HOUSE_OVERSIGHT_014116.jpg
2.12 MB
Extraction Summary
9
People
3
Organizations
0
Locations
2
Events
4
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / discovery dispute letter
File Size:
2.12 MB
Summary
This document is page 5 of a legal letter dated February 25, 2015, regarding discovery disputes in the case Edwards and Cassell v. Dershowitz. The text criticizes the Defendant (Dershowitz) for providing evasive, incomplete, or legally unfounded responses to interrogatories concerning his relationship with Jeffrey Epstein, statements made about Bradley Edwards, and potential witnesses. It specifically notes that Dershowitz refused to provide details based on flight logs or the deposition status of Jane Doe #3, and lists Thomas and Joanne Ashe as individuals identified by the Defendant.
People (9)
| Name | Role | Context |
|---|---|---|
| Thomas E. Scott, Jr. | Attorney (Recipient) |
Addressee of the letter regarding the Edwards and Cassell v. Dershowitz case.
|
| Jeffrey Epstein | Associate of Defendant |
Mentioned in the context of exploring the 'full extent of the personal relationship' the Defendant had with him.
|
| Alan Dershowitz | Defendant |
Referenced as 'Defendant' and 'Mr. Dershowitz'; the letter criticizes his evasive responses to interrogatories.
|
| Bradley Edwards | Plaintiff/Attorney |
Mentioned regarding alleged improper conduct contended by the Defendant.
|
| Jane Doe #3 | Victim/Witness |
Mentioned in relation to a CVRA filing and defamation actions; her deposition is a point of contention.
|
| Thomas Ashe | Witness/Associate |
Name provided by Defendant in response to Interrogatory #15.
|
| Joanne Ashe | Witness/Associate |
Name provided by Defendant in response to Interrogatory #15.
|
| Defendant's wife | Family Member |
Mentioned as a person identified in response to Interrogatory #15.
|
| Defendant's daughter | Family Member |
Mentioned as a person identified in response to Interrogatory #15.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| FLSD |
United States District Court for the Southern District of Florida (Docket location).
|
|
| SDBS |
Law firm logo at the bottom of the page (likely representing the sender).
|
|
| House Oversight Committee |
Implied by the Bates stamp 'HOUSE_OVERSIGHT_014116'.
|
Timeline (2 events)
2015-02-25
Correspondence regarding discovery disputes in Edwards and Cassell v. Dershowitz.
N/A
Relationships (4)
Text mentions exploring the 'full extent of the personal relationship he has had with Jeffrey Epstein'.
Listed in response to Interrogatory #15.
Listed in response to Interrogatory #15.
Mentions defamation action against Dershowitz and his defamation action against Jane Doe #3.
Key Quotes (4)
"explore the full extent of the personal relationship he has had with Jeffrey Epstein."Source
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Quote #1
"The response to Interrogatory #2 is a typical example of an evasive response."Source
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Quote #2
"We are entitled to Dershowitz’s sworn responses regardless of what flight logs purport to show."Source
HOUSE_OVERSIGHT_014116.jpg
Quote #3
"A question that asks for names, addresses, and telephone numbers, is not properly responded to if all we get is, “Thomas and Joanne Ashe, as well as Defendant’s wife and daughter.”"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,322 characters)
Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 33 of 34
Thomas E. Scott, Jr., Esq.
Re: Edwards and Cassell v. Dershowitz
February 25, 2015
Page 5
Re: Edwards and Cassell v. Dershowitz
February 25, 2015
Page 5
test the accuracy of those statements and to explore the full extent of the personal relationship he has had with Jeffrey Epstein.
Evasive Answers
The response to Interrogatory #2 is a typical example of an evasive response. Rather than address the substance of the questions posed, the Defendant engages in a four page diatribe about the alleged impropriety of naming him in a CVRA filing on behalf of Jane Doe #3. If that is the only improper conduct in which the Defendant contends Bradley Edwards has engaged, then the Defendant is obliged to say so.
Interrogatory #3 asks for the specific content of statements and the names of every witness to the making of the statements. We get a vague reference to “such comments” and references to the inability to “recall all of the people.” Not a single witness’ name is disclosed. If the Defendant is unable to identify a single person he is obliged to unequivocally say so.
Refusing to Provide Substantive Responses Until Jane Doe #3 is Deposed
This objection has absolutely no legal basis and fails to recognize that this is a defamation action against Dershowitz and not Mr. Dershowitz’s defamation action against Jane Doe #3. This action is absolutely not dependent on the accuracy of the statements made by Jane Doe #3, although the Plaintiffs were and are confident of the accuracy of those statements.
Objecting Because You Think We Already Know the Answers
See for example the Response to Interrogatory #13. There is no legal basis for refusing to provide information because the Defendant believes the Plaintiff already knows the answer or has alternative sources to ascertain some or all of the information requested. An admission from an opposing party carries legal significance that other evidence does not have. We are entitled to Dershowitz’s sworn responses regardless of what flight logs purport to show.
Incomplete Answers
See, for example, Interrogatory #15. A question that asks for names, addresses, and telephone numbers, is not properly responded to if all we get is, “Thomas and Joanne Ashe, as well as Defendant’s wife and daughter.”
SDBS
HOUSE_OVERSIGHT_014116
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