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Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 4 of 34 In his most recent supplemental filing with this court (DE 317-1), Dershowitz twists the facts and jumps to conclusions in service of his crusade against Jane Doe No. 3. For example, Dershowitz notes that Jane Doe No. 3 told attorney Edwards before April 2011 that Dershowitz had abused her, but then says “she and Edwards sat on this highly charged accusation for three years and eight months before first using it in their [sic] pleading filed on December 30, 2014. This constitutes laches that prejudiced . . . Dershowitz... .’ DE 317-1 at 2. Dershowitz ignores the key fact that in April 2011, attorney Edwards did not represent Jane Doe No. 3. Accordingly, he could not “sit” on her claims against Dershowitz because he was not empowered, at that time, to pursue them.* With regard to the claim of laches, Dershowitz argues that he has been prejudiced because if the allegations had been filed earlier, “he would have been in a far better position to secure travel and other records needed to disprove these charges.” DE 317-1 at 2. But, as noted above, Dershowitz has already told worldwide news media that he has already collected all of the records and can provide irrefutable, documentary proof that Jane Doe No. 3 is lying. For example, Dershowitz has told the Boston Globe that “he will use his travel and credit card records, which he said he has fastidiously saved, to refute the allegations against him.” “Nor did Jane Doe No. 3 sit on any claims against Dershowitz, notably claims relating to the CVRA case. In 2011, Jane Doe No. 3 lacked legal counsel regarding the CVRA claim. It was not until her recent return from Australia to the United States that she understood the claims involved in the CVRA action and obtained legal counsel to pursue them. See DE 310-1 at 8, § 57. > “Dershowitz ‘thrilled’ to be sued for defamation,” Boston Globe (Jan. 7, 2015), available at, http://www.bostonglobe.com/metro/2015/01/06/sued-for-defamation-dershowitz- thrilled-chance-question-lawyers-sex-crime-accuser/2 1 QibSrwNC343eKMadWNeL/story. html. 3 HOUSE_OVERSIGHT_014087