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Case 1:15-cv-07433-LAP Document 1330-1 Filed 01/05/24 Page 10 of 13 p. Dershowitz had told the Palm Beach Police Department that he was going to make Epstein available to answer questions about sex abuse of underage girls, but then repeatedly rescheduled those meetings, ultimately never producing Epstein — a pattern of deception that appeared to be designed to deliberately delay the investigation; q. Dershowitz’s pattern of avoiding depositions (and helping Epstein avoid questioning) was consistent with a pattern of other persons who were involved in Epstein’s international sex trafficking organization evading efforts to obtain information from them; r. Ms. Giuffre had alleged abuse by other powerful friends of Epstein, including Prince Andrew, and there was a photograph showing Prince Andrew with his arm around Ms. Giuffre apparently taken in London (where she said the sex abuse had taken place). Sealed Exhibit 1, Depo. of Paul Cassell (Oct. 16 & 17, 2015), at 61-117. 22. Ms. Giuffre was not a party to the litigation between Dershowitz, Mr. Edwards, and me. 23. During the course of the litigation, however, Dershowitz sought to obtain discovery from Ms. 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 denied his discovery request. Attached hereto as Sealed Exhibit 2 is a true and correct copy of the court’s order denying that discovery. 24. Dershowitz produced many documents in the course of discovery in that case — and, ironically, he placed many document under a protective order in Florida. Attached hereto as 10