37 H3VOGIU1 1 that Edwards and Cassell made in this other lawsuit are somehow 2 binding on Ms. Giuffre. Edwards and Cassell had separate legal 3 counsel, Florida attorney Jack Scarola. Whatever was going on 4 in that case isn't binding on Ms. Giuffre. 5 Under the relevant rules, an attorney's statements are 6 binding on a client only on a matter within the scope of the 7 relationship. And this was vindicating separate professional 8 interests, this was not vindicating some interest of 9 Ms. Giuffre. 10 So for all those reasons, we ask that the defamation 1a litigation between Dershowitz and Edwards and Cassell be 12 excluded. Of course, you have the separate issue of Dershowitz 13 in front of you already. 14 Let me turn then to point number 19. Here again, we 15 have a narrow issue presented to your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. de As your Honor is well aware, the triggering event in this case 18 was when Ms. Giuffre, then known as Jane Doe Number 3, filed a 19 motion to join Jane Doe 1 and Jane Doe 2 in the Florida pro 20 bono Crime Victims Rights action. 21 Now, Judge Marra denied that motion to join, but at 22 the same time he said, "The reason I'm denying the motion to 23 join is you can participate in the case in other ways without 24 being a formal party." He cited, and I quote, "Of course, Jane 25 Doe 3 can participate in this litigated effort to vindicate the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011340