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Case 1:19-cv-03377 Document 1-13 Filed 04/16/19 Page 3 of 4

6. In fact, the purpose of the May 19th meeting with Mr. Boies was for Mr. Dershowitz to propose a method to persuade Mr. Boies that his client was mistaken about having sex with Mr. Dershowitz. Mr. Dershowitz proposed to show using his own records of travel and calendars that he could not have been present at the times alleged as he was demonstratively elsewhere. However, Mr. Dershowitz did not have the records with him at that meeting and a later meeting was scheduled for Mr. Dershowitz and his paralegal to present the records. Neither at or prior to the May 19th meeting, had Mr. Dershowitz given anything for Mr. Boies to evaluate the issue further.

7. I am informed that Mr. Dershowitz has also asserted that at a meeting on June 1, 2015, “Boies said his goal was to persuade Virginia Roberts that she was mistaken in identifying me as a person with whom she had sex.” Mr. Boies never said that in my presence, and what he did say in my presence both before and after June 1, 2015 was inconsistent with what Mr. Dershowitz ascribes to Mr. Boies. Mr. Boies said he would discuss Mr. Dershowitz presentation with his client and see if it changed the client’s mind regarding her recollections but he also said that the client strongly believed what she was saying.

8. At Mr. Dershowitz’s request I attended a meeting on July 6, 2015, at the Boies Schiller Flexner offices in New York City with David Boies and Sigrid McCawley with Mr. Dershowitz participating by Skype. The purpose of the meeting as stated at the meeting, and as stated to me by Mr. Dershowitz prior to the meeting, was to continue his efforts to persuade Mr. Boies and Ms. McCawley that Mr. Dershowitz had not been in any of the places where the client said Mr. Dershowitz had sex with her at any relevant time. The assertion by Mr. Dershowitz that Mr. Boies had, by this time, stated that he was convinced that Mr. Dershowitz had not had sex with the client or had expressed this view in my presence, is not accurate.

(a) Mr. Boies indicated at the July 6th meeting that while the information was “useful” he had open questions about what he was given, and that there were gaps in what he was being given. Moreover, there were locations where Mr. Dershowitz was alleged to have had sex with the client with respect to which Mr. Dershowitz had not yet produced sufficient documentation.

(b) The meeting ended with Mr. Dershowitz promising to produce additional materials to BSF and with the parties planning to have another meeting to review those materials.

9. Throughout this process, Mr. Dershowitz appeared determined that the outcome of those meetings would vindicate him. At various points, Mr. Boies did say that if he became convinced that his client was honestly mistaken about Mr. Dershowitz that he would convey that view to his client and that if he could not convince her, his firm would consider withdrawing from her representation. However, Mr. Boies also said that while he had an open mind on this matter, in light of the steps his firm had taken to verify the client’s accounts, and the other evidence of which he was aware, Mr. Dershowitz would have to produce compelling proof to convince him the client was mistaken. Following

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