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Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records
Page 4 of 20

the materials in the records would be harmful to his professional
reputation. Carnegie recited subsection vi's restriction on release of materials involving a
privacy right, but noted that “statements Tedder alleged were defamatory and damaging were
allegations in Carnegie's counterclaim for which she seeks damages.
These matters were not peripheral to the lawsuit; they were inherent to it.” Id. at 1312. Of
course, exactly the same principle applies here: sexual abuse allegations filed by attorneys
Edwards and Cassell for their client Ms. Virginia Giuffre are not peripheral to this lawsuit – they
are inherent to it.

To see how “inherent” the sexual abuse allegations are to this lawsuit, the Court need
look no further than Dershowitz's counterclaim in this case. Count I of Dershowitz's
Counterclaim (styled as “False Allegations in the Joinder Motion”) contends that Edwards and
Cassell should pay him damages because they “filed a pleading in the Federal Action titled ‘Jane
Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in Action' . . . .” Dershowitz
Counterclaim at ¶ 14. Dershowitz's Counterclaim then goes on to quote at length from the
Joinder Motion. His counterclaim contains, for example, this paragraph recounting the
allegations:

The Joinder Motion then goes on to allege – without any supporting evidence – as
follows:

One such powerful individual that Epstein forced then-minor Jane Doe #3 to
have sexual relations with was former Harvard Law Professor Alan
Dershowitz, a close friend of Epstein's and well-known criminal defense
attorney. Epstein required Jane Doe #3 to have sexual relations with
Dershowitz on numerous occasions while she was a minor, not only in Florida
but also on private planes, in New York, New Mexico, and the U.S. Virgin

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