Case 1:15-cv-07433-RWS Document 117 Filed 04/21/16 Page 1 of 2
Case 1:15-cv-07433-RWS Document 117 Filed 04/21/16 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
X 15-cv-07433-RWS
Declaration Of Laura A. Menninger In Opposition to
Renewed Pro Ha Vice Motions of Messrs. Cassell and Edwards
I, Laura A. Menninger, declare as follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant
Ghislaine Maxwell ("Maxwell") in this action. I respectfully submit this declaration in
support of Defendant's Opposition to Plaintiff's Motion for Forensic Examination.
2. Attached as Exhibit A are true and correct copies of correspondence between
counsel for Ms. Maxwell and counsel for Ms. Giuffre on April 21, 2016.
3. Attached as Exhibit B is a true and correct copy of "Plaintiffs and Non-Party
Virginia Giuffre's Notice Regarding the Parties Joint Stipulation of Dismissal," filed on
April 11, 2016, in Cassell and Edwards v. Dershowiiz, In and for the Seventeenth Judicial
District, Broward County, Florida.
EFTA00592788
Case 1:15-cv-07433-RWS Document 117 Filed 04/21/16 Page 2 of 2
By: Is/Laura A. Menninger
Laura A. Menninger
CERTIFICATE OF SERVICE
I certify that on April 21, 2016, I electronically served this Declaration Of Laura A.
Menninger In Opposition to Renewed Pro Hac Vice Motions of Messrs. Cassell anEdward via
ECF on the following:
Sigrid S. McCawley
BOIES, SCHILLER & FLEXNER, LLP
401 East Las Olas Boulevard, Ste. 1200
Ft. Lauderdale, FL 33301
smccawley®bsflIp.com
/s/ Laura A Menninger
Laura A. Menninger
2
EFTA00592789
Case 1:15-cv-07433-RWS Document 117-1 Filed 04/21/16 Page 1 of 13
Thursday, April 21, 2016 at 11:22:05 PM Eastern Daylight Time
Subject: Giuffre v Maxwell -[Supplemental Materials]
Date: Thursday, April 21, 2016 at 5:44:02 PM Eastern Daylight Time
From: Laura Menninger
To: Sigrid S. McCawley
CC: Jeff Pagliuca
Sigrid
We did not receive any supplemental materials in support of Mr Cassell's pro hac application.
If materials were submitted to the Court, please provide them to us immediately.
-Laura
Page 1 of 13
EFTA00592790
Case 1:15-cv-07433-RWS Document 117-1 Filed 04/21/16 Page 2 of 13
Thursday, April 21, 2016 at 11:22:05 PM Eastern Daylight Time
Subject: RE: Giuffre v Maxwell -[Supplemental Materials]
Date: Thursday, April 21, 2016 at 5:44:56 PM Eastern Daylight Time
From: Sigrid McCawley
To: Laura Menninger
CC: Jeff Pagliuca
My staff is scanning them to you now. You should have them momentarily.
Sigrid S. McCawley
Partner
BOIES, SCHILLER & FLEXNER LLP
401 East Las Olas Blvd., Suite 1200
Fort Lauderdale, FL 33301
Phone: 954-356-0011 ext. 4223
Fax: 954-356-0022
http:/ p.com
Original Message
From: Laura Menninger Imailto:Imenning hmflaw.com
Sent: Thursday, April 21, 2016 5:44 PM
To: Sigrid McCawley
Cc: Jeff Pagliuca
Subject: Giuffre v Maxwell -(Supplemental Materials]
Sigrid
We did not receive any supplemental materials in support of Mr Cassell's pro hac application.
If materials were submitted to the Court, please provide them to us immediately.
