DS9 Document EFTA00615583

462 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, vs. ALAN M. DERSHOWITZ, Defendant. VIDEOTAPE CONTINUED DEPOSITION OF ALAN M. DERSHOWITZ VOLUME 4 Pages 462 through 647 Tuesday, January 12, 2016 1:05 p.m. - 4:45 p.m. Stenographically Reported By: Kimberly Fontalvo, RPR, CLR Realtime Systems Administrator www.phi sre orting.com EFTA00615583 463 1 APPEARANCES: 2 On behalf of Plaintiffs: 3 4 5 SEARCY, DENNEY, SCAROLA BARNHART & SHIPLEY, P.A. 6 7 8 On behalf of Defendant: 9 COLE, SCOTT & KISSANE, P.A. Dadeland Centre II - Suite 1400 10 I II. P IRIR 11 12 : , . (Via phone) il 13 --an -- 14 SWEDER & ROSS, LLP 15 BY: KENNETH A. SWEDER, ESQ. 16 17 --and-- 18 WILEY, REIN 19 BY: RICHARD A. SIMPSON, ESQ. 20 21 22 23 24 25 www.piiiiiiiiiiiiir.com EFTA00615584 464 1 APPEARANCES (Continued): 2 3 On behalf of Jeffrey Epstein: 4 5 Sligi BY: DARREN K. INDYKE, ESQ. (Via phone) 6 7 On behalf of 8 BOIES, SCHILLER & FLEXNER, LLP 9 BY: SIGRID STONE MCCAWLEY, ESQ. 10 11 12 ALSO PRESENT: 13 Edward J. Pozzuoli, Special Master 14 Sean D. Reyes, Utah Attorney General Office 15 Travis Gallagher, Videographer 16 17 18 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615585 465 1 INDEX 2 3 Examination Page 4 5 VOLUME 4 (Pages 462 - 647) 6 7 Certificate of Oath 645 Certificate of Reporter 646 8 Read and Sign Letter to Witness 647 Errata Sheet (forwarded upon execution) 648 9 10 PLAINTIFF EXHIBITS 11 12 No. Page 13 19 Proposed Joint Letter to the Special 501 Master 14 20 Document reflecting entry for Bands, 548 15 Doug 16 21 562 17 18 22 Letter dated Jul 6 2007 from Gerald 612 B. Lefcourt to First 19 Assistant U.S. torney an o hers 22 pages 20 23 Document titled NewsRoom/Alan 623 21 Dershowitz to talk in Alburquerque 22 24 628 23 24 25 www.phi sre orting.com EFTA00615586 466 1 VIDEOGRAPHER: Going back on the record. 2 The time is approximately 1:05 p.m. 3 MR. INDYKE: This is Darren Indyke. If it 4 would be okay with everyone, I would like to 5 clarify a couple of points for the record. 6 SPECIAL MASTER POZZUOLI: Go ahead. 7 MR. INDYKE: First, I apologize for the 8 spotty reception during the morning session. I 9 was having difficulty hearing you folks, and I 10 think you were having some difficulty hearing 11 me. I think I've corrected it, but if I could 12 ask if you could move the mic closer to him 13 somehow or if I let you know that I can't hear, 14 if somebody could just speak up. 15 MR. SCAROLA: Did we turn that speaker 16 volume up? 17 MR. SIMPSON: Let's turn up the volume. 18 MR. INDYKE: Secondly, as to the argument 19 that work product belongs to the attorney and 20 not the client, I want to make sure that it's 21 clear that we disagree with that vehemently. 22 We believe that it is a client's every bit 23 as much as an attorney's and an attorney has no 24 right to waive that privilege over the 25 objection of a client. If that were true, www.phi sre orting.com EFTA00615587 467 1 there would be nothing improper with an 2 attorney publishing his entire case file over 3 the objection of his client with the exception 4 of communications back and forth between 5 attorney and client. Strategies, witnesses, 6 things like that could be disclosed over the 7 objection of a client, and that's just not the 8 case. 9 So for the record, Mr. Epstein reasserts 10 the work product privilege and would continue 11 do so. And I would instruct Mr. Dershowitz not 12 provide any response to any question that would 13 require Mr. Dershowitz to invade that 14 privilege. 15 Third, I guess as to the joint defense 16 agreement, it is our position that any party to 17 the joint defense agreement may assert it, and 18 it doesn't require disclosure of all parties to 19 the agreement in order for the assertion to be 20 valid. 21 I would note that disclosure of the 22 parties to a joint defense agreement are often, 23 by the terms of a joint defense agreement, 24 subject to confidentiality and, thus, protected 25 by the privilege. www.phi sre orting.com EFTA00615588 468 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 And I would also point out that it's not necessary for a person to be a party to a joint defense agreement for the communications with that person by a lawyer who is making those communications on behalf of the client party to the agreement to be subject to the joint defense agreement. And while we need to do some more background research to get the full details of the joint defense agreement, I would -- for those reasons, to the extent that any disclosure in response to any questions posed to Mr. Dershowitz would require Mr. Dershowitz to invade that joint defense agreement, we would instruct -- we would object and instruct that Mr. Dershowitz not respond. I think covers everything that I have. SPECIAL MASTER POZZUOLI: Let's proceed. MR. SCAROLA: Before we Thank you. proceed, I that want to note for the record that the various transcripts of statements made by Mr. Dershowitz that had been requested during the earlier session of the deposition were marked as Exhibit Number 1 to the prior www.phi sre orting.com EFTA00615589 469 1 sessions of Mr. Dershowitz's deposition. 