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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 1 of 27 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA GIUFFRE, Index No. 15 Civ. 7433 (RWS) Plaintiff, -against- REPLY DECLARATION OF ALAN M. DERSHOWITZ IN GHISLAINE MAXWELL, FURTHER SUPPORT OF MOTION TO INTERVENE Defendant. AND UNSEAL ALAN M. DERSHOWITZ declares under penalty of perjury that the following is true and correct: 1. I am personally familiar with the facts set forth in this Reply Declaration, which I submit in further support of my pending motion to intervene and to unseal the “Requested Documents,” as that term is defined in Paragraph 3 of my August 11, 2016 Declaration. Introduction and Overview 2. Rather than offering a valid and proper basis for opposing my motion, the papers submitted on behalf of plaintiff Virginia Roberts Giuffre—particularly, the lengthy declaration of Paul Cassell, one of Ms. Giuffre’s lawyers and a former federal judge—are little more than an effort to revive and further the false and scurrilous allegations of sexual misconduct that compelled me to seek the Court’s assistance in the first place. As his declaration makes clear, Mr. Cassell has crossed the line from being a legitimate advocate for a client, to being a lawyer who is seeking to justify his own conduct in the face of compelling evidence that his client is a thoroughgoing liar. That was, after all, the gravamen of Mr. Cassell’s defamation case against me: the assertion, now repeated at length before this Court, that Ms. Giuffre’s lawyers