Filing # 37357304 E-Filed 02/03/2016 12:44:44 PM

Filing # 37357304 E-Filed 02/03/2016 12:44:44 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs/Counterclaim Defendants, VS. ALAN M. DERSHOWITZ, Defendant/Counterclaim Plaintiff. / DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN M. DERSHOWITZ’S REDACTED MOTION TO MODIFY CONFIDENTIALITY ORDER Defendant/Counterclaim Plaintiff, Alan M. Dershowitz (“Dershowitz”), by and through undersigned counsel, hereby files his Redacted Motion to Modify Confidentiality Order of January 12, 2016, and in support thereof states the following: On January 16, 2016, Defendant Alan M. Dershowitz began the deposition of non-party Virginia Roberts Giuffre (“Roberts”). Pursuant to this Court’s January 12, 2016 Confidentiality Order, that transcript currently is under seal. The Confidentiality Order should be modified at least to allow Dershowitz to defend this case. Dershowitz and his counsel need to be able to contact witnesses, inform them of Roberts’s testimony, and ask them whether Ms. Roberts’s testimony is accurate. They also need to be able to use Ms. Roberts’s testimony in other ways as part of the defense effort, such as by providing it to expert witnesses, among other things. The bottom line is that Dershowitz’s counsel must be able to use Roberts’s testimony as necessary in their professional judgment to represent their client, as a matter of fairness and due process. HOUSE_OVERSIGHT_015590