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that Edwards and Cassell made in this other lawsuit are somehow

binding on Ms. Giuffre. Edwards and Cassell had separate legal counsel, Florida attorney Jack Scarola. Whatever was going on in that case isn't binding on Ms. Giuffre.

Under the relevant rules, an attorney's statements are

binding on a client only on a matter within the scope of the relationship. And this was vindicating separate professional interests, this was not vindicating some interest of

Ms. Giuttre.

So for all those reasons, we ask that the defamation

litigation between Dershowitz and Edwards and Cassell be

excluded. Of course, you have the separate issue of Dershowitz

in front of you already.

Let me turn then to point number 19. Here again, we

have a narrow issue presented to your Honor. We are asking

that you exclude Judge Marra's ruling on the joinder motion. As your Honor is well aware, the triggering event in this case was when Ms. Giuffre, then known as Jane Doe Number 3, filed a motion to join Jane Doe 1 and Jane Doe 2 in the Florida pro

bono Crime Victims Rights action.

Now, Judge Marra denied that motion to join, but at

the same time he said, "The reason I'm denying the motion to

join is you can participate in the case in other ways without

being a formal party." He cited, and I quote, "Of course, Jane

Doe 3 can participate in this litigated effort to vindicate the

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

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