Filing # 37557658 E-Filed 02/08/2016 06:20:47 PM

Filing # 37557658 E-Filed 02/08/2016 06:20:47 PM IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION BRADLEY J. EDWARDS, and CASE NO. CACE 15-000072 PAUL G. CASSELL, Plaintiffs, V. ALAN DERSHOWITZ, Defendant. RESPONSE TO DEFENDANT ALAN DERSHOWITZ’S MOTION FOR CLARIFICATION OF CONFIDENTIALITY ORDER OR RELIEF FROM THAT ORDER Non-Party Virginia Giuffre, by and through undersigned counsel, hereby responds to Defendant Alan Dershowitz’s Motion for Clarification of Confidentiality Order or Relief From that Order and states as follows: FACTUAL BACKGROUND On November 12, 2015 this Court issued an Order granting in part, non-party Virginia Giuffre’s Motion to Quash the subpoena served by Defendant Alan Dershowitz and ordered protective limits relating to her deposition. See Exhibit A, November 12, 2015 Order. On December 18, 2016, this Court entered a Confidentiality Order holding that non-party Virginia Giuffre’s deposition would be confidential. See Exhibit B, December 18, 2015 Confidentiality Order. On January 16, 2016, Ms. Giuffre testified at her deposition in accordance with this Court’s Order. The deposition was labelled confidential in accordance with this Court’s Order. As the Court knows, Ms. Giuffre was a victim of sexual trafficking when she was a minor child. Indeed, the U.S. Attorney’s Office for the Southern District of Florida has specifically recognized HOUSE_OVERSIGHT_015650