2 I believe that everything that was 3 referenced has been disclosed. To the extent 4 that opposing counsel identifies anything that 5 is not included in Composite Exhibit Number 1 6 previously marked, we would be happy to provide 7 a copy of that as soon as a copy -- 8 MR. INDYKE: Is that Mr. Scarola? 9 MR. SCAROLA: It is, yes. 10 SPECIAL MASTER POZZUOLI: Hang on. Speak 11 up a little bit, Jack. 12 MR. SCAROLA: Certainly. As soon as a 13 copy that does not include work product 14 notations is available, and the portions of 15 statements made by Mr. Dershowitz not included 16 in Exhibit Number 1 are identified to us, we 17 will provide those. 18 MR. SCOTT: I think what we most want, 19 Jack, are the -- I think we have one 20 transcript, but I think there's another 21 transcript of the bench and Bar that we need. 22 MR. SCAROLA: There are multiple 23 transcripts included in Exhibit Number 1. 24 MR. EDWARDS: If there are transcripts 25 that you need that are not included in Exhibit www.phi sre orting.com EFTA00615590 470 1 Number 1, tell me. I'll get them to you, and 2 I'll get them to you tomorrow since we're here 3 again. 4 MR. SCAROLA: I just want the record to 5 reflect that I believe that everything that 6 we've made reference to is included in Exhibit 7 Number 1. If I'm incorrect in that regard, you 8 let us know what it is, we'll give it to you. 9 SPECIAL MASTER POZZUOLI: Darren, anything 10 on your end? You okay? 11 MR. INDYKE: Yep. 12 SPECIAL MASTER POZZUOLI: I would welcome 13 the parties just to get together to make sure 14 they have a complete set of what they need, and 15 we'll go from there. 16 MR. EDWARDS: Absolutely. Just for the 17 record, my only real objection was not turning 18 over what I had marked and my work product. 19 SPECIAL MASTER POZZUOLI: I understood. 20 MR. EDWARDS: I'll get everything to him 21 tomorrow. 22 SPECIAL MASTER POZZUOLI: I took it that 23 way. 24 BY MR. EDWARDS: 25 Q. Going back to testing the credibility of www.phi sre orting.com EFTA00615591 EFTA00615592 472 1 A. I imagine there would be if there were 2 videotapes. I've always said from the beginning, I 3 hope there are videotapes of every moment in 4 life, because they would exculpate 5 me completely. So I hope there are videotapes. 6 Q. Aren't you aware that there were 7 videotapes that were taken within your client 8 Jeffrey Epstein's various homes? 9 MR. INDYKE: Objection. Work product, 10 11 12 13 14 15 16 Q. Well, the statement was -- which I was not 17 going there. The statement was, if there are 18 videos, I want them all out there? 19 A. Absolutely. 20 Q. So, isn't it true that you know that there 21 were indeed videos taken from within your client's 22 various homes? 23 MR. INDYKE: Same objection. 24 BY MR. EDWARDS: 25 Q. Privileged or nonprivileged. attorney-client. Common interest. SPECIAL MASTER POZZUOLI: Carve out the privileged issue and non-privileged, if he gained information through a nonprivileged source. BY MR. EDWARDS: www.phi sre orting.com EFTA00615593 473 1 MR. SCOTT: Asked and answered in the last 2 depo. 3 A. I hope there were videos. I hope there 4 are videos of every moment of ' life 5 from the time she allegedly met Jeffrey Epstein to 6 the time she left. I hope there were videos in 7 every bedroom. I hope there were videos in every 8 massage room. I hope there are videos all over. 9 And from day one, I categorically stated 10 that there could be no photograph, no video that 11 would demonstrate that what she said was true, 12 because I knew it was false. She knew it was false. 13 And you knew it was false. 14 BY MR. EDWARDS: 15 Q. In representing a client, don't you try to 16 determine or ascertain what evidence does exist that 17 may incriminate or exonerate any particular client? 18 A. Of course. 19 Q. Okay. In making that inquiry in this 20 case, haven't you learned that there are -- 21 SPECIAL MASTER POZZUOLI: Which case? 22 BY MR. EDWARDS: 23 Q. In the case in which you represented 24 Jeffrey Epstein, haven't you learned that there were 25 video recordings taken from within Jeffrey Epstein's www.phi sre orting.com EFTA00615594 474 1 various homes as well as his airplane? 2 MR. INDYKE: Objection, same objection. 3 Instruct him not to answer. 4 A. I hope there were. 5 BY MR. EDWARDS: 6 Q. Will you then assist us 7 A. Yes. 8 Q. -- in obtaining those videos from your 9 client? 