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Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 10 of 34 Edwards, Bradley vs. Dershowitz Case No.: CACE 15-000072 Plaintiffs’ Motion to Compel Production of Documents http:/Awww.cnn.com/videos/world/2015/01/05/wm-uk-sex-abuse-allegations-alan-dershowitz- intv.cnn In the course of defaming Edwards and Cassell, Dershowitz also made numerous representations that he had collected documents proving that he had never even met Jane Doe No. 3, much less sexually abused her. For example, on the same CNN program on January 5, Dershowitz stated: “No, never met her [Jane Doe No. 3], I didn’t know what she looked like until I saw her photograph. . . . I have a superb memory. I have a memory of not having met her. J did not meet her. And believe me, I remember everybody I’ve ever had sex with... . I can prove it by flight records. I can prove it by my travel records.” Id. (emphasis added). Dershowitz went on to say that disproving Jane Doe No. 3’s allegations was a simple task requiring about one hour of work: “If they [Edwards and Cassell] had just done an hours’ worth of work, they would have seen she is lying through her teeth.” Jd. That same day, on NBC’s Today Show, Dershowitz repeated his claim that it was a simple matter to collect documents disproving allegations made by Jane Doe No. 3: Her lawyers Paul Cassell, a former Federal judge and Brad Edwards, deliberately and willfully filed this pleading which they knew I had no opportunity to respond to in court, without doing any investigation, if they had simply investigated the manifests of the airplanes, if they had checked my travel records, if they had asked me and I could have given the names of these people who are witnesses, they would know the stories, totally, completely false. https://Awww.youtube.com/watch? v=ZXePK Tws0f0 HOUSE_OVERSIGHT_014093