-Laura
The information contained in this electronic message is confidential information intended only for the use of the
named recipient(s) and may contain information that, among other protections, is the subject of attorney-client
privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic
message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you
are hereby notified that any dissemination, distribution, copying or other use of this communication is strictly
prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the
sender by replying to this electronic message and then deleting this electronic message from your computer. (v.1]
Page 2 of 13
EFTA00592791
Case 1:15-cv-07433-RWS Document 117-1 Filed 04/21/16 Page 3 of 13
Thursday, April 21, 2016 at 11:22:05 PM Eastern Daylight Time
Subject: Re: Giuffre v Maxwell -(Supplemental Materials)
Date: Thursday, April 21, 2016 at 5:48:25 PM Eastern Daylight Time
From: Laura Menninger
To: Sigrid McCawley
CC: Jeff Pagliuca
How and when were they provided to the Court?
On Apr 21, 2016, at 5:45 PM, Sigrid McCawley <[email protected]> wrote:
My staff is scanning them to you now. You should have them momentarily.
Sigrid S. McCawley
Partner
BOIES, SCHILLER & FLEXNER LLP
401 East Las Olas Blvd., Suite 1200
Fort Lauderdale, FL 33301
Phone: 954-356-0011 ext. 4223
Fax: 954-356-0022
http://www.bsfllp.com
Original Message
From: Laura Menninger (mailto:Imenningg hmflaw.coml
Sent: Thursday, April 21, 2016 5:44 PM
To: Sigrid McCawley
Cc: Jeff Pagliuca
Subject: Giuffre v Maxwell -(Supplemental Materials]
Sigrid
We did not receive any supplemental materials in support of Mr Cassell's pro hac application.
If materials were submitted to the Court, please provide them to us immediately.
-Laura
The information contained in this electronic message is confidential information intended only for the use of the
named recipient(s) and may contain information that, among other protections, is the subject of attorney-client
privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic
message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you
are hereby notified that any dissemination, distribution, copying or other use of this communication is strictly
prohibited and no privilege is waived. If you have received this communication in error, please immediately notify
the sender by replying to this electronic message and then deleting this electronic message from your computer.
[v.1]
Page 3 of 13
EFTA00592792
Case 1:15-cv-07433-RWS Document 117-1 Filed 04/21/16 Page 4 of 13
Thursday, April 21, 2016 at 11:22:05 PM Eastern Daylight Time
Subject: Supplemental Materials
Date: Thursday, April 21, 2016 at 5:49:24 PM Eastern Daylight Time
From: Meredith Schultz
To: Laura Menninger, Jeff Pagliuca
CC: Sigrid McCawley
Laura/Jeff,
Please see the attached.
Thanks,
Meredith
The information contained in this electronic message is confidential inforrnabon intended only for the use of the named reament(s) and may contain information that.
among other protections. is the subject of attorney-client pnvilege. attorney work product or exempt from disclosure under app cable law. if the reader of this electronic
message is not the named recipient. or the employee or agent responsible to deliver it to the named recipient. you are hereby notified that any dissemination.
distnbution. copying or other use of this communication is stnctly prohibited and no pnvilege is waived. If you have received this communicatco in error. please
immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. (v.1)
Page 4 of 13
EFTA00592793
Case 1:15-cv-07433-RWS Document 117-1 Filed 04/21/16 Page 5 of 13
Thursday, April 21, 2016 at 11:22:05 PM Eastern Daylight Time
Subject: Re: Supplemental Materials
Date: Thursday, April 21, 2016 at 5:52:27 PM Eastern Daylight Time
From: Jeff Pagliuca
To: Meredith Schultz
CC: Laura Menninger, Sigrid McCawley
I would like to know when these were filed with the court.
Jeff
On Apr 21, 2016, at 5:49 PM, Meredith Schultz <[email protected]> wrote:
Laura/Jeff,
Please see the attached.
