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EMERY CELLI BRINCKERHOFF & ABADY LLP
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Florida Bar that reference information that was developed during discovery in this case. In
keeping with plaintiff’s enduring practice of insisting on selective confidentiality to bolster her
own accusations while concealing evidence that undermines her claims, the materials provided to
the Post include cherry-picked and misleading characterizations of evidence that is sealed and/or
designated confidential under the protective order governing this action—to say nothing of the
fact that it is simply false. In several instances, the materials plaintiff’s counsel provided to the
Post directly reproduce exhibits that were marked confidential in this case by plaintiff, and which
plaintiff filed under seal before the district court. These disclosures violate both the spirit and
the letter of the district court’s orders, and appear calculated to hamstring Professor
Dershowitz—who respects and will abide by the court’s orders—in responding to the
accusations against him.

Most notably, the materials provided to the Washington Post repeat the
outrageous claim that [REDACTED] “came forward” and “corroborated” Ms. Giuffre’s
accusations against Dershowitz when she “testified under oath that she had been trafficked by
Mr. Epstein and had had sex with Mr. Dershowitz.” As plaintiff’s counsel are well aware, Ms.
[REDACTED] testimony is marked confidential and remains under seal; indeed, plaintiff herself
filed the relevant deposition transcript under seal before the district court. See ECF No. 701-1.
Yet the materials provided to the Washington Post repeat specific details from Ms. [REDACTED]
sealed deposition, including specific sex acts she claims occurred with specific individuals.
Plaintiff’s counsel’s selective characterization of this sealed evidence to a national newspaper is
an outrageous violation of the district court’s orders. See ECF No. 62 ¶ 4 (“CONFIDENTIAL
information shall not be disclosed or used for any purpose except the preparation and trial of this
case.”); see also, e.g., Taylor v. Teledyne Techs., Inc., 338 F. Supp. 2d 1323, 1343 (N.D. Ga.
2004) (publicly summarizing and paraphrasing confidential documents violated protective order
even without verbatim disclosure).

This is especially so given that the totality of this individual’s testimony and other
documents produced confidentially in discovery (none of which plaintiff’s counsel elected to
describe to reporters) demonstrate that her claims are utterly unworthy of belief.¹ Among other
things, in emails sent in 2016, Ms. [REDACTED] claimed that she received help from “the Russians”
and the hacker network Anonymous in responding to a hack of her email by the CIA; that Hillary
Clinton sent “Special Agents Forces Men” to “intimidate[]” and “ruff[] (sic) . . . up” her friend in
an effort to “to protect [Ms. Clinton’s] presidential campaign”; that she possessed video and
photographic evidence against both Ms. Clinton and Donald Trump that she would release to
Wikileaks and Russian media by Sunday, October 23, 2016; that she possessed video footage of
Bill Clinton, Prince Andrew, and Richard Branson having sex with her friend which was backed
up on “several USB sticks” that she had “securely sent . . . to various different locations
throughout Europe”; and that another friend had—while the two “were showering together”—
showed her physical evidence that “Donald Trump liked flicking and sucking her nipples until

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¹ As you know, on June 21, 2017, we, on behalf of Professor Dershowitz ,wrote to Judge Sweet
asking that, in the event that Ms. [REDACTED] deposition were unsealed (or its designation as
“confidential” by the parties withdrawn), the Court permit public disclosure of her emails.

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