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Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 12 of 31 Giuffre. In particular, Dershowitz sought to obtain from Ms. Giuffre (a non-party to the action) all of her emails with the media. The Court granted in part Ms. Giuffre’s Motion to Quash and, among other things, denied Dershowitz’s discovery request relating to communications with media and denied Dershowitz’s request for “manuscripts or writings.” '” Dershowitz produced many documents in the course of discovery in that case — ironically, documents that he quickly placed under a protective order in Florida. Jd. Dershowitz claims that the Churcher email somehow exonerates him, but the brief mention does no such thing. Indeed, while asserting that there is no “proof” that Dershowitz is a pedophile, Ms. Churcher also stated that “[w]e all suspect Alan is a pedo[phile].””°*’ Similarly, Dershowitz believes that an excerpt from Ms. Giuffre’s manuscript she was somehow suggests his innocence, even though the passage in question recounts Dershowitz intruding on Epstein while he was sexually abusing Ms. Giuffre. DE 364 at 9. Apparently Dershowitz believes that because he is not described more often and prominently in the manuscript, that is proof of her '° Judge Lynch Quashed discovery from non-party Virginia Giuffre on the Following: (1) Request 9 — “All documents concerning any communications by Jane Doe #3 or on Jane Doe #3’s behalf with any media outlet concerning Dershowitz or the Federal Action whether or not such communications were “on the record” or “off the record;” (2) Request 17 “All documents concerning any actual or potential book, television or movie contracts or deals concerning Jane Doe #3’s allegations about being a sex slave;” (3) Request 18 “All documents concerning any monetary payments or other consideration received by Jane Doe #3 from any media outlet in exchange for her statements whether ‘on the record’ or ‘off the record’ regarding Epstein, Dershowitz, Prince Andrew, Duke of York, and/or being a sex slave;” (4) Request 20 “All documents showing any payments or renumeration of any kind made by Epstein or any of his agents or associates to you from January 1, 1999 through December 31, 2002;” and (4) Request 23: “All manuscripts and/or other writings whether published or unpublished, created in whole or in part by Jane Doe #3 concerning Epstein and any of his agents or associates.” °° Dershowitz asserts that before this May 11, 2011, email was sent by Ms. Churcher, that Ms. Giuffre “did not in any way accuse Professor Dershowitz of sexual abuse . . . .” DE 364 at 9-10. But the support for this assertion appears to be a statement from Asst. U.S. Attorney Jeff Sloman that Dershowitz’s name had not come up in 2006 to 2008 when Dershowitz was helping to negotiate Jeffrey Epstein’s plea deal. Dershowitz Dec., | 5 (referring to unnamed Asst. U.S. Attorney). However, because of Dershowitz’s penchant for twisting words, Mr. Sloman has sent a corrective note that he left the U.S. Attorney’s Office in 2008 and does not know what the investigation of Epstein revealed after that time. Also, Dershowitz does not recount in his statement of facts that in March 2011, two months before Ms. Churcher sent the email in question to Ms. Giuffre, Ms. Giuffre had told attorney Jack Scarola ina recorded interview that Dershowitz has relevant information about Epstein’s sexual abuse. ?! Dershowitz wrongly suggests to this Court that Ms. Giuffre answered questions incorrectly in her deposition. Ms. Giuffre answered questions to the best of her recollection. Ms. Giuffre had never sent an email to Ms. Churcher with Dershowitz’s name in it — instead, as Dershowitz recounts, Ms. Churcher turns out to have sent one email to Ms. Giuffre with Dershowitz’s name in it.