1320-18.pdf

"Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-RWS"

"EDWARDS AND CASSELL FILED AND PURSUED THEIR OWN DEFAMATION ACTION AGAINST ALAN DERSHOWITZ"

"EDWARDS AND CASSELL FILED AND PURSUED THEIR OWN DEFAMATION ACTION AGAINST ALAN DERSHOWITZ"

"Sigrid McCawley (Pro Hac Vice) Boies Schiller & Flexner LLP... Attorneys for Plaintiff Virginia Giuffre"

"Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP... Attorneys for Plaintiff Virginia Giuffre"

"David Boies Boies Schiller & Flexner LLP... Attorneys for Plaintiff Virginia Giuffre"

"COMMUNICATIONS WITH ATTORNEY JACK SCAROLA ARE COVERED BY A JOINT DEFENSE AGREEMENT AND ARE THUS PROTECTED"

"Ms. Giuffre’s Deposition in the Defamation Case"

"Giuffre v. Maxwell, DE 135, 2016 WL 175918"

"Jane Doe 1 v. United States, No. 9:08-cv-80736 (S.D. Fla. July 7, 2008)"

"Does 1 and 2 v. United States, 817 F.Supp.2d 1337 (S.D. Fla. 2011)"

"Jane Doe 1 v. United States, No. 9:08-cv-80736 (S.D. Fla. July 7, 2008)"

"Plaintiff Virginia Giuffre... files this response to Defendant’s Motion... Jane Doe 3 also alleged that Defendant (i.e., Ghislaine"

"Cassell and Edwards filed a Motion Pursuant to Rule 21 for Joinder in the Action on behalf two additional victims: Jane Doe 3 and Jane Doe 4. (Jane Do"

"Cassell and Edwards filed a Motion Pursuant to Rule 21 for Joinder in the Action on behalf two additional victims: Jane Doe 3 and Jane Doe 4. (Jane Do"

"Plaintiff Virginia Giuffre, by and through her undersigned counsel... Declaration of Sigrid McCawley"

"Jane Doe 3 alleged that she had been forced by Epstein to have sexual relations with various persons"

"Alan Dershowitz – who had been one of Epstein’s defense attorneys negotiating the non-prosecution deal"

"attorney Bradley J. Edwards... filed a pro bono action... Filed on behalf of Jane Doe 1"

"On December 30, 2014, Cassell and Edwards filed a Motion Pursuant to Rule 21 for Joinder in the Action on behalf two additional victims: Jane Doe 3 an"

"non-prosecution agreement reached between the Government and Epstein"

"Dershowitz, as one of Epstein’s defense counsel, had helped negotiate the non-prosecution agreement and helped to arrange to keep it secret from the v"

"sworn testimony from one of Epstein’s household employees (Juan Alessi)"

"sworn testimony from another of Epstein’s household employees (Alfredo Rodriquez)"

"Cassell and Edwards then filed a state law defamation action against Dershowitz in Broward County, Florida"

"the Court (Marra, J.) denied Jane Doe 3 and Jane Doe 4’s motion for joinder"

"the Florida Court (Lynch, J.) ruled, denying Dershowitz’s argument that attorney-client privilege had been waived"

"Dershowitz subpoenaed Ms. Giuffre to a deposition... During the deposition, held in Fort Lauderdale, Florida, Ms. Giuffre was represented by the under"

"Dershowitz took the airwaves to attack not only Jane Doe 3, but also Cassell and Edwards. Typical of these attacks was one levelled on CNN"

"the lawsuit (Cassell and Edwards) and Dershowitz... placing at issue the truthfulness of Jane Doe No. 3’s allegations"

"Defendant does not appear to dispute that an attorney-client privilege exists with regard to the communications between Ms. Giuffre and her attorneys."

"Defendant does not appear to dispute that an attorney-client privilege exists with regard to the communications between Ms. Giuffre and her attorneys."

"Ultimately, Cassell, Edwards, and Dershowitz agreed to settle their defamation case. That settlement included both a public statement and confidential"

"Ultimately, Cassell, Edwards, and Dershowitz agreed to settle their defamation case. That settlement included both a public statement and confidential"

"Edwards and Cassell withdrew their allegations against Dershowitz in the defamation case"

"Giuffre v. Maxwell, DE 135 at 6, 2016 WL 175918 at * 6 (applying New York privilege law)"

"Edwards and Cassell filed and pursued their own defamation action against Alan Dershowitz."

"Edwards and Cassell filed and pursued their own defamation action against Alan Dershowitz."

"Defendant exclusively cites federal case law. ... Giuffre v. Maxwell, DE 135"

"Giuffre v. Maxwell, DE 135"

"information Ms. Giuffre had confidentially provided to Cassell and Edwards as her attorneys"

"information Ms. Giuffre had confidentially provided to Cassell and Edwards as her attorneys"

"Judge Lynch was the presiding judge over the Dershowitz matter"

"Ms. Giuffre’s March 5, 2011, interview with the Daily Mail"

"Ms. Giuffre’s confidential communications with her attorneys... Cassell and Edwards"

"Ms. Giuffre’s confidential communications with her attorneys... Cassell and Edwards"

"her attorneys’ personal, defamation case against Dershowitz"

"flight logs from Epstein’s jet"

"Epstein’s telephone directory"

"Ms. Giuffre’s communications were never at issue in her attorneys’ personal, defamation case against Dershowitz"