Thanks,
Meredith
The information contained in this electronic message is confidential inforrnabon intended only for the use of the named recip:ent(s) and may contain
information that. among other protections. is the subject of attorney-client pnvilege, attorney work product or exempt from disclosure under
applicable law. If the reader of this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named
recipient. you are hereby notified that any dissemination, distribution. copying or other use of this communication is strictly prohibited and no
privilege is waived If you have received this communication in error, please immediately nobly the sender by replying to this electronic message
and then deleting this electronic message from your computer. Ev.11
<Pages from GM Scanned fax.pdf>
Page S of 13
EFTA00592794
Case 1:15-cv-07433-RWS Document 117-1 Filed 04/21/16 Page 6 of 13
Thursday, April 21,2016 at 11:22:05 PM Eastern Daylight Time
Subject: RE: Giuffre v Maxwell -(Supplemental Materials]
Date: Thursday, April 21, 2016 at 6:02:10 PM Eastern Daylight Time
From: Sigrid McCawley
To: Laura Menninger
CC: Jeff Pagliuca
I am in the NY office and we gave it to staff for faxing and then scanning. I believe it was about an hour ago. I
just got the scanned copy and sent it to you. We are also planning to file similar papers on behalf of Brad
Edwards which we will be sending shortly but it is not complete.
Sigrid S. McCawley
Partricr
1OIES, SCHILLER & FLEXNER LL'
401 East Las Olas Blvd., Suite 1200
Fort Lauderdale, FL 33301
Phone: 954-356-0011 ext. 4223
Fax: 954-356-0022
http://www.bsflIp.com
From: Laura Menninger [mailto:[email protected]]
Sent Thursday, April 21, 2016 5:48 PM
To: Sigrid McCawley
Cc: Jeff Pagliuca
Subject: Re: Giuffre v Maxwell -[Supplemental Materials]
How and when were they provided to the Court?
> On Apr 21, 2016, at 5:45 PM, Sigrid McCawley <[email protected]> wrote:
> My staff is scanning them to you now. You should have them momentarily.
> Sigrid S. McCawley
> Partner
> BOIES, SCHILLER & FLEXNER LLP
> 401 East Las Olas Blvd., Suite 1200
> Fort Lauderdale, FL 33301
> Phone: 954-356-0011 ext. 4223
> Fax: 954-356-0022
> httplAvww.bsflIp.com
> Original Message
> From: Laura Menninger fmailto:Imenninger(ahmflawcom]
> Sent: Thursday, April 21, 2016 5:44 PM
> To: Sigrid McCawley
> Cc: Jeff Pagliuca
> Subject: Giuffre v Maxwell -[Supplemental Materials]
> Sigrid
Page 6 of 13
EFTA00592795
Case 1:15-cv-07433-RWS Document 117-1 Filed 04/21/16 Page 7 of 13
> We did not receive any supplemental materials in support of Mr Cassell's pro hac application.
> If materials were submitted to the Court, please provide them to us immediately.
> -Laura
> The information contained in this electronic message is confidential information intended only for the
use of the named recipient(s) and may contain information that, among other protections, is the subject
of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If
the reader of this electronic message is not the named recipient, or the employee or agent responsible to
deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying
or other use of this communication is strictly prohibited and no privilege is waived. If you have
received this communication in error, please immediately notify the sender by replying to this
electronic message and then deleting this electronic message from your computer. [v.1]
The information contained in this electronic message is confidential inforrnabon intended only for the use of the named recipent(s) and may contain information that.
among other protections. is the subject of attorney-client pnvilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic
message is not the named recipient. or the employee or agent responsible to deliver it to the named recipient, you an hereby notified that any dissemination.
distribution, copying or other use of this communication is stnctly prohibited and no pnvilege is waived. If you have received this communicatm in error. please
immediately notify the sender by replying to this electronte message and then deleting his electron message from your computer. (v.1)
Page 7 of 13
EFTA00592796
Case 1:15-cv-07433-RWS Document 117-1 Filed 04/21/16 Page 8 of 13
Thursday, April 21,2016 at 11:22:05 PM Eastern Daylight Time
Subject: Re: Giuffre v Maxwell -(Supplemental Materials]
Date: Thursday, April 21, 2016 at 6:57:29 PM Eastern Daylight Time
From: Jeff Pagliuca
To: Sigrid McCawley
CC: Laura Menninger
I am assuming you have a time stamp on your fax. It was not part of what you sent to me. Please give me an exact
time stamp on the filing.
