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HOUSE_OVERSIGHT_015590

2016-02-03 - Dershowitz (public and redacted) Motion to Modify Confidentiality Order for Limited Use- Pages 1 to 60

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Filing # 37357304 E-Filed 02/03/2016 12:44:44 PM
BRADLEY J. EDWARDS and
PAUL G. CASSELL,
vs.
Plaintiffs/Counterclaim Defendants,
ALAN M. DERSHOWITZ,
Defendant/Counterclaim Plaintiff.
___________________________________________/
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE 15-000072
DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN M. DERSHOWITZ’S REDACTED
MOTION TO MODIFY CONFIDENTIALITY ORDER
Defendant/Counterclaim Plaintiff, Alan M. Dershowitz (“Dershowitz”), by and through
undersigned counsel, hereby files his Redacted Motion to Modify Confidentiality Order of
January 12, 2016, and in support thereof states the following:
On January 16, 2016, Defendant Alan M. Dershowitz began the deposition of non-party
Virginia Roberts Giuffre (“Roberts”). Pursuant to this Court’s January 12, 2016 Confidentiality
Order, that transcript currently is under seal. The Confidentiality Order should be modified at
least to allow Dershowitz to defend this case. Dershowitz and his counsel need to be able to
contact witnesses, inform them of Roberts’s testimony, and ask them whether Ms. Roberts’s
testimony is accurate. They also need to be able to use Ms. Roberts’s testimony in other ways as
part of the defense effort, such as by providing it to expert witnesses, among other things. The
bottom line is that Dershowitz’s counsel must be able to use Roberts’s testimony as necessary in
their professional judgment to represent their client, as a matter of fairness and due process.
Accordingly, Dershowitz requests that the Court modify the Confidentiality Order to
confirm that Dershowitz’s counsel may disclose Ms. Roberts’s testimony as they deem necessary
in their professional judgment in order to represent Dershowitz in this case.
BACKGROUND & EXECUTIVE SUMMARY
Dershowitz was first presented with Roberts’s heinous and false allegations against him
when her lawyers, Bradley J. Edwards (“Edwards”) and Paul G. Cassell (“Cassell”), filed certain

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