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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 5 of 27 his airplane—during the time Ms. Giuffre was associated with him. Dershowitz Decl.,! 4 9. Nothing about Ms. Giuffre’s relationship with Mr. Epstein, or her age, could have been “obvious” to me, because I never met her. Second, there is simply no evidence that Mr. Epstein’s alleged abuse of minor victims at his home in Palm Beach was “obvious” or known to any “visiting guests,” given that the abuse took is alleged to have taken place in a separate part of the house, namely Mr. Epstein’s private bedroom. 10. Ms. Giuffre and her counsel have alleged that she was not the only “young girl” that I had sexual contact with —i.e., that there were others. Of course, no such persons have ever presented themselves to corroborate this accusation. Nonetheless, Mr. Cassell latched on to this allegation as a “basis” for his filing in the CRVA Action, which named me as a serial abuser. 11. Demonstrating how little Mr. Cassell really had to go on in this regard, I ask the Court to consider Mr. Cassell’s response to a question put to him in deposition concerning who, other than his client, he had reason to believe was abused by me. All Mr. Cassell could muster was this: [CASSELL]: ...I have 24 names in mind as possible sexual abuse victims that Dershowitz may or may not have abused. And I have not been able to pinpoint exactly what happened, because the people who would be in the best position to help me sort out what the names were [--] specifically Jeffrey Epstein, among others [--] have refused to cooperate and give me those names” (emphasis added). Ex. O at 36-37. 12. The very idea that Mr. Cassell could claim that, without more, a mere /ist of alleged victims that he believes that I “may or may not have abused” would provide a basis for publicly accusing me of heinous crimes, well illustrates Mr. Cassell’s mindset. ' Citations to “Dershowitz Decl.” refer to my August 11, 2016 moving declaration. Exhibits O through X are attached to this Reply Declaration.