10 A. I will assist you in getting any possible 11 videotapes of r any of the 12 13 made. I would be thrilled to have videos of every 14 moment of my life during that period of time, and 15 16 17 18 19 20 21 Mr. Epstein is not waiving any of his 22 objections as to any such information to the 23 extent that it exists. 24 BY MR. EDWARDS: 25 Q. Okay. Well, this video or photograph -- locations where the false accusation against me was every moment of her life. Because they would prove conclusively that which I know to be conclusively false, namely that she made up the stories about me. Q. Okay. Just so I understand your agreement, is that -- MR. INDYKE: Just so we're clear, www.phi sre orting.com EFTA00615595 475 1 if there are videos or photographs of that have been taken or recorded from 3 Jeffrey Epstein's home, is that -- is that evidence 4 that you will assist us in obtaining? 5 A. I will try my best to try to get every 6 possible 7 MR. INDYKE: Objection. 8 A. -- photograph -- I'm entitled to say what 9 I'll try to best to do. I will try my best to get 10 every possible video, photograph, and any other 11 piece of objective evidence because I know it will 12 all completely prove beyond any doubt that I wasn't 13 there. 14 BY MR. EDWARDS: 15 Q. And if that information has already 16 exchanged hands -- that evidence has already 17 exchanged hands from Jeffrey Epstein's hands to the 18 hands of his attorneys, as part of their work 19 product, would you agree to waive your work product 20 privilege to produce that evidence? 21 MR. SCOTT: Objection. 22 MR. INDYKE: Objection. 23 A. I don't have any such evidence. I wish I 24 did. 25 www.phi sre orting.com EFTA00615596 476 1 BY MR. EDWARDS: 2 Q. With respect to the search warrant that 3 was executed on Jeffrey Epstein's house, isn't it 4 true that just before that search warrant was 5 executed, the -- Jeffrey Epstein's legal team 6 ordered that three computers be removed from Jeffrey 7 Epstein's home that contained pornographic images, 8 including those of 9 A. I made no such order. 10 MR. INDYKE: Same objection. And instruct 11 not to answer. 12 BY MR. EDWARDS: 13 Q. I didn't ask if you made the order. Isn't 14 it true that that occurred? 15 MR. INDYKE: Same objection. 16 MR. SIMPSON: Darren? 17 SPECIAL MASTER POZZUOLI: I'm not so sure 18 you can waive that objection. 19 A. I wish I could. 20 BY MR. EDWARDS: 21 Q. Didn't the U.S. Attorney's Office issue 22 grand jury subpoenas to the investigators that were 23 working on Jeffrey Epstein's behalf and were holding 24 those computers, and those grand jury subpoenas 25 outstanding at the time that the case resolved? www.phi sre orting.com EFTA00615597 477 1 A. All I can say -- 2 MR. INDYKE: Same objection and 3 instruction. 4 A. -- is I wish every video, every computer, 5 I wish everything that would show where was had been turned over and would be turned 7 over. 8 MR. SCAROLA: Mr. Dershowitz's repeated 9 comments about what he wishes would happen are 10 an indirect statement that if he could answer 11 the questions, the responses that he would give 12 would be favorable to him and would exonerate 13 him. 14 His wishes are not the subject of the 15 inquiry. And every occasion on which he 16 expresses a wish and refuses to give an answer 17 is unresponsive to the questions that are being 18 asked, and should be stricken. 19 They also constitute a waiver to the 20 extent that they imply that if the question 21 could be answered, the answer would be 22 favorable. 23 I would ask you to instruct 24 MR. INDYKE: And to the extent that they 25 imply a waiver -- www.phi sre orting.com EFTA00615598 478 1 SPECIAL MASTER POZZUOLI: Hang on a 2 second. Let him finish. 3 MR. INDYKE: I apologize, Mr. Scarola 4 MR. SCAROLA: That's quite all right, 5 thank you. 6 I know that over the speakerphone, it's 7 difficult, and I take no offense to the 8 interruption. I know it was inadvertent. 9 But I would ask that the witness be 10 instructed to discontinue that improper 11 assertion of statements of opinion when no 12 opinions are being requested. 13 SPECIAL MASTER POZZUOLI: Counsel, do you 14 have a response? I think Mr. Scarola is done. 15 MR. INDYKE: My response is to the extent 16 that you're attempting to imply anything 17 from -- imply a waiver from Mr. Dershowitz, 18 Mr. Epstein does not waive, and instructs 19 Mr. Dershowitz that he can make no such waiver. 20 THE WITNESS: I have not refused to 21 answer. 