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Case 1:15-cv-07433-LAP Document 1330-1 Filed 01/05/24 Page 5 of 13 done one hour of work investigating Ms. Giuffre’s allegations of sexual abuse against him, we would have immediately seen that those allegations were false. 12. On January 5, 2015, Dershowitz filed a motion to intervene to argue to have the allegations stricken. DE 282. Dershowitz also argued that Ms. Giuffre had not provided a sworn affidavit attesting to the truth of her allegations. 13. On January 21, 2015, Edwards and I filed a response for our clients, Ms. Giuffre and Jane Doe No. 4. DE 291. The response enumerated nine specific reasons why Ms. Giuffre’s specific allegations against Dershowitz were relevant to the case, including the fact that Ms. Giuffre needed to establish that she was a “victim” in the case, that pending discovery requests concerning Dershowitz-specific documents were pending, and that Dershowitz’s role as a defense attorney in the case was highly relevant to the motive for the Government and defense counsel to conceal the plea deal from the victims. DE 291 at 17-26 & n.17. The response included a detailed affidavit from Ms. Giuffre about the sexual abuse she had suffered from Epstein, Dershowitz, and other powerful persons. DE 291-1. 14. On February 6, 2015, Edwards and Cassell filed a further pleading (and affidavit from Ms. Giuffre, see DE 291-1) in support of her motion to intervene. 15. On April 7, 2015, Judge Marra denied Ms. Giuffre’s motion to join the case. Judge Marra concluded that “at this juncture in the proceedings” details about the sexual abuse she had suffered was unnecessary to making a determination “of whether Jane Doe 3 and Jane Doe 4 should be permitted to join [the other victims’] claim that the Government violated their rights under the CVRA. The factual details regarding with whom and where the Jane Does engaged in sexual activities are impertinent to this central claim (i.e., that they were known victims of Mr. Epstein and the Government owed them CVRA duties), especially considering