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Case 1:19-cv-03377-LAP Document 36-4 Filed 07/03/19
PAUL G. CASSELL
Ronald N. Boyce Presidential Professor of Criminal Law
THE UNIVERSITY OF UTAH and University Distinguished Professor of Law
S.J. QUINNEY Telephone: 801-585-5202
- | COLLEGE OF LAW cassellp@Jaw.utah.cdu
November 6, 2017
The Florida Bar
651 E. Jefferson St.
Tallahassee, FL 32399
Re: Bar Complaint By Mr. Dershawitz
Dear Florida Bar:
1. I have been advised of assertions made by Mr. Dershowitz to the Florida Bar
concerning attorneys David Boies and Sigrid McCawley. I provide this affidavit at the request
of counsel for Mr. Boies and Ms. McCawley in order to provide the Florida Bar with information
that I have regarding the accuracy or inaccuracy of those assertions.
Spt teresa tee weaned De,
Civil Cases Against Epstein and Connections with Mr. Dershowitz
12, While the CVRA case was proceeding, Mr. Edwards and | also represented several
of Epstein’s victims in civil cases against Epstein. During those civil cases, Mr. Epstein was
deposed about others who might have been involved in his sexual abuse of minor girls. Several
civil attomeys asked Epstein about Mr. Dershowitz, and Epstein invoked his Fifth Amendment
rights rather than answer questions about Dershowitz. Efforts were made to depose Dershowitz
on his connections, but they were unsuccessful.
13. It was known at the time that Dershowitz had not only served as Epstein’s legal
counsel, but was also an extremely close personal friend of Epstein. Household employees of
Epstein also placed Dershowitz inside the Epstcin mansion during time periods when Epstein
was involved in sexually abusing minor girls. For example, houschold employee Juan Alessi
testified under oath that one of the famous visitors who came to (he Epstein mansion was “a very
famous lawyer that I’m sure you know, Alan Dershowitz.” (Alessi Depo., at 73:22-25.)
According to Alessi's sworn testimony, Dershowitz came to the mansion “pretty often . . . at
least four or five times a year” and would stay “two [or] three days.” (73:22-25). Alessi also
testified that Ms. Virginia Roberts Giuffre came to the house when Dershowitz was there.
(73:18-20) Alessi answered “yes” when asked whether Dershowitz “had massages sometimes
when he was there,” (74:1-4). Alessi explained that “[a] massage was like a treat for
everybody.” (/d.)
14. Similar testimony was provided by another household employee, who worked for
Epstein at a different time period -- Alfredo Rodriguez, According to Rodriguez, Dershowitz
was at Epstcin’s mansion when underage girls were there to give massages. (Rodriguez Depo. at
78:13-25, 279:9-280:2). According to Rodriguez, Dershowitz stayed at the house in his role as
Epstein’s friend, as opposed to being his lawyer. (ld. at 279:5-8; 385:1-6).
15. Dershowitz was present alone, without his family, at the home of Jeffery Epstein in
the presence of young girls. (Jd. at 199:12-13, 279:9-12, 426:16-25, 427:1). Rodriguez testified
that when the underage girls would come over, Dershowitz would drink wine and read books on
the couch. (/d. at 426:16-25; 427:1.)
16. Ultimately Epstein choose to settle his civil suits with Jane Doe |, Jane Doe 2, and
Ms. Virginia Roberts Giuffre. However, Epstein did not settle the CVRA case, and Mr. Edwards
and I have continued to attempt to secure factual evidence that would demonstrate that the plea
decisions made by the Government were improper or improperly influenced.
8 See, &g., Vicky Ward, The Talented Mr. Epstein, in Vanity Fair (Jan. 2005) (quoting Dershowitz as
stating “I’m on my 2(th book. . .. The only person outside of my immediate family that | send drafts to is
Jeffrey”); see alsa Ray Gustini, Vanity Fair Reminds Us When Jeffrey Epstein Wasn't a Creep, in The
Wire (June 21, 2011) (quoting Dershowitz as stating that even if Epstein went bankrupt, “I would be as
interested in him as a friend if we had hamburgers on the boardwalk in Coney Island and talked about his
ideas.").
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| Filename | HOUSE_OVERSIGHT_016198.jpg |
| File Size | 0.0 KB |
| OCR Confidence | 85.0% |
| Has Readable Text | Yes |
| Text Length | 4,031 characters |
| Indexed | 2026-02-04T16:27:19.237776 |