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Extracted Text (OCR)
13. Describe in detail Each instance in which Jane Doe #3 has provided information
referencing Dershowitz by name that Concern the allegations set forth in Paragraphs 24-31
of the 2015 Jane Doe #3 Declaration.
ANSWER: Edwards and Cassell lack sufficient information to determine all circumstances in
which Jane Doe No. 3 has mentioned to others Dershowitz’s name as someone who abused her
or had information relevant to abuse.
With regard to when she has provided information related to this subject to them, Jane Doe No. 3
provided such information in telephone calls with Brad Edwards beginning in 2011.
Jane Doe No. 3 has also provided this information in a public affidavit, filed on January 21,
2015, in the CVRA case. Jane Doe No. 3 has also provided similar information on other
occasions, but the specifics of those communications are protected by the attorney-client
privilege and the work product doctrine.
14. If You have ever seen a photograph or video of Jane Doe #3 with Dershowitz, then state
when You saw the photograph or video, identify who took the original photograph
or video, identify Each person who possesses a copy of the photograph or video, and state
the location of Each such original and copy.
ANSWER: Edwards and Cassell have not personally seen such a photograph or
video. Discovery efforts to obtain photographic materials regarding Jane Doe No. 3 held by the
U.S. Attorney’s Office for the Southern District of Florida and/or other federal law enforcement
and prosecuting agencies are on-going.
15. For Each communication between You or anyone acting on Your behalf, and anyone
from, or acting on behalf of, any media outlet Concerning this action, the Joinder Motion,
or Dershowitz, and regardless of whether such communication was “on the record” or “off
the record,” (a) state the date of the communication; (b) state the participants in the
communication; and (c) describe the contents of the communication.
ANSWER: Objection, not reasonably calculated to lead to the discovery of admissible evidence;
vague, harassing, work-product.
16. Describe in detail All facts Concerning any assertion that Dershowitz was
a “coconspirator” with Epstein.
ANSWER: See answers to interrogatory number 5 above, as well as answers to interrogatories
numbers 1, 6, 8, 9, 10 above. In addition, factual information is found in the documents and
other materials and references provided in answer to Request for Production Number 2
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