Dershowitz to use the transcript for those limited purposes as deemed necessary in the

Dershowitz now requests that the Court modify the Confidentiality Order to allow Dershowitz to use the transcript for those limited purposes as deemed necessary in the professional judgment of his counsel to ensure Dershowitz is afforded his night to build and present his defense. I. DERSHOWITZ MUST BE ALLOWED TO CONTACT WITNESSES AND ADVISE THEM OF WHAT ROBERTS ALLEGES IN ORDER TO VERIFY OR DISPROVE HER ALLEGATIONS AND CREDIBILITY AND DETERMINE WHETHER PLAINTIFFS EVER MADE EFFORT TO CONTACT THESE INDIVIDUALS TO VERIFY ROBERTS’S ALLEGATIONS AND CREDIBILITY. As explained by Plaintiffs Edwards and Cassell in their Response to Dershowitz’ s Motion to Determine Confidentiality, the “sexual abuse allegations filed by Edwards and Cassell for their client Ms. Virginia Giuffre are not peripheral to this lawsuit — they are inherent to it.” Plaintiffs’ Response to Dershowitz’s Motion to Determine Confidentiality, November 23, 2015, attached hereto as Exhibit E at 4 (emphasis added). Those “sexual abuse allegations filed by Edwards and Cassell for their client” go beyond Dershowitz. Another inherent part of this lawsuit is what investigation, if any, Plaintiffs undertook with respect to the scope of Roberts’s allegations, all of which bear upon her credibility. Dershowitz argues that Plaintiffs did not perform a reasonable investigation before making the allegations in the Federal Action. Plaintiffs argue that they did. Dershowitz must be allowed to contact witnesses and advise them of what Roberts alleges so that Dershowitz can not only verify or disprove her allegations and credibility, but also determine whether Plaintiffs ever made efforts to contact key witnesses to verify Roberts’s allegations and credibility. As explained by one Florida court, “[o]penness in courts has a salutary effect on the propensity of witnesses to tell the truth” as it “informs persons affected by litigation of its effect upon them... .” John Doe-1 Through John Doe-4 v. Museum of Sci. & History of Jacksonville, Inc., No. 92-32567-CI-CI, 1994 WL 741009, at *1 (Fla. Cir. Ct. June 8, 1994) (internal citations omitted). HOUSE_OVERSIGHT_015592