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Case 1:15-cv-07433-LAP Document 1330-1 Filed 01/05/24 Page 4 of 13 reason: “Our position is that we oppose adding new petitioners at this stage of the litigation.” See DE 291 at 5. 10. Because the Government now contested the joinder motion, Edwards and I prepared a more detailed pleading explaining the justification for granting the motion. One week after receiving the Government’s objection, on December 30, 2014, Ms. Giuffre (i.e., Jane Doe No. 3) and Jane Doe No. 4 filed a motion (and later a corrected motion) seeking to join the case. DE 279 and DE 280. Uncertain as to the basis for the Government’s objection, the motion briefly proffered the circumstances that would qualify the two women as “victims” eligible to assert rights under the CVRA. See 18 U.S.C. 3771(e) (defining “crime victim” protected under the Act). With regard to Ms. Giuffre, the motion indicated that when she was a minor, Jeffrey Epstein had trafficked her to Dershowitz and Prince Andrew (among others) for sexual purposes. Jane Doe No. 3 stated that she was prepared to prove her proffer. See DE 280 at 3 (“If allowed to join this action, Jane Doe No. 3 would prove the following... . “). The motion also provided specific reasons why Jane Doe No. 3’s participation was relevant to the case, including the pending discovery issues regarding Dershowitz and Prince Andrew. DE 280 at 9-10 (explaining several reasons participation of new victims was relevant to existing issues). 11. After the motion was filed, various news organizations published articles about it. Dershowitz also made numerous media statements about the filing, including calling Jane Doe No. 3 “a serial liar’ who “has lied through her teeth about many world leaders.” http://www.cnn.com/2015/01/06/us/dershowitz-sex-allegation/, | Dershowitz also repeatedly called Edwards and me “two sleazy, unprofessional, disbarable lawyers.” Jd. He made many similar remarks of an equivalent character, and also stated in media appearance that if we had