22 SPECIAL MASTER POZZUOLI: Hang on one 23 second. Let me say this: I would suggest that 24 I don't take such inference that he's waiving 25 based upon his general statements. www.phi sre orting.com EFTA00615599 479 1 What -- we have been down a little bit of 2 this road this morning on trying to get to what 3 appears to be privileged information or 4 information that -- or activity that was 5 undertaken or not undertaken during the course 6 of the representation, the relationship the 7 attorney-client relationship between 8 Mr. Dershowitz and Mr. Epstein. 9 And at this point, based upon the 10 objection, I will uphold the objection and 11 we'll move forward. 12 MR. SCAROLA: The second part of my 13 request is that Mr. Dershowitz be instructed to 14 refrain from expressing a desire to answer 15 questions. It's not responsive. It implies 16 that if he could answer, the answers would be 17 favorable. 18 The implication is improper, and the 19 insertion into the record of the implication is 20 improper. If he can't answer the question, he 21 should simply say he cannot answer based on 22 privilege. 23 THE WITNESS: Can I respond? 24 SPECIAL MASTER POZZUOLI: No. Let me 25 respond. www.phi sre orting.com EFTA00615600 480 1 I think that's appropriate. I do actually 2 agree with Mr. Scarola in this respect. I do 3 think that you should be responsive 4 specifically to the question if you can. 5 Where you can't, you state you can't. I 6 believe that the record is now full of your 7 views on some of this in a generic way, and so 8 with that said, I would ask that you be more 9 pointed with your answers. 10 THE WITNESS: I appreciate that. I just 11 want to comment that I did not ever refuse to 12 answer any of those questions. It was 13 instructed not to answer any of those 14 questions. 15 SPECIAL MASTER POZZUOLI: I do understand 16 that. For purposes of some efficiency here, I 17 would like to get through this within the time 18 alloted. 19 MR. EDWARDS: Me, too. Thank you. 20 BY MR. EDWARDS: 21 Q. Is there any nonprivileged information 22 which would demonstrate whether 23 statement that she was flown on Jeffrey Epstein's 24 plane while underage was true or false? 25 A. I'm sure there must be, but I don't have www.phi sre orting.com EFTA00615601 481 1 it in my mind right now, so I can't answer that 2 question. 3 Q. The flight logs were previously marked 4 as -- 5 MR. SCAROLA: Exhibit 7. 6 BY MR. EDWARDS: 7 Q. -- as Exhibit 7 to the deposition. I'll 8 show you pages from Exhibit 7 which indicate the 9 dates of the flight logs for those on the phone 10 November 2002 through January -- sorry, 11 November 2000 through January 2001 and January 2001 12 through February 20th, 2001. 13 SPECIAL MASTER POZZUOLI: Counsel? 14 MR. SCOTT: Okay. 15 A. Yes, I see the flights that you have 16 marked in green. 17 BY MR. EDWARDS: 18 Q. Do the flight logs indicate II~sa passenger on Jeffrey Epstein's plane 20 with Jeffrey Epstein? 21 A. Well, the first one I look at does not. 22 It has and Although it's 23 underlined, it doesn't suggest 24 The second one does say ■ . And the fourth and fifth ones say www.phi sre orting.com EFTA00615602 482 1 . And on the next page, two of them say 2 , yes. 3 Q. These in the year 2000 and early 2001; is 4 that correct? 5 A. I can't see dates. I see 2001. I see 6 November 2000. Could you remind me of ' birthday. 8 Q. 9 A. So she would be I at this 10 time. 11 Q. So she's traveling as a passenger under 12 the age of 18? That's my question. 13 A. Under the age of 18, but the age of 14 consent in numerous places that she flew to were 17 15 and 16. So New York, the age is 17, to my 16 recollection. And in New Mexico, I think it's 17. 17 And the Virgin Islands, I think it's 16. So the 18 answer to the question is she underage might well be 19 no. 20 Q. My question was, is there nonprivileged 21 information that would indicate the truth or falsity 22 of her statement that she traveled on Jeffrey 23 Epstein's airplane with Jeffrey Epstein while under 24 the age of 18? 25 A. I do not know of any statement that she www.phi sre orting.com EFTA00615603 483 1 said -- may have said it, but I don't have in my 2 mind any statement that says below the age of 18 as 3 distinguished from when she was underage. So you 4 would have to show me. If the statement was below 5 the age of 18, that would be correct. If the 6 statement would be underage, that would be more 7 questionable. 8 Q. Do you know the purpose for which she was 9 traveling with Jeffrey Epstein during the flights 10 indicated on those logs? 11 A. I do not. 12 MR. SCOTT: Privileged. 13 MR. INDYKE: Objection, work product, 14 attorney-client, common interest. 15 BY MR. EDWARDS: 16 Q. Your answer is "I do not"? 17 A. I do not. 18 Q. You have not ascertained from any source, 19 is what you're telling us, the purpose for her 20 travels with Jeffrey Epstein, correct? 21 MR. INDYKE: Objection. Same objection 22 and instruction. 