Jeff
On Apr 21, 2016, at 6:02 PM, Sigrid McCawley <[email protected]> wrote:
I am in the NY office and we gave it to staff for faxing and then scanning. I believe it was about
an hour ago. I just got the scanned copy and sent it to you. We are also planning to file similar
papers on behalf of Brad Edwards which we will be sending shortly but it is not complete.
Sigrid S. McCawley
Partner
1OIES, SCHILLER & FLEXNER LL '
401 East Las Olas Blvd., Suite 1200
Fort Lauderdale, FL 33301
Phone: 954-356-0011 ext. 4223
Fax: 954-356-0022
http://www.bsfllp.com
From: Laura Menninger [mailto:[email protected]]
Sent: Thursday, April 21, 2016 5:48 PM
To: Sigrid McCawley
Cc: Jeff Pagliuca
Subject: Re: Giuffre v Maxwell -[Supplemental Materials]
How and when were they provided to the Court?
> On Apr 21, 2016, at 5:45 PM, Sigrid McCawley <[email protected]> wrote:
> My staff is scanning them to you now. You should have them momentarily.
> Sigrid S. McCawley
> Partner
> BOIES, SCHILLER & FLEXNER LLP
> 401 East Las Olas Blvd., Suite 1200
> Fort Lauderdale, FL 33301
> Phone: 954-356-0011 ext. 4223
> Fax: 954-356-0022
> mIp:/Avww.bsflIp.com
Page 8 of 13
EFTA00592797
Case 1:15-cv-07433-RWS Document 117-1 Filed 04/21/16 Page 9 of 13
> Original Message
> From: Laura Menninger [mailto:[email protected]]
> Sent: Thursday, April 21, 2016 5:44 PM
> To: Sigrid McCawley
> Cc: Jeff Pagliuca
> Subject: Giuffre v Maxwell -[Supplemental Materials]
> Sigrid
> We did not receive any supplemental materials in support of Mr Cassell's pro hac
application.
> If materials were submitted to the Court, please provide them to us immediately.
> -Laura
> The information contained in this electronic message is confidential information
intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product
or exempt from disclosure under applicable law. If the reader of this electronic message is
not the named recipient, or the employee or agent responsible to deliver it to the named
recipient, you are hereby notified that any dissemination, distribution, copying or other use
of this communication is strictly prohibited and no privilege is waived. If you have
received this communication in error, please immediately notify the sender by replying to
this electronic message and then deleting this electronic message from your computer. [v.1]
The information contained in this electronic message is confidential Information intended only for the use of the named recipent(s) and may contain
information that. among other protections. is the subject of attomey-client pnvilege, attorney work product or exempt from disclosure under
applicable law. If the reader of this electronic message is not the named recipient, or the employee or agent response/ate to deliver it to the named
recipient. you are hereby notified that any dissemination, distribution. copying or other use of this come unicatcn is strictly prohibited and no
privilege is waived. If you have received this communication in error, please immediately nobly the sender by replying to this electronic message
and then deleting this electronic message from your computer. Iv.1]
Page 9 of 13
EFTA00592798
Case 1:15-cv-07433-RWS Document 117-1 Filed 04/21/16 Page 10 of 13
Thursday, April 21, 2016 at 11:22:05 PM Eastern Daylight Time
Subject: Re: Giuffre v Maxwell -]Supplemental Materials]
Date: Thursday, April 21, 2016 at 8:17:47 PM Eastern Daylight Time
From: Jeff Pagliuca
To: Sigrid McCawley
CC: Laura Menninger
I have not received a response to this request. "I believe it was about an hour ago" is not an acceptable response.
Given that the court converted this issue into a motion hearing it was inappropriate for you to respond by letter and
fax to the judge. I assume it is because you did not want the adverse party in the Dershowitz matter to have these
statements available for review.
