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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 3 of 27 colleague, Bradley Edwards, brought against me (Edwards v. Dershowitz, Case No. CACE 15-000072 (Cir. Ct., Broward Cnty., Fla.)). Moreover, he elides or mischaracterizes testimony gathered in those and other proceedings in order to make them appear inculpatory of me when, in fact, they are just the opposite. 5. In doing so, Mr. Cassell seeks to accomplish two goals simultaneously: first, to suppress information—the Requested Documents—which exculpates me from the charges of sexual misconduct, while allowing Ms. Giuffre and her allies to publicly disseminate those selected “facts” that, they believe, support her allegations against me; and, second, to prove that Mr. Cassell—and , by extension, his colleague Mr. Edwards and Ms. Giuffre’s current lawyers at Boies Schiller & Flexner, LLP—have a valid factual basis for continuing to press Ms. Giuffre’s false allegations. Mr. Cassell’s effort is an unmitigated failure, as this declaration demonstrates. 6. While much of the Cassell Declaration goes far beyond what is reasonably required to respond to the instant motion, and while it surely has the distinct air of “protesting too much,” I cannot stand mute in the face of this continuing assault on my character. As this declaration and the accompanying reply brief will demonstrate, the charges against me are baseless, and unsealing the Requested Document is the only proper response to Ms. Giuffre’s efforts to smear me through the legal process. 7. In its effort to block the unsealing of the Requested Documents and to justify Ms. Giuffre’s lawyers’ decision to represent her, the Cassell Declaration cites five sources: (i) a Palm Beach Police Department Report dated July 19, 2006; (ii) flight logs for the aircraft owned by Jeffrey Epstein; (iii) the fact that a “very well-regarded Florida” lawyer filed a civil complaint against Mr. Epstein on Ms. Giuffre’s behalf which accused “academicians”