23 BY MR. EDWARDS: 24 Q. You are unable to answer, or you have not? 25 A. I have been instructed not to answer. www.phi sre orting.com EFTA00615604 484 1 Q. I misunderstood you. I thought you said 2 earlier "I have not," indicating that you don't know 3 the purpose? 4 A. I said that in answer to one question. 5 You've asked me other questions. 6 Q. Is there a legitimate purpose for her 7 being 17 years old, traveling with Jeffrey Epstein? 8 MR. SCOTT: Objection, argumentative. 9 MR. INDYKE: Objection. Same objection, 10 same instructions. 11 BY MR. EDWARDS: 12 Q. Isn't it a federal crime to knowingly 13 transport an individual who has not attained the age 14 of 18 years in interstate commerce with the intent 15 that that individual engage in prostitution or in 16 any sexual activity? 17 A. I haven't read the statute clearly, but I 18 think that's an accurate paraphrase of my 19 understanding of the law, yeah. 20 Q. Would you agree that that flight log in 21 front of you indicates a federal crime was being 22 committed against at the time when 23 she has said a federal crime was being committed 24 against her? 25 A. Oh, absolutely not. www.phi sre orting.com EFTA00615605 485 1 MR. INDYKE: Objection. 2 A. Does not prove a federal crime. 3 MR. INDYKE: Same objection, same 4 instruction. 5 BY MR. EDWARDS: 6 Q. So that goes back to my last question. 7 What is, then, the legitimate reason that causes 8 that flight to fall outside of this criminal statute 9 that I just read to you? 10 MR. INDYKE: Same objection, same 11 instruction. 12 A. I can give this answer. My understanding 13 of federal law imposes the burden of proof on the 14 prosecution to demonstrate one of the illicit 15 purposes, and this does not satisfy that burden of 16 proof. So this would not prove that a federal crime 17 occurred. It would prove one element of that crime. 18 BY MR. EDWARDS: 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615606 486 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 BY MR. EDWARDS: SPECIAL MASTER POZZUOLI: Move forward. 22 BY MR. EDWARDS: 23 Q. Let me try to understand that which you 24 are explaining right now, which is are you saying 25 that if she was traveling on Jeffrey Epstein's www.phi sre orting.com EFTA00615607 487 1 airplane while underage for the purposes of sex and 2 or prostitution, that -- 3 MR. INDYKE: Same objection, same 4 instructions. 5 BY MR. EDWARDS: 6 Q. -- she was not being sexually trafficked 7 or would not be a victim of that statute? 8 MR. INDYKE: Same objection, same 9 instruction. 10 MR. EDWARDS: I'm asking a hypothetical 11 now based on his last statement. 12 MR. SCOTT: That's not a hypothetical. 13 SPECIAL MASTER POZZUOLI: That's not how 14 you framed it. 15 BY MR. EDWARDS: 16 Q. Let me reframe it, then. 17 Assuming that -- I'll give you a 18 hypothetical based on what you say her friends have 19 told you, which is that she is free to leave while 20 being taken across state lines by Jeffrey Epstein. 21 This is the hypothetical. And being used for sexual 22 purposes. Is she, in that hypothetical, not a 23 victim to sexual trafficking? 24 MR. SCOTT: Objection to form, 25 speculation, argumentative. Can you answer www.phi sre orting.com EFTA00615608 488 1 that? 2 A. I can answer it. Since you gave me a 3 hypothetical, as a law professor for 50 years, I 4 would give this as a hypothetical to my class. I 5 would ask my students do you think it's trafficking, 6 do you think a woman has been trafficked when she 7 voluntarily, below the age of consent in some 8 states, above the age of consent in other states, 9 when she voluntarily engages in sexual conduct for 10 money, free to leave at any time. 11 I think it would be an interesting 12 classroom discussion about whether that constitutes 13 trafficking. 14 That's a different question from whether 15 or not that would violate the statute. That would 16 violate the statute. But your question is, would it 17 constitute trafficking. That would be a very 18 interesting law school hypothetical. 19 BY MR. EDWARDS: 20 Q. In your opinion, does it constitute 21 trafficking? 22 A. I think the word "trafficking" is 23 overused, and I think should be reserved for the 24 kinds of people who I have enormous sympathy for, 25 people who have no choice, no options, whose www.phi sre orting.com EFTA00615609 489 1 passports have been taken away, who have been forced 2 and coerced in some way to engage in sexual conduct. 3 And I think it begins to weaken the very 4 important term "trafficking" when it's applied to a 5 volunteer, close to her 18th birthday who was 6 enjoying and spending money and has the option of 7 leaving. I know that Sigrid McCawley is shaking her 8 head, but that's my honest opinion. 