Again, please provide me with a fax confirmation sheet that discloses when this communication was sent to Judge
Sweet.
Jeff
On Apr 21, 2016, at 6:57 PM, Jeff Pagliuca <jpsgliucaahmfiaw.com> wrote:
I am assuming you have a time stamp on your fax. It was not part of what you sent to me. Please give
me an exact time stamp on the filing.
Jeff
On Apr 21, 2016, at 6:02 PM, Sigrid McCawley <[email protected]> wrote:
I am in the NY office and we gave it to staff for faxing and then scanning. I believe
it was about an hour ago. I just got the scanned copy and sent it to you. We are
also planning to file similar papers on behalf of Brad Edwards which we will be
sending shortly but it is not complete.
Sigrid S. McCawley
Partner
MIES, SCHILLER & FLEXNER LIT
401 East Las Olas Blvd., Suite 1200
Fort Lauderdale, FL 33301
Phone: 954-356-0011 ext. 4223
Fax: 954-356-0022
http://www.bsillp.com
From: Laura Menninger [mailtodmenningerahmflaw.com]
Sent: Thursday, April 21, 2016 5:48 PM
To: Sigrid McCawley
Cc: Jeff Pagliuca
Subject: Re: Giuffre v Maxwell -[Supplemental Materials]
How and when were they provided to the Court?
Page 10 of 13
EFTA00592799
Case 1:15-cv-07433-RWS Document 117-1 Filed 04/21/16 Page 11 of 13
> On Apr 21, 2016, at 5:45 PM, Sigrid McCawley
<SmccawleyOBSFLLP.com> wrote:
> My staff is scanning them to you now. You should have them momentarily.
> Sigrid S. McCawley
> Partner
> BOIES, SCHILLER & FLEXNER LLP
> 401 East Las Olas Blvd., Suite 1200
> Fort Lauderdale, FL 33301
> Phone: 954-356-0011 ext. 4223
> Fax: 954-356-0022
> sIp://www.bsfflp.com
> Original Message
> From: Laura Menninger [mailto:Imenninger(ahmflaw.com]
> Sent: Thursday, April 21, 2016 5:44 PM
> To: Sigrid McCawley
> Cc: Jeff Pagliuca
> Subject: Giuffre v Maxwell -[Supplemental Materials]
> Sigrid
> We did not receive any supplemental materials in support of Mr Cassell's
pro hac application.
> If materials were submitted to the Court, please provide them to us
immediately.
> -Laura
> The information contained in this electronic message is confidential
information intended only for the use of the named recipient(s) and may
contain information that, among other protections, is the subject of attorney-
client privilege, attorney work product or exempt from disclosure under
applicable law. If the reader of this electronic message is not the named
recipient, or the employee or agent responsible to deliver it to the named
recipient, you are hereby notified that any dissemination, distribution, copying
or other use of this communication is strictly prohibited and no privilege is
waived. If you have received this communication in error, please immediately
notify the sender by replying to this electronic message and then deleting this
electronic message from your computer. [v.1]
Page 11 of 13
EFTA00592800
Case 1:15-cv-07433-RWS Document 117-1 Filed 04/21/16 Page 12 of 13
Thursday, April 21, 2016 at 11:22:05 PM Eastern Daylight Time
The information contained in this electronic message is confidential information intended only for the use of the named
recipient(s) and may contain informabon that. among other protections. is the subject of attorney-client pdvdege. attorney work
product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named reap:eat. or
the employee or agent responsible to deliver it to the named recipient. you are hereby noticed that any clisseminatm.
distnbution. copying or other use of this communication is strictly prohibited and no pnvilege is waived. If you have recewed
this communication in env,. please immediately nobly the sender by replying to this electronic message and then deleting this
electronic message from your computer. kill
Subject: FW: fax transmittal
Date: Thursday, April 21, 2016 at 8:39:56 PM Eastern Daylight Time
From: Jeff Pagliuca
To: Laura Menninger
From: Meredith Schultz <[email protected]>
Date: Thursday, April 21, 2016 at 6:07 PM
To: Jeffrey Pagliuca <jugliucaPhmflaw.com>
Cc: Sigrid McCawley CmccawleyBBSFLLP.com>
Subject: fax transmittal
Jeff,
We sent the fax to the Court at approximately 4:30. We were going to serve it to you at that time, but it did
not get out until later due to a clerical error. You have my apologies for that — it was not intentional.
