Edwards, Bradley vs. Dershowitz Case No.: CACE 15-000072 Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records Page 4 of 20 the materials in the records would be harmful to his _ professional reputation. Carnegie recited subsection vi’s restriction on release of materials involving a privacy right, but noted that “statements Tedder alleged were defamatory and damaging were allegations in Carnegie's counterclaim for which she seeks damages. These matters were not peripheral to the lawsuit; they were inherent to it.” Jd at 1312. Of course, exactly the same principle applies here: sexual abuse allegations filed by attorneys Edwards and Cassell for their client Ms. Virginia Giuffre are not peripheral to this lawsuit — they are inherent to it. To see how “inherent” the sexual abuse allegations are to this lawsuit, the Court need look no further than Dershowitz’s counterclaim in this case. Count I of Dershowitz’s Counterclaim (styled as “False Allegations in the Joinder Motion”) contends that Edwards and Cassell should pay him damages because they “filed a pleading in the Federal Action titled ‘Jane Doe #3 and Jane Doe #4’s Motion Pursuant to Rule 21 for Joinder in Action’... .” Dershowitz Counterclaim at { 14. Dershowitz’s Counterclaim then goes on to quote at length from the Joinder Motion. His counterclaim contains, for example, this paragraph recounting the allegations: The Joinder Motion then goes on to allege — without any supporting evidence — as follows: One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein’s and well-known criminal defense attorney. Epstein required Jane Doe #3 to have sexual relations with Dershowitz on numerous occasions while she was a minor, not only in Florida but also on private planes, in New York, New Mexico, and the U.S. Virgin HOUSE_OVERSIGHT_010760