9 Q. Does your answer to the hypothetical 10 change if we rewind time 11 when she's 15 or 12 16 years old? Meaning are you making a distinction 13 because she's 17 as opposed to 16 or 15? If so, 14 what's the cutoff? 15 A. Well, I think that age is relevant 16 MR. INDYKE: For my clarification, this is 17 all hypothetical? 18 MR. SCAROLA: Yes, it is. 19 A. Age is one of the relevant factors. It's 20 not the only relevant factor. It's one of the 21 relevant factors. That's why your hypothetical was 22 17, almost 18, 17 and a half. 23 BY MR. EDWARDS: 24 Q. Let's get that right. That's when, 25 www.phi sre orting.com EFTA00615610 490 1 A. We're talking about 2 SPECIAL MASTER POZZUOLI: We're still 3 operating under the hypothetical? 4 MR. EDWARDS: We are. I thought he said 5 that my hypothetical was almost 18. Which in 6 this hypothetical, she turns 7 8 THE WITNESS: =, the same year. 9 BY MR. EDWARDS: 10 Q. Was she lying when she said that 11 Epstein -- 12 SPECIAL MASTER POZZUOLI: Are we now done 13 with the hypothetical? 14 MR. EDWARDS: Yes, we are. 15 BY MR. EDWARDS: 16 Q. engaged in sex with many underage 17 girls? Was she lying when she said that? 18 MR. INDYKE: Same objection, same 19 instructions. 20 A. I can only say this. You -- 21 MR. SIMPSON: Was there an instruction? 22 A. There was an instruction, but I can answer 23 without that. 24 You have accused me of having sex with 25 many underage girls -- www.phi sre orting.com EFTA00615611 491 1 MR. EDWARDS: I move to strike this as 2 nonresponsive to my question. 3 A. -- based on no evidence whatsoever. 4 MR. EDWARDS: I want a ruling on the 5 Motion to Strike. 6 SPECIAL MASTER POZZUOLI: Let me hear the 7 rest of it. 8 A. So when you say "many," I need to know 9 with some precision what you have in mind. 10 SPECIAL MASTER POZZUOLI: I'll strike the 11 first part of it, the first part of his answer. 12 And if you can assist him in defining "many." 13 BY MR. EDWARDS: 14 Q. Sure. You do know Bob Josefsberg, 15 correct? 16 A. I've known him since 1959. 17 Q. And you are aware that he represented, I 18 believe, more than 15 girls who claimed to have been 19 victims of Mr. Epstein in this case, aren't you? 20 A. I recommended him for that job because I 21 think so highly of him. 22 Q. And in his Complaints, are you aware that 23 he's made the allegation that Defendant Epstein has 24 a sexual preference for underage minor girls? Are 25 you aware of that? www.phi sre orting.com EFTA00615612 492 1 MR. SCOTT: Just for the record, object to 2 the relevancy of all of this. 3 A. I'm not aware of that. 4 MR. INDYKE: Just for the record, to the 5 extent that Alan's answer requires him to 6 invade privilege, I would object and instruct 7 him not to answer. 8 SPECIAL MASTER POZZUOLI: Within the 9 confines of the privilege objection, if you can 10 answer. 11 A. I'm not aware that he said that. I 12 haven't read his pleadings. 13 BY MR. EDWARDS: 14 Q. Okay. Are you aware that in his 15 pleadings, he wrote "Defendant Epstein used his 16 resources and his influence over vulnerable minor 17 girls to engage in a systemic -- systematic pattern 18 of sexually exploited behavior"? 19 A. I'm not aware. 20 MR. INDYKE: Same objection, same 21 instruction. 22 A. I was not involved in that aspect of the 23 case. 24 BY MR. EDWARDS: 25 Q. You were not involved in the facts part of www.phi sre orting.com EFTA00615613 493 1 the case? 2 A. I was not involved in the compensation 3 part of the case. The part that Bob Josefsberg was 4 involved in, I was not involved in. 5 MR. INDYKE: Alan, just admonishment, 6 let's not go into the subject matter of your 7 representation, please. 8 BY MR. EDWARDS: 9 10 11 12 13 14 15 16 17 18 BY MR. EDWARDS: 19 20 22 23 24 25 www.phi sre orting.com EFTA00615614 494 1 question. 2 BY MR. EDWARDS: 3 Q. In 2009, when that Complaint and that 4 allegation was asserted, are you aware that Jeffrey 5 Epstein never refuted that allegation in any 6 pleading? 7 MR. INDYKE: Same objection, same 8 instruction. 9 BY MR. EDWARDS: 10 Q. Were you representing Jeffrey Epstein in 11 2009? 12 A. Not in connection with that case. And I 13 was not aware of what his response was, if any. 14 Q. Are you aware that after that allegation 15 was made by , that Jeffrey Epstein 16 paid money to settle her case? 17 MR. INDYKE: Same objection, same 18 instruction. 19 MR. SCOTT: Let me object to all the 20 relevancy of this. 21 A. My understanding is that the plea bargain 22 required him to make payments regardless of what his 23 views may have been, that he was absolutely required 24 to make those payments. He had no discretion. 25 That's my understanding. I may be wrong, but you www.phi sre orting.com EFTA00615615 495 1 can check the actual nonprosecution agreement, but 2 that's my understanding of what it said, that he 3 could not contest anything. 