My fax transmittal sheet is in error, and says that the fax was sent at 3:31. Again, this is in error. All of the fax
machines in my firm's New York office are off by approximately 1 hour. It appears that all the fax machines
were not set reset last month with the "spring forward" time change. Judge Sweet's fax receipt (if set
correctly) should say the exact time it was received, and it should reflect that it was transmitted around 4:30
instead of around 3:30.
I looked at three fax machines in the office from which the fax could have been sent. At present, I don't know
what machine it was sent from. However, the time displayed by all three fax machines are off by about an
hour, but all differ a few minutes in what time they read. Because of the discrepancies among the machines,
and because we don't know at present which fax machine it was sent from, I cannot give you a precise time
of transmittal at the time. However, all three machines read approximately one hour earlier than it actually is.
The staff has been made aware of this issue (as you can see from the attached). Also, earlier, we took a
picture of one of the fax machines with a time-stamp of the photograph, showing the discrepancy — that
picture is also attached.
Thanks,
Meredith
Meredith L. Schultz
BOLES, SCHILLER & FLEXNER LLP
401 East Las Olas Blvd., Suite 1200
Fort Lauderdale, FL 33301
Page 12 of 13
EFTA00592801
Case 1:15-cv-07433-RWS Document 117-1 Filed 04/21/16 Page 13 of 13
Phone: 954-356-0011 ext. 4204
Fax: 954-356-0022
slp://www.bsfllp.com
The information contained in this electronic message is confidential informabon intended only for the use of the named recaptent(s) and may contain information that.
among other protections. is the subject of attorney-client pnvilege. attorney work product or exempt from disclosure under appecable law. tithe reader of this electronic
message is not the named recipient. or the employee or agent responsible to deliver it to the named recipient. you age hereby notified that any dissemination.
distnbution. copying or other use of this communication is stncuy prohibited and no pnvilege is waived. If you have received this ccenmunicabon in error. please
immediately notify the sender by replying to this electronic message and then deleting this electronic message from your amputee; (v.1)
Page 13 of 13
EFTA00592802
Filing #4O09659M; tikkic6407psowpwi :ppoierptet 117-2 Filed 04/21/16 Page 1 of 7
BRADLEY J. EDWARDS. and
PAUL G. CASSELL,
Plaintiffs,
v.
ALAN DERSHOWITZ.
Defendant. IN THE CIRCUIT COURT OF THE 17th
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIVIL DIVISION
CASE NO. CACE 15-000072
PLAINTIFFS AND NON-PARTY VIRGINIA GIUFFRE'S NOTICE REGARDING THE
PARTIES' JOINT SITPULATION OF DISMISSAL
Plaintiffs and Non-Party Virginia Giuffre, by and through undersigned counsel, hereby
provide the Court with Notice that while the Plaintiff and Defendant submitted a Joint Stipulation
of Dismissal, on April 8. 2016, there remain issues pending before the Court that requires the
Court to retain jurisdiction over this matter. Specifically, the Court has specially set for hearing
on May 12, 2016, non-party Virginia Giuffre's Supplemental Motion to Strike and for Sanctions
against Defendant Dershowitz. See Exhibit A. The parties agreed that the settlement between the
Plaintiffs and the Defendant would in no way affect the right of non-party Virginia Giuffre to have
her pending Motion to Strike and for Sanctions heard by the Court. Accordingly, in an abundance
of caution, Plaintiffs and Non-Party Giuffre provide this Notice to ensure the Court retains
jurisdiction over the matter to resolve the remaining pending issues.
