HOUSE_OVERSIGHT_011340.jpg

10 fd. 12 [3 14 15 16 i) 18 wife) 20 21 22 23 24 25 Sil H3VOGIU1 that Edwards and Cassell made in this other lawsuit are somehow binding on Ms. Giuffre. Edwards and Cassell had separate legal counsel, Florida attorney Jack Scarola. Whatever was going on in that case isn't binding on Ms. Giuffre. Under the relevant rules, an attorney's statements are binding on a client only on a matter within the scope of the relationship. And this was vindicating separate professional interests, this was not vindicating some interest of Ms. Giuitre. So for all those reasons, we ask that the defamation litigation between Dershowitz and Edwards and Cassell be excluded. Of course, you have the separate issue of Dershowitz in front of you already. Let me turn then to point number 19. Here again, we have a narrow issue presented to your Honor. We are asking that you exclude Judge Marra's ruling on the joinder motion. As your Honor is well aware, the triggering event in this case was when Ms. Giuffre, then known as Jane Doe Number 3, filed a motion to join Jane Doe 1 and Jane Doe 2 in the Florida pro bono Crime Victims Rights action. Now, Judge Marra denied that motion to join, but at the same time he said, "The reason I'm denying the motion to join is you can participate in the case in other ways without being a formal party." He cited, and I quote, "Of course, Jane Doe 3 can participate in this litigated effort to vindicate the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011340