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Case 1:19-cv-03377-LAP Document 36-4 Filed 07/03/19 Page 5 of 6

43. During the lawsuit, Mr. Edwards and I realized that Ms. Giuffre would need separate legal counsel, apart from us, when she became a witness. As a result, we requested and helped to arrange for Ms. McCawley to provide that separate representation.

44. I recall that at some point during the lawsuit, Mr. Dershowitz met with Mr. Boies in an effort to persuade Mr. Boies of his innocence of abusing Ms. Giuffre. While I was not present at that meeting, it was my understanding from later events that Mr. Boies did not find Dershowitz's claims of innocence to be persuasive, particularly given that Dershowitz repeatedly made statements that were demonstrably untrue and apparently deliberate lies.

45. Ultimately, Mr. Edwards and I agreed to settle our defamation lawsuit against Mr. Dershowitz. The terms of the settlement were confidential and nothing in this affidavit should be construed as any disclosing confidential terms of that settlement.

46. That said, I can report that, contemporaneously with settling the case, my attorney, Jack Scarola, filed a Notice of Withdrawal of Motion for Partial Summary Judgment in which he responded to a public distortion made prominently by Mr. Dershowitz. Mr. Dershowitz claimed publicly that the word "mistake," contained in a jointly agreed public statement issued by him and us at the time of settlement, showed that we had supposedly exonerated him of the charges made by our client, Ms. Giuffre. To help keep the record from being distorted, Mr. Scarola included the following accurate statement:

In the event that the noticed withdrawal is determined to be subject to Court approval, the Plaintiffs would show in support of this notice that Edwards and Cassell continue to represent Virginia Giuffre in separate pending matters, and shall continue to advance her legitimate legal interests in those matters. As expressly understood by the parties upon the execution of the Confidential Settlement Agreement and Mutual Release, Ms. Giuffre reaffirms her allegations, and the withdrawal of the referenced filings is not intended to be, and should not be construed as being, an acknowledgement by Edwards and Cassell that the allegations made by Ms. Giuffre were mistaken. Edwards and Cassell do acknowledge that the public filing in the Crime Victims' Rights Act case of their client's allegations against Defendant Dershowitz became a major distraction from the merits of the well-founded Crime Victims' Rights Act case by causing delay and, as a consequence, turned out to have been a tactical mistake. For that reason, Edwards and Cassell have chosen to withdraw the referenced filing as a condition of settlement.

Notice of Withdrawal of Motion for Partial Summary Judgment, Edwards & Cassell v. Dershowitz, No. 15-000072 (17th Judicial Circuit for Broward County, Florida) (Apr. 8, 2016).

No Extortion Plot Exists

53. I understand that Mr. Dershowitz has alleged that, in around fall 2014, Mr. Boies and Ms. McCawley were involved in an "extortion plot" to obtain money from Mr. Wexner. I am not aware of any such plot or even any suggestion of such a plot. I would also find any such suggestion entirely at odds with the professionalism that I have seen exhibited by Mr. Boies and Ms. McCawley in the course of professional dealings with them, including working closely with them as co-counsel to represent Ms. Giuffre in the complicated Giuffre v. Maxwell case. At all times they have exhibited nothing but the highest levels of professionalism and adherence to ethical requirements.

54. I expected no less since I knew that Mr. Boies had served as legal counsel in many high profile cases before I had the chance to work with him, including representing the Vice President of the United States before the United States Supreme Court in Bush v. Gore. And

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