EFTA00592788.pdf

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. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. X 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 > mI p:/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 > sI p://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 sl p://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 IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION BRADLEY J. EDWARDS. and CASE NO. CACE 15-000072 PAUL G. CASSELL, Plaintiffs, v. ALAN DERSHOWITZ. Defendant. 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 Attorneyfor 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 Attorneyfor 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 I I, 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 Richard A. Simpson 1-hoinas.setni'.if c:klegal.corn rsimpsonv:( wi levrein.,..)1n Steven R. Safra Mary E. Borja SteA ti.sali.;I:ct cskicgal.coin niborja covilereip,coni COLE, SCOTT & KISSANE, P.A. 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 Counselfor 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 Counselfor 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 Counselfor 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 .414/ si> OQA CH>" ,N4c csA ,4c 4c s.s .% t<sis .s* • "CN- • •S" ..."SN' • •SS' CS=', • •,3N- -C> • <SS ,' '4 C app • • 1'. • ,014/ , e o 4A e e N.4 ww , # , •,4 •N'' •.- 44.\ COQ ooQo c*.r, e .4•Nt• s"' N N' c≥t" N 4. 4 4 4 s) 4 • v-s> • , • ,s> • ,s> ,s> • \. ,s> se se s% S.> 4 14/ S> • 4 414/% 4 014/ 4 , <014/ 4.‘,, <014/ isc,, <014/ _cc\.0 , 414/%-, 4 _„4 „p. • <.Ne ..„4$ e e 4.c 4 \ • • • • 4 1 s t I t "is I' t .,.,.‘ ty ..I , e N.,4A N.6 , I , I 4 4A 4 4/ '4 s -:c e „4 e 4 e 4 41 < 14 / • • ',Ss' 4' 4\ s, cs* $ 14 / app Ns,4\ ,,•s• 4\ 4.%e • e • e • e • % %St"' Nt-- 'Ss" 4S.;:‘ 4 4.> 4 4.> "P' • • 4k-14/ • 41-14/ • e < • t>-• NO It) e • 414/ • 4\ s_ ,-14/ c*, `..,§\ -1 ) .1) Nt *I) 9 s. t CZ "‘" EFTA00592806  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 CASE NO. CACE 15-000072 PAUL G. CASSELL, Plaintiffs. v. ALAN DERSHOWITZ, Defendant. AMENDED RE-NOTICE OF SPECIAL SET HEARING (1hour ) 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 ItI..ci _rrhsillit.coin Byils/Sigyid S. McCawley Sigrid S. McCawley, Esq. Attorneyfor 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 7 ,. :St 43,< ,G >` :. Vag .: - A cks‘> A <‘ s- A <‘ N'> A < Sc, t\ Ne O A NeSN O A 0 0 Ne 0 0 0 Ne 0 'se COQ aO aO aO aO -' • iIASI AV * 1 • • 4` _act $S le - XS( i .( • *N ..,-. *. a a *. ' # %..- ao _,Thomas E. Sett& Richard A. Si son 414/ e \ OQA Thomas.scotfircsklegal.cont:> 4, rsim son rein.com ww O Steven frit, ',z>-- ...k -a Sitoyoti.$alragzsilaom A.` -- • CS ap COLE, SCOTT & KISSANE, P.A:. •ctiz-- der % O -• 00 0 9150 S. Dadeland Blvd., Suite 1400 O <8 ' aeik 1 ",t Miami, Florida 33156 N WILEY REIN, O .- Rence.nail(ccesittegal.com A 1776 K Street NW S'hellv.7aml cskleeal.com Washington, D.C. 20006 c,,O. OQA O *.S. C.) tz ?-Coeinseij:»- A km ~O$ 4:1- Dershowitz4:\ $.<-, cc Counselfor Alan Dershowitz S., 0 -..itz- . Charles H. Lichtman, Esq. aN 0 Bruce S. Rogow, Esq. %- ..N BERGER SINGERMAN LLP BRUCE S. ROGOW, P.A. 0\4 350 E. Las Olas Blvd. 100 NE 3rd Avenue. Suite 1000 Suite 1000 _,c Fort Lauderdale, FL 33301 4 14 / Fort Lauderdale, FL 33301 Tel: (954) 767-8909 Tel: (954) 525-9900 c. 41 4/ ,‘, ,. ,$' Fax: (954) 7(1.-153( .... 4' Fax: (954)523-2872'N ,..S''