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Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 33 of 34 Thomas E. Scott, Jr., Esq. Re: Edwards and Cassell v. Dershowitz February 25, 2015 Page 5 test the accuracy of those statements and to explore the full extent of the personal relationship he has had with Jeffrey Epstein. Evasive Answers The response to Interrogatory #2 is a typical example of an evasive response. Rather than address the substance of the questions posed, the Defendant engages in a four page diatribe about the alleged impropriety of naming him in a CVRA filing on behalf of Jane Doe #3. If that is the only improper conduct in which the Defendant contends Bradley Edwards has engaged, then the Defendant is obliged to say so. Interrogatory #3 asks for the specific content of statements and the names of every witness to the making of the statements. We get a vague reference to “such comments” and references to the inability to “recall all of the people.” Not a single witness’ name is disclosed. If the Defendant is unable to identify a single person he is obliged to unequivocally say so. Refusing to Provide Substantive Responses Until Jane Doe #3 is Deposed This objection has absolutely no legal basis and fails to recognize that this is a defamation action against Dershowitz and not Mr. Dershowitz’s defamation action against Jane Doe #3. This action is absolutely not dependent on the accuracy of the statements made by Jane Doe #3, although the Plaintiffs were and are confident of the accuracy of those statements. Objecting Because You Think We Already Know the Answers See for example the Response to Interrogatory #13. There is no legal basis for refusing to provide information because the Defendant believes the Plaintiff already knows the answer or has alternative sources to ascertain some or all of the information requested. An admission from an opposing party carries legal significance that other evidence does not have. We are entitled to Dershowitz’s sworn responses regardless of what flight logs purport to show. Incomplete Answers See, for example, Interrogatory #15. A question that asks for names, addresses, and telephone numbers, is not properly responded to if all we get is, “Thomas and Joanne Ashe, as well as Defendant’s wife and daughter.” HOUSE_OVERSIGHT_014116