EFTA00613391Dataset 9
2016-02-0150p13,597w
…bad faith, with the intent to profit financially and/or to injure Dershowitz. • Second, the proposed Second Amended Complaint seeks to add recently discovered facts in support of all Dershowitz's defamation claims. In particular, the proposed pleading includes new factual allegations establishing that Edwards and Cassell made the false allegations against Dershowitz in the Joinder Motion for improper financial 2 EFTA00613392 gain. First, Edwards and Cassell intended to maximize publicity for sensational allegations and secure a book, movie, and…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00613391.pdf
EFTA01196775Dataset 9
2011-09-2615p4,099w
…BY ALAN M. DERSHOWITZ Alan M. Dershowitz (herein, "Prof. Dershowitz"), a nonparty to this litigation, is the victim of scurrilous allegations made in Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in the Action (the "Joinder Motion"), filed as of record at DE 279. Having no remedy in this proceeding for the harm to his reputational interest, Prof. Dershowitz hereby seeks to intervene in this action, both as of right under Fed. R…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01196775.pdf
EFTA01184679Dataset 9
18p5,207w
…her falsehoods about Prof. Dershowitz, Jane Doe #3 struggles to justify the vicious smears as having any relevance to the issues in this proceeding. Her Response to Prof. Dershowitz's Motion for Limited Intervention (DE 291) (herein "Response") offers no legitimate reason for defaming Prof. Dershowitz in her Joinder Motion, and she has no right to continue to do so in this Court. Strikingly, the Response does not explain why Jane Doe #3, discredited and disbelieved, and with an obvious…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01184679.pdf
EFTA01136992Dataset 9
16p4,553w
…Dershowitz (herein, "Prof. Dershowitz"), Jane Doe #3 struggles to justify the vicious smears as having any relevance to the issues in this proceeding. Her Response to Prof. Dershowitz's Motion for Limited Intervention (DE 291) (herein "Response") offers no legitimate reason for defaming Prof. Dershowitz in her Joinder Motion, and she has no right to continue to do so in this Court. Strikingly, the Response does not explain why Jane Doe #3, discredited and disbelieved, and with an obvious financial…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01136992.pdf
EFTA01200036Dataset 9
2011-09-2610p2,469w
…BY ALAN M. DERSHOWITZ Alan M. Dershowitz (herein, "Prof. Dershowitz"), a nonparty to this litigation, is the victim of scurrilous allegations made in Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in the Action (the "Joinder Motion"), filed as of record at DE 279. Having no remedy in this proceeding for the harm to his reputational interest, Prof. Dershowitz hereby seeks to intervene in this action, both as of right under Fed. R…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01200036.pdf
EFTA01081376Dataset 9
2011-09-2610p2,385w
…BY ALAN M. DERSHOWITZ Alan M. Dershowitz (herein, "Prof. Dershowitz"), a nonparty to this litigation, is the victim of scurrilous allegations made in Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in the Action (the "Joinder Motion"), filed as of record at DE 279. Having no remedy in this proceeding for the harm to his reputational interest, Prof. Dershowitz hereby seeks to intervene in this action, both as of right under Fed. R…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01081376.pdf
EFTA01132961Dataset 9
2015-02-0219p6,027w
…Prof. Dershowitz, Jane Doe #3 struggles to justify her defamations as having any relevance to the issues in this proceeding. Her Response to Prof. Dershowitz's Motion for Limited Intervention (DE 291) (herein "Response") offers no legitimate reason for defaming Prof. Dershowitz in her Joinder Motion, and she has no right to continue to do so in this Court. Strikingly, the Response does not explain why Jane Doe #3, with an obvious financial motive for fabrication of salacious accusations, waited…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01132961.pdf
EFTA01099134Dataset 9
2015-03-0226p11,196w
…emphasis added). If the litigation privilege means anything, it must mean that attorneys are free to make allegation on behalf of their clients in a legal pleading — i.e., in the federal court joinder motion. Florida law has long recognized that attorneys must have immunity for statements they make in the course of judicial proceedings in order for a "free adversarial atmosphere to flourish, which atmosphere is so essential to our system of justice." Sussman v. Damian, 355 So.2d…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01099134.pdf
EFTA00097378Dataset 9
2016-04-0716p3,785w
…While they deliberately filed the motion without disclosing Ms. name, claiming the need for privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly. As the district court noted in ruling on the joinder motion, Ms. "name[d] several EFTA00097382 individuals, and she offers details about the type of sex acts performed and where they took place." Ex. L at 5. The court ruled the lurid details are unnecessary…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00097378.pdf
EFTA01081533Dataset 9
2015-04-1122p6,321w
…. . in support of their motion will be" admissible in later proceedings. Id. at 9 n.5. In short, while the Court concluded that Jane Doe 3's allegations about Dershowitz in the earlier pleading were unnecessary for that joinder motion, the Court left open whether such allegations, would be appropriate in later pleadings. Accordingly, we turn now to explaining why the victims' discovery requests about Dershowitz are appropriate. III. THE VICTIMS' DISCOVERY REQUESTS ARE REASONABLY CALCULATED TO LEAD TO THE…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01081533.pdf
EFTA00020541Dataset 8
2018-08-2729p10,996w
…dismiss the Complaint which was denied by opinion of February 29, 2016 (the "February 29 Opinion"). The primary issue presented was the truth or falsity of the January 3 statement issued Maxwell, which in turn challenged all the previous statements made to the press by and in Joinder Motion. This resulted, understandably, in a lengthy and tumultuous discovery process resulting in 18 hearings and 15 decisions. After hearing counsel, it was determined that fact discovery would be completed on July…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00020541.pdf
EFTA00603608Dataset 9
2015-01-06129p34,335w
…2008). Because Plaintiffs are public figures or limited public figures, they must also prove that Dershowitz acted with actual malice in making his statements, i.e., that Defendant "knew [the Joinder Motion] to be an entirely proper and well- founded pleading." Exhibit A, Comp. ¶ 17. 6 EFTA00603613 to assert the relevancy of information through some affirmative act for his own benefit, while at the same time denying his opponent access to the very evidence that might refute or allow defense…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00603608.pdf