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Filing # 37557658 E-Filed 02/08/2016 06:20:47 PM

IN THE CIRCUIT COURT OF THE 17th
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA

CIVIL DIVISION

BRADLEY J. EDWARDS, and
PAUL G. CASSELL,

Plaintiffs,

v.

ALAN DERSHOWITZ,

Defendant.
________________________________________/

CASE NO. CACE 15-000072

RESPONSE TO DEFENDANT ALAN DERSHOWITZ’S MOTION FOR
CLARIFICATION OF CONFIDENTIALITY ORDER OR RELIEF FROM THAT ORDER

Non-Party Virginia Giuffre, by and through undersigned counsel, hereby responds to
Defendant Alan Dershowitz’s Motion for Clarification of Confidentiality Order or Relief From
that Order and states as follows:

FACTUAL BACKGROUND

On November 12, 2015 this Court issued an Order granting in part, non-party Virginia
Giuffre’s Motion to Quash the subpoena served by Defendant Alan Dershowitz and ordered
protective limits relating to her deposition. See Exhibit A, November 12, 2015 Order. On
December 18, 2016, this Court entered a Confidentiality Order holding that non-party Virginia
Giuffre’s deposition would be confidential. See Exhibit B, December 18, 2015 Confidentiality
Order. On January 16, 2016, Ms. Giuffre testified at her deposition in accordance with this
Court’s Order. The deposition was labelled confidential in accordance with this Court’s Order.
As the Court knows, Ms. Giuffre was a victim of sexual trafficking when she was a minor child.
Indeed, the U.S. Attorney’s Office for the Southern District of Florida has specifically recognized

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