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Case 1:17-mc-00025-RWS   Document 10-2   Filed 06/30/16   Page 1 of 29




                    EXHIBIT B
              Case 1:17-mc-00025-RWS           Document 10-2        Filed 06/30/16     Page 2 of 29
Filing# 35180835 E-Filed 12/04/2015 03:19:02 PM


                                                           IN THE CIRCUIT COURT OF THE
                                                           SEVENTEENTH JUDICIAL CIRCUIT, IN
                                                           AND FOR BROWARD COUNTY, FLORIDA

                                                           CASE NO.: .CACE 15-000072
        BRADLEY J. EDWARDS and PAUL G.
        CASSELL,

                Plaintiffs,

        VS.


        ALAN M. DERSHOWITZ,

                Defendants.
        -------~--------I
                     PLAINTIFFS, BRADLEY J. EDWARDS AND PAUL CASSELL'S
                        MOTION FOR SUMMARY JUDGMENT ON LIABILITY

                Plaintiffs, Bradley J. Edwards, Esq. and Paul G. Cassell, Esq., by and through their

        lUldersigned counsel and pursuant to Rule 1.510, Florida Rules of Civil Procedure, hereby move

        for (1) partial summary judgment on the issue of the false and defamatory nature of the

        statements at issue in this defamation case, as well to the presumed damages from those

        statements, with respect to both of claims against the Defendant, Alan Dershowitz, and (2) final

        summary judgment as to Dershowitz's First Amended Counterclaim against them, and in support

        thereof state as follows:

                I.      INTRODUCTION

                As the Court is well aware, this case involves a defamation action filed by two attorneys:

        Edwards and Cassell. They contend that the defendant, Alan Dershowitz, defamed them by

       repeatedly claiming in worldwide media broadcasts and other widely-disseminated statements

       that they had engaged in conspiring ·with their client to make up sexual abuse

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