4 BY MR. EDWARDS: 5 Q. You were one of the attorneys that 6 represented Jeffrey Epstein in the negotiations with 7 the United States Attorney's Office, right? 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Right, along with MR. INDYKE: Same A. No, I don't think Kenneth Starr -- objection. Objection. you can object to that. These are people who are at the hearings, at the events with the U.S. Attorney. The people who were at the events representing Jeffrey Epstein is not privileged, included Roy Black, Ken Starr, Marty Weinberg, Jay Lefkowitz -- MR. SCAROLA: Not responsive. A. -- Jerry Lefcourt. BY MR. EDWARDS: Q. lawyers. A. I was one of them, yes. Q. I only asked if you were one of the The answer is yes? A. The complete answer is yes, but the rest of the people were part of the legal team. Q. I will ask you when I want somebody else's www.phi sre orting.com EFTA00615616 496 1 name. 2 Were you a part of the negotiations in 3 October of 2007 when the special matter was 4 selected? You remember that part? 5 A. Is the special master Josephsburg? 6 MR. INDYKE: Same objection, same 7 instruction. 8 BY MR. EDWARDS: 9 Q. Yes. 10 A. My recollection is that I was simply asked 11 for a recommendation, but I played no further role. 12 Q. Were you aware that there was a joint 13 letter to the special master created between Jeffrey 14 Epstein's attorneys and the United States Attorney's 15 Office describing the investigation? 16 MR. INDYKE: Same objection, same 17 instruction. 18 A. I'm not -- as I sit here today, I have no 19 recollection of that. 20 BY MR. EDWARDS: 21 Q. Was lying when she says 22 that while underage, she was made to massage Jeffrey 23 Epstein in the nude, while he masturbated? 24 A. I have no idea. 25 MR. INDYKE: Same objection, same www.phi sre orting.com EFTA00615617 497 1 instruction. 2 BY MR. EDWARDS: 3 Q. If I show you the proposed joint letter to 4 the special master, will it refresh your 5 recollection? 6 A. I want to add to the last question When 7 I say I have no idea, 8 9 10 11 MR. EDWARDS: Move to strike as 12 nonresponsive. 13 A. But that's relevant to standing naked and 14 being masturbated. 15 SPECIAL MASTER POZZUOLI: Move on to your 16 next question. 17 A. Yes. 18 BY MR. EDWARDS: 19 Q. When I am asking for nonprivileged 20 information or evidence that would give you the 21 ability to tell me whether is lying 22 when she says she had sex with Jeffrey Epstein while 23 underage, would you consider a joint letter crafted 24 between Jeffrey Epstein's lawyers and the United 25 States Attorney's Office to form the basis of that www.phi sre orting.com EFTA00615618 498 1 answer? Let me rephrase the question. 2 When I'm asking for nonprivileged 3 information that you may have to demonstrate the 4 truth or falsity of ' statement that 5 she was made to have sex with Jeffrey Epstein while 6 underage, would you consider the joint letter to the 7 special master evidence from which you could draw an 8 answer? 9 MR. SCOTT: Objection. 10 A. I would have to know more about it than 11 that. I would have to know the nature of the 12 letter, the reason it was sent. 13 BY MR. EDWARDS: 14 Q. Would you like to review the letter? Is 15 that going to help you? 16 SPECIAL MASTER POZZUOLI: Ask him if he's 17 seen the letter first. 18 BY MR. EDWARDS: 19 Q. You were part of the team that was mainly 20 negotiating with U.S. Attorney's Office, correct? 21 A. I was only negotiating the criminal part 22 of the case. 23 Q. Okay. I'm going to show you the letter, 24 and if you had nothing to do with it, tell me that. 25 If you've never seen it before, then tell me that. www.phi sre orting.com EFTA00615619 499 1 I guess my first question is, have you 2 seen it? 3 MR. INDYKE: I would object to that. 4 MR. SCOTT: I would like to make a request 5 for this depo and future depositions, if they 6 are going to show exhibits to a witness, I 7 think we should be -- have a copy of them. 8 We provided copies to you of all exhibits 9 we used during the deposition of your client. 10 And I think if you're going to pull out 11 exhibits and have one, you should have at least 12 copies for counsel, and I would agree to do the 13 same thing, rather than having to run and make 14 a copy and all the rest of it. 15 MR. EDWARDS: I wasn't ready for him to be 16 unfamiliar with his and his legal team's 17 correspondence. 18 MR. SCOTT: I understand, but you haven't 19 had any all day. So all I'm asking you, 20 Mr. Edwards, is that we have copies of exhibits 21 that you intend to confront the witness with. 22 That's -- as you pointed out, you've got all 23 the questions laid out, so you know where we're 24 headed. There's a note on here. Do you want 25 that on there? www.phi sre orting.com EFTA00615620 500 1 MR. EDWARDS: No. 2 MR. SCOTT: It's one of your cheat sheet 3 notes. I don't know if you really want that on 4 there. 