*** FILED: BROWARD COUNTY. FL HOWARD FORMAN. CLERK 4/11/2016 1:52:00 PMS**
EFTA00592803
Case 1:15-cv-07433-RWS Document 117-2 Filed 04/21/16 Page 2 of 7
Dated: April 11, 2016
Respectfully submitted,
4S>
BOWS, SCHILLER & FLEXNER LLP
By: /s/Siarid S. McCawley_
Sigrid S. McCawley, Esq.
Florida Bar No. 129305
401 East Las Olas Boulevard, Suite 1200
Fort Lauderdale, Florida 33301
Telephone: (954) 356-0011
Facsimile: (954) 356-0022
Attorney for Non-Party Virginia Giuffre
By: /s/ Jack Scarola
Jack Scarola, Esq.
SEARCY DENNEY SCAROLA BARNHART
& SHIPLEY, P.A.
ISN(aseartzylnw.com
2139 Palm Beach Lakes Blvd.
West Palm Beach, FL 33409-6601
Attorney for Plaint0
EFTA00592804
Case 1:15-cv-07433-RWS Document 117-2 Filed 04/21/16 Page 3 of 7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on April II, 2016, a true and correct copy of the foregoing
was served by Electronic Mail to the individuals identified below.
By: /s/Sigrid S. McCawley
Sigrid S. McCawley
Thomas E. Scott
1-hoinas.setni'.if c:klegal.corn
Steven R. Safra
SteAti.sali.;I:ct cskicgal.coin
COLE, SCOTT & KISSANE, P.A. Richard A. Simpson
rsimpsonv:( wi levrein.,..)1n
Mary E. Borja
niborja covilereip,coni
Ashley E. Eiler
9150 S. Dadeland Blvd., Suite 1400 aeiler,c wilpyrein.con!
Miami, Florida 33156 WILEY REIN, LLP
Renee,nail .i:icskleoal,coin 1776 K Street NW
Shell) damboYcsklq/al.ccnn Washington. D.C. 20006
Counsel for Alan Dershowit: Counsellor Alan Demhowitz
Charles H. Lichtman, Esq. Bruce S. Rogow, Esq.
BERGER SINGERMAN LLP BRUCE S. ROGOW, P.A.
350 E. Las Olas Blvd. 100 NE 3n1 Avenue, Suite 1000
Suite 1000 Fort Lauderdale, FL 33301
Fort Lauderdale, FL 33301 Tel: (954) 767-8909
Tel: (954) 525-9900 Fax: (954) 764-1530
Fax: (954) 523-2872 Email: brogow(drogolaw.com
Email: clicli:njainibergersinaerman.com
Counsel for Alan Dershowitz
Kenneth A. Sweder, Esq.
SWEDER & ROSS. LLP
131 Oliver Street
Boston, MA 02110 .,- a . -;.- Tel: (6 I 7) 646-4466 -..-:".:- Email: }i‘, cki,: • O-.weder4bss. Qm
c..0
Counsel for Alan Dershowitz
3
EFTA00592805
Case 1:15=c.v,074.13-RWS_Dacument_U_7-2_Eilad_0_4/2111 s Page 4_of 7
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Case 1:15-cv-07433-RWS Document 117-2 Filed 04/21/16 Page 5 of 7
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND FOR
f3ROWARD COUNTY, FLORIDA
CIVIL DIVISION
BRADLEY J. EDWARDS, and
PAUL G. CASSELL,
Plaintiffs.
v.
