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Case 9:08-cv-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 6 of 19 Second, Jane Doe #3 claims that she needed to defame Prof. Dershowitz and others in the Joinder Motion because of discovery disputes between the government and Jane Doe #1 and Jane Doe #2. This does not even make sense, legally or factually. Jane Doe #3’s right to join in this case has nothing to do with Jane Doe #1 and Jane Doe #2’s entitlement to documents in discovery. In fact, the discovery requests that Jane Doe #3 cites to in her Response as purported cover for their sliming of Prof Dershowitz show that their argument is factually bogus. Prof. Dershowitz is mentioned in only two of twenty-five requests for production propounded by Jane Doe #1 and Jane Doe #2. (See Jane Doe #1 and Jane Doe #2’s First Request for Production to the Government Regarding Information Relevant to Their Pending Action Concern [sic] the Crime Victims Act, at DE 225-1 at 26-38.) Both requests, nos. 8 and 21 seek his communications with the government in his role as Mr. Epstein’s defense attorney. There is no issue of complicity or knowledge in any misconduct. Moreover, a fact conveniently omitted by Jane Doe #3 is that Prof. Dershowitz is one of eleven lawyers whose communications Jane Doe #1 and Jane Doe #2 sought in the requests for production. As the Court knows, Prof. Dershowitz had no material connection to this case—as to the merits or as to discovery—before he was dragged in by Jane Doe #3. Third, Jane Doe #3 claims that the smears against Prof. Dershowitz are relevant to show that Prof. Dershowitz had a motive to negotiate “confidentiality” and “blank check” provisions discovery requests regarding her belief that Prince Andrew was somehow involved in “lobbying efforts to persuade the Government to give him a more favorable plea arrangement,” and because her allegations against Prince Andrews occurred in London, therefore “affect[ing] foreign commerce” are patently absurd. (DE 291 at 20 and 18, fn. 10.) Because Jane Doe #3’s other allegations are replete with allegations of interstate activity and because implications of Prince Andrew’s involvement in “lobbying” for the NPA are entirely nonsensical, it is obvious that the inclusion of claims against Prince Andrew were included solely for their intended audience: the media. 6 HOUSE_OVERSIGHT_010740