Case 1:19-cv-03377-LAP Document 36-4 Filed 07/03/19 Page 5 of 6 43, During the lawsuit, Mr, Edwards and I realized that Ms. Giuffre would need separate legal counsel, apart from us, when she became a witness, As a result, we requested and helped to arrange for Ms. McCawley to provide that separate representation, 44. I recall that at some point during the lawsuit, Mr. Dershowitz met with Mr. Boies in an eftort to persuade Mr, Boies of his innocence of abusing Ms. Giuffre. While I was not present at that meeting, it was my understanding from later events that Mr. Boies did not find Dershowitz’s claims of innocence to be persuasive, particularly given that Dershowitz repeatedly made statements that were demonstrably untrue and apparently deliberate lies, 45. Ultimately, Mr. Edwards and I agreed to settle our defamation lawsuit against Mr. Dershowitz. The terms of the settlement were confidential and nothing in this affidavit should be construed as any disclosing confidential terms of that settlement. 46. That said, I can report that, contemporaneously with settling the case, my attomey, Jack Scarola, filed a Notice of Withdrawal of Motion for Partial Summary Judgment in which he responded to a public distortion made prominently by Mr. Dershowitz. Mr. Dershowitz claimed publicly that the word “mistake,” contained in a jointly agreed public statement issued by him and us at the ime of settlement, showed that we had supposedly exonerated him of the charges made by our client, Ms, Giuffre. To help keep the record from being distorted, Mr. Scarola included the following accurate statement: In the event that the noticed withdrawal is determined to be subject to Court approval, the Plaintiffs would show in support of this notice that Edwards and Cassell continue to represent Virginia Giuffre in separate pending matters, and shall continue to advance her legitimate legal interests in those matters. As expressly understood by the parties upon the execution of the Confiden