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Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 9 of 34

Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Plaintiffs’ Motion to Compel Production of Documents

FACTUAL BACKGROUND

On December 30, 2014, Jane Doe No. 3 filed a motion (and later a corrected motion)
seeking to join a case in the U.S. District Court for the Southern District of Florida, Jane Doe
Nos. 1 and 2 v. United States, No. 9:08-cv-80736. She was represented by two attorneys who
specialize in (among other things) representing crime victims, Bradley J. Edwards and Paul G.
Cassell. The case involved an attempt to rescind a non-prosecution agreement (NPA) barring the
prosecution of Jeffrey Epstein and his criminal associates on grounds that the victims’ rights
under the Crime Victims Rights Act (CVRA) had been violated.

In her corrected motion, Docket Entry (DE) 280, Jane Doe No. 3 briefly proffered the
circumstances that would qualify her as a “victim” eligible to assert rights under the CVRA. See
18 U.S.C. 3771(e) (defining a CVRA “victim”). Jane Doe No. 3 briefly explained that when she
was a minor, Jeffrey Epstein had trafficked her to Prince Andrew and Alan Dershowitz (among
others) for sexual purposes. The motion also provided specific reasons why Jane Doe No. 3’s
participation was relevant to the case, including the pending discovery issues regarding Prince
Andrew and Dershowitz. See DE 280 at 9-10 (explaining several reasons participation of new
victims was relevant to existing issues).

After the motion was filed, Dershowitz made numerous media statements about the filing
– and defamatory statements about Edwards and Cassell. For example, on CNN on January 5,
2015, Dershowitz stated that Edwards and Cassell are “prepared to lie, cheat, and steal. These
are unethical lawyers.”

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