ALAN DERSHOWITZ,
Defendant. CASE NO. CACE 15-000072
AMENDED RE-NOTICE OF SPECIAL SET HEARING
(1 hour )
YOU ARE HEREBY NOTIFIED that the following hearing is being rescheduled before
the Honorable Thomas Lynch, IV, Circuit Court Judge, Seventeenth Judicial Circuit Court,
Broward County Courthouse, 201 S.E. 6'h Street. Room 950, Fort Lauderdale, Florida 33301, to
Thursday, May 12, 2016 beginning at 1:30 p.m., and will address the following matters:
1) Non-Party Virginia Roberts' Motion to Strike And For Sanctions;
2) Non-Party Virginia Giuffre's Supplemental Motion to Strike and For
Sanctions
3) Defendant Alan Dershowitz's Motion in 'Amine to Overrule Objections
4) Defendant Alan Dershow•itz.'s Motion to Strike Motion of Non-Party Virginia
Roberts' Motion for Sanctions
NOTICE TO DISABLED PERSONS
If you are a person with a disability who needs any accommodation in order to participate in this proceeding. you arc
entitled, at no cost to you, to the provision of certain assistance. Please contact the Seventeenth Judicial Circuit's
ADA Coordinator at 201 S.E. Sixth Street. Fort Lauderdalz, FL 33301, telephone number (954) 831-7721, within
two (2) working days of receipt of this document. TDD users may also call 1-800-955-8771 for the Florida Relay
Service.
EFTA00592807
Case 1:15-cv-07433-RWS Document 117-2 Filed 04/21/16 Page 6 of 7
Dated: March 30, 2016
Respectfully submitted,
Bows, SCHILLER & FLEXNER LLP
Sigrid S. McCawley, Esq.
~ntiiaWtle) rz cow
Florida Bar No. 129305
401 East Las Olas Boulevard, Suite 1200
Fort Lauderdale, Florida 33301
Telephone: (954) 356-0011
Facsimile: (954) 356-0022
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Byils/Sigyid S. McCawley
Sigrid S. McCawley, Esq.
Attorney for Non-Parry Virginia Giuffre
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served by
Electronic Mail on March 30, 2016 to the individuals identified on the attached Service List.
By: /s/Sigrid S. McCawley
Sigrid S. McCawley
EFTA00592808
Case 1:15-cv-07433-RWS Document 117-2 Filed 04/21/16 Page 7 of
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100 NE 3rd Avenue. Suite 1000
Fort Lauderdale, FL 33301
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EFTA00592809
📷 Images in this document (22 detected; 6 largest described)
AI-generated factual descriptions of embedded images (llava:13b). These are searchable across the corpus.
[Image 1] The image shows a document with a heading that reads "SERVICE LIST." Below the heading, there is a table with columns labeled "Name," "Address," "Phone," and "Email." The table contains several entries with names, addresses, phone numbers, and email addresses. The document appears to be a list of service providers or contacts, possibly for a business or organization. The text is in English, and th
[Image 2] The image shows a document, which appears to be a court order or a legal notice. It is a scanned document with visible text and a header that includes the name of the court and the case number. The document is titled "AMENDED NOTICE OF SPECIAL SETTING" and mentions a case number and the names of the parties involved. It refers to a specific case and includes a list of items to be addressed during
[Image 3] The image shows a document with text, which appears to be a legal or official document. The document is titled "CERTIFICATE OF SERVICE" and includes a case number and a date. It mentions a plaintiff and a defendant, with the defendant's name being redacted. The document is signed by a person whose name is also redacted. The text includes a description of the service method and the date of service.
[Image 4] The image appears to be a document with a watermark that reads "EXHIBIT A." The document is a photograph of a physical page, which seems to be a legal or official document, possibly an exhibit in a court case or a report. The text is too small to read clearly, and the document contains a header with a date and a footer with a page number. The visible part of the document is the upper right corner,
[Image 5] The image shows a document, which appears to be a court order or a legal notice. The document is titled "NOTICE OF FILING OF PLEADINGS AND PARTIES" and is addressed to "Defendant." It mentions a case number and a date, which is redacted for privacy. The document is from the "United States District Court for the Southern District of Florida." It mentions the names of the parties involved in the cas
[Image 6] The image shows a document titled "CERTIFICATE OF SERVICE" from a court case. It appears to be a formal legal document, possibly related to a lawsuit or legal proceeding. The document includes the names of individuals and entities that have been served with legal documents, along with their addresses. The text is printed in black ink on a white background, and the document is signed by a person wh