhibit #11). 
Depo. of Paul Cassell (Oct. 16 & 17, 2015), at 61-117 (Exhibit #3). 
Edwards and Cassell clearly had a powerful basis for believing their client's allegation 
that she had been sexually abused by Dershowitz, particularly where she had made this 
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Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Edwards and Cassells Motion for Summary Judgment on Liability 
Page 17 of 20 
allegation to them as far back as 2011 before they were representing her. But equally clear is the 
fact that Dershowitz engaged in intentional misconduct, because of his lack of any basis for 
attacking their professionalism. Dershowitz served as Epstein's defense counsel during the 
negotiations that lead to his guilty plea and associated non-prosecution agreement. Dershowitz 
uniquely would have been aware of the compelling evidence against Epstein — and no doubt 
would have taken a keen interest in the evidence that would have connected him with Epstein's 
crimes. Most notably, since then, Dershowitz has yet to provide any evidence that he relied upon 
in January 2015 for his claims that Edwards and Cascell had conspired with their client to make 
up allegations against him. And the idea that if Edwards and Cassell "had just done an hours' 
worth of work, they would have seen she is lying through her teeth" is laughable in light of the 
mountain of evidence supporting her allegations — as well as Dershowitz's refusal to be deposed 
regarding his knowledge of the sexual abuse of Epstein's victims and his personal inability to 
obtain exonerating evidence. 
And what does Dershowitz now claim was the support for his media tirade against these 
two capable lawyers? As the Court can readily confirm by reading even a small snippet of 
Dershowitz's deposition, it was very difficult to get him to answer questions directly and 
specifically. (As a result, Dershowitz's deposition will continue on December 9 and 10.) 
However, Dershowitz never provided any basis for his attacks on Edwards and Cassell. See 
generally Depo. of Alan Dershowitz (Oct. 15, 2015) (Exhibit #12); Depo. of Alan Dershowitz 
(Oct. 16, 2015) (Exhibit #13). 
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Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15.000072 
Edwards and Cassells Motion for Summary Judgment on Liability 
Page 18 of 20 
Moreover, some answers were successfully extracted which leaves no doubt that 
Dershowitz's defamatory statements about Edwards and Cassell were made without any basis. 
Some of these have been collected in the attached PowerPoint presentation, which shows 
intentional misconduct — specifically, a series of deliberate lies -- by Dershowitz, apparently 
designed to conceal his culpability. For example, Dershowitz claimed that the flight logs would 
"exonerate" him. But he had never even looked at them before attacking Edwards and Cassell. 
See Depo. of Alan Dershowitz at 239-42 (Oct. 16, 2015) (Exhibit #13). Dershowitz also stated 
in his media appearances that "[a]s far as the planes are concerned, there are flight manifests. 
They will prove I was never on any private airplane with any young women." Nana Gorani - 
CNN Live (Jan. 5, 2015). And yet a flight log shows Dershowitz on a flight with a young woman 
named "Tatianna." Dershowitz also was forced to admit in his deposition that whenever he met 
with Epstein, part of the Epstein "entourage" were woman whom he described as being between 
the age of 25 and 30. 
Dershowitz also stated: "I've been married to the same woman for 28 years. She goes 
with me everywhere. People know that I won't argue a case or give a speech unless my wife 
travels with me." American Lawyer, Jan. 15, 2015. And yet the available flight logs for 
Epstein's planes do not show Dershowitz's wife on a single flight while showing Dershowitz 
traveling without his wife on numerous flights — including a flight with "Tatianna" on it. 
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Edwards, Bradley vs. Dershowitz 
Case No • CACE 15-000072 
Edwards and Cassells Motion for Summary Judgment on Liability 
Page 19 of 20 
Dershowitz also stated "I have never been alone . . . with Jeffrey Epstein." UMAR 
News, Jan. 5, 2015. 
And yet (among other occasions), a flight log shows Epstein and 
Dershowitz traveling together — alone. 
Dershowitz said "I never got a massage from anybody. It's made up out of whole cloth." 
But on Local 10 News (Jan. 22, 2015), Dershowitz said he got a massage but "kept my 
underwear on." 
Based on evidence such at this, there is no doubt as the false defamatory nature of 
Dershowitz's statements against Edwards and Cassell. 
CONCLUSION AS TO PLAINTIFFS' CLAIMS 
Partial summary judgment is appropriate in this case, particularly because Florida law 
provides strong protection for a person's reputation. As the Fourth DCA has explained in 
upholding a punitive damages award in a defamation case: 
Florida's unusually high protection of personal reputation derives from the 
common consent of humankind and has ancient roots. It is highly valued by 
civilized people. Our state constitution and common law powerfully support it. 
This is a value as old as the Pentateuch and the Book of Exodus, and its command 
as clear as the Decalogue: "Thou shall not bear false witness against thy 
neighbor." The personal interest in one's own good name and reputation 
surpasses economics, business practices or money. It is a fundamental part of 
personhood, of individual standing and one's sense of worth. In short, the 
wrongdoing underlying the punitive damages in this case has Florida law's most 
severe condemnation, its highest blameworthiness, its most deserving culpability. 
For [defamation] per se, reprehensibility is at its highest. 
Lawnwood Medical Center, Inc. v. Sadow, 43 SO.3d 710, 729 (Fla. App. 4th DCA 2010). 
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Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Edwards and CasselIs Motion for Summary Judgment on Liability 
Page 20 of 20 
The record evidence and law described here provide clear support for the conclusion not 
only that Dershowitz sexually abused Ms. 
but also indisputably that Dershowitz made 
false and defamatory statements by alleging that two experienced and capable attorneys who 
thoroughly investigated and believed Ms. 
allegations in good faith should be disbarred. 
Equally obvious from the surrounding circumstances is the improper motive behind Alan 
Dershowitz's high profile media assault. In his own words: 
"There's an old saying: 
`If you have the law on your side, bang on the law. 
If you have the facts on your side, bang on the facts. 
If you have neither, bang on the table.' 
I have never believed that, but I do believe in a variation on that theme: 
If you don't have the law or legal facts on your side, argue your case in the court 
of public opinion." 
Alan M. Dershowitz, Taking the Stand My Life in the Law 
With neither law nor facts available to defend himself against charges of gross 
wrongdoing, Dershowitz followed his own prescription and took his defense to the court of 
public opinion where he had an audience willing to ignore both law and facts. The lawyer 
victims of Dershowitz's attacks remained temporarily silenced by their personal unwillingness to 
abandon their faith in the legal system or the interests of their pro bono client. They filed this 
action to protect their interests, and the record evidence now supports their entitlement to partial 
summary judgment on the issues that Dershowitz made false and defamatory statements about 
them and, in addition, that the Edwards and Cassell suffered presumed damage because these 
statements are defamatory per se. 
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