Deposition excerpt where witness claims he could produce exonerating documents within an hour

av won num Fs WN EF wo aon nub WN FE NNNNNNPREFP PP RP PRP FP RP WMPBWNF Ow ATH UY Bw NE OO often than we usually say. MR. SCAROLA: Yes, sir. BY MR. SCAROLA: Q. In interviews on January 4 and January 5, you claim to have completed the necessary work to identify documents exonerating you within an hour after learning of the accusations that were made, correct? A. 1 don't remember having said that. But within a minute, I had clear knowledge that every document in the world would exonerate me because I knew for absolute certainty that every aspect of her allegation was totally false. That's why I challenged the other side to produce videos, to produce photographs. I knew that there could be no evidence inculpating me because I knew I was innocent. So I knew that all of my records would prove that. Facts are facts. And I just wasn't in any contact or any sexual contact with [REDACTED], and I knew with absolute certainty that the facts would completely exonerate me. And if your clients had just called me, at the courtesy of simply calling me, I would have been able to point them to Professor Michael Porter of the Harvard Business fo On HM fF WN NNN NNN EH HM eB bb pp pp ob WN FO © ON A MB WN HO A. Where? Where? Can you point to that? BY MR. SCAROLA: Q. Well, I'm asking you, sir, based upon your superb memory whether you remember having said — MR. SCOTT: No, we're going to do -- BY MR. SCAROLA: Q. - on Jan -- MR. SCOTT: He's going to take a moment to review the transcript and -- and that's -- any witness is entitled to do that. So why don't we take a break, he'll review transcript and we'll come back? We've been going an hour -- MR. SCAROLA: Because I haven't asked him a question about the transcript. MR. SCOTT: You've asked -- MR. SCAROLA: I'masking him a question about his recollection. MR. SCOTT: Based upon what he said in the transcript. MR. SCAROLA: No, I'm asking him whether he has a recollection of having made public statements that within an hour, he had gathered the documents that proved his innocence, exonerated him. 262 School. I would have been able to -- to alert them to the Ashes. I would have been able to tell them that | keep little black books which have all of my travel information. Although they were in the basement of Martha's Vineyard, | would have been happy to go up and get them. If they had just simply called me, I would have been able to persuade them without any doubt that these allegations were false. If they needed any persuading because I believe, as | sit here today, that they knew they were false at the time -- certainly should have known, but I believe knew they were false at the time that they leveled them. Q. My question related to your gathering documents that you claim exonerated you -- A. That's right. Q. --and your public statements were that within an hour, you -- A. Can you -- Q. -- had gathered the documents -- MR. SCOTT: Listen to the question. BY MR. SCAROLA: Q. -- you had gathered the documents that exonerated you, correct? MR. SCOTT: You can refer. fo On nm fb WN FE NNNNN NPP FP FP RP PP OF PB UP wWNnNEF OM MAYH MH BwWNEH OO BY MR. SCAROLA: Q. Do you remember having made those statements? A. I donot, but it's true. I was able to gather documents literally within an hour. I was able to call Tom Ashe. He was able to access his daughter's journal notes that I had taught his daughter's class. 1 was able to find out where my other documents were. My wife made some phone calls immediately. We called the Canyon Ranch. We called and determined the dates of when I was in Florida. We called the Porters. We very, very, very quickly were able to gather information that conclusively would prove that she was lying about me having had sex with me on the island, in the ranch, particularly those two I was able to prove conclusively. And when a woman lies deliberately and willfully about two instances where she in great detail claims she had had sex, I think you can be clear that you should discount any other -- any other false allegations. MR. SCOTT: We've been going for an hour. Let's take a break for a few minutes. Then we 22 (Pages 261 to 264) www.phippsreporting.com (888) 811-3408 HOUSE_OVERSIGHT_010804