Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 3 of 34 records that I couldn’t have been in these places. The woman is a serial liar. If [Cassell and Edwards] had done that investigation, they would have come to the same conclusion.”! Similarly, on January 8, 2015, on the Greta van Susteren show on FOX, Dershowitz claimed: “Now I can prove through documentary evidence that I was never at the times and places she [Jane Doe No. 3] alleges she had sex with me.” Yet despite having publicly claimed to have “all kinds of records” and “documentary evidence” that “prove” Jane Doe No. 3 is lying, Dershowitz has yet to produce a single document to this Court. Dershowitz’s intransigence is not limited to this case, as he has also refused to comply with discovery requests in a parallel defamation action in state court. His refusal has led to a pending motion to compel. See Plaintiffs Motion to Compel Production of Documents, Edwards v. Dershowitz, No. CACE 15- 000072 (Feb. 23, 2015) (attached as Exhibit 1) (“despite having had 45 days to gather materials that allegedly provide ‘absolute proof’ than he has never even met Jane Doe No. 3 — and despite having told numerous media sources that he had already collected such information — Dershowitz has provided none of these documents . . . .”).? The Court should draw the obvious inference that Dershowitz, despite making broad claims to the media, has no such evidence to produce — because Jane Doe No. 3’s allegations are true. ' hittp://video.foxbusiness.com/v/397663067600 1/alan-dershowitz-the-woman-is-a-serial- liar/? - sp=show-clips. * http://radio.foxnews.com/2015/01/08/greta-alan-dershowitz-this-time-its-personal/. > Jane Doe No. 3 explained in her earlier response that the Court should not allow Dershowitz to intervene here because he can protect his (alleged) reputational interests in the pending defamation action. DE 291 at 11-12). The Court may be interested to learn that Dershowitz has recent