5 MR. EDWARDS: It just says "Isn't this 6 nonprivileged?" 7 MR. SCOTT: Okay. It's still an exhibit 8 going into evidence, right? Without your 9 notes? 10 MR. SIMPSON: Can we get it marked? 11 THE WITNESS: This is a draft, not a 12 letter. 13 MR. EDWARDS: I said it's a proposed 14 letter. I read the title exactly. 15 (Thereupon, marked as Plaintiff Exhibit 16 19.) 17 A. This is not -- it's not familiar to me 18 except that what I said previously that as part of 19 the resolution of this case, Mr. Epstein agreed he 20 would not contest jurisdiction for the victims who 21 chose to sue him, et cetera, is consistent with my 22 memory, but I have no recollection of actually 23 seeing this draft, this proposed draft. 24 MR. SCOTT: That's number? 25 COURT REPORTER: Nineteen. www.phi sre orting.com EFTA00615621 501 1 BY MR. EDWARDS: 2 Q. Wouldn't you agree wasn't one of the listed victims to the 4 nonprosecution agreement? 5 A. If so, I was not aware of. 6 MR. INDYKE: Same objection, same 7 instruction. 8 BY MR. EDWARDS: 9 Q. As you sit here today, after having made 10 many statements about being a 11 serial liar -- 12 A. She is. 13 Q. -- you have no idea whether she was a 14 listed victim to the nonprosecution agreement? 15 MR. SCOTT: Objection, asked and answered. 16 MR. INDYKE: Same objection, same 17 instruction. 18 A. Right now, I have no recollection of 19 whether she was listed or not. 20 BY MR. EDWARDS: 21 Q. Okay. 22 A. I know that the FBI tried to speak to her 23 and she wouldn't speak to them is my recollection. 24 MR. SCAROLA: That's not responsive. 25 MR. EDWARDS: Not responsive. www.phi sre orting.com EFTA00615622 502 1 MR. SCAROLA: Move to strike. 2 SPECIAL MASTER POZZUOLI: That, I will 3 strike. Move forward. 4 BY MR. EDWARDS: 5 Q. Was lying when she says that 6 Jeffrey Epstein also had sex with a girl named 8 9 MR. INDYKE: Same objections, same 10 instruction. 11 MR. SCOTT: Can you answer that? 12 A. I've never heard that name. It's not 13 familiar to me at all. 14 BY MR. EDWARDS: 15 Q. Was lying when she says 16 she traveled to Jeffrey Epstein's island when 17 underage? 18 MR. INDYKE: Same objections, same 19 instruction. 20 BY MR. EDWARDS: 21 Q. By "underage," I mean under the age of 18. 22 A. I can only tell you I never saw her on the 23 island. I was on the island when she was not there. 24 I would love to know whole story she was 25 on the island -- www.phi sre orting.com EFTA00615623 503 1 MR. SCOTT: There's no question pending. 2 BY MR. EDWARDS: 3 Q. The two-page flight log exhibit, if we 4 look at January 22nd, 2001, and also 5 December 14th, 2000, can you look at those, and 6 I'll ask a question. 7 A. Sure. Give me the dates again. 8 January 16? 9 Q. Where it has the departing airport code 10 and 11 A. Yeah. 12 Q. -- where she's landing. 13 A. Right. 14 Q. TIST is the code for Virgin Islands, 15 correct? 16 A. I have no idea. Been to the Virgin 17 Islands once that I remember. 18 Q. You have been to Jeffrey Epstein's home on 19 the Virgin Islands, haven't you? 20 MR. SCOTT: He's already answered that. 21 A. I was with my wife and my daughter and 22 Professor 23 BY MR. EDWARDS: 24 Q. I don't mean to ask who you went with -- I 25 didn't mean to ask -- www.phi sre orting.com EFTA00615624 504 1 SPECIAL MASTER POZZUOLI: Hang on. Let 2 him finish his answer. I think this is 3 contextual. I'm okay with it. 4 A. And six months before 5 ever met Jeffrey Epstein. So I was never on the 6 island during the period of time that Jeffrey 7 Epstein knew 8 SPECIAL MASTER POZZUOLI: Go ahead. 9 BY MR. EDWARDS: 10 Q. My question was, how did you get to the 11 island? 12 A. Jeffrey Epstein sent a one-engine, small 13 plane with a 70-year-old pilot for me, my wife and 14 my daughter, and I regret to this day ever getting 15 on that plane. Flew us from Guadalupe to the Virgin 16 Islands, where I was picked up by a boat and taken 17 to Jeffrey Epstein's island where we had dinner with 18 Michael Porter and his wife and family and my wife 19 and my daughter, and stayed, as far as we remember, 20 for one night and left the next day. 21 Q. How did you get to Guadalupe? 22 A. Jeffrey Epstein flew us from Charleston, 23 South Carolina, where we were visiting Caroline, my 24 wife's mother, on an airplane that had a bathroom 25 that had only a little curtain. That's all I www.phi sre orting.com EFTA00615625 505 1 remember about it. 2 Q. What was the date of that trip that you're 3 describing that you took Jeffrey Epstein's island? 4 MR. SCOTT: If you know. 5 A. It was six months or eight months before 6 she ever met Jeffrey Epstein, so it would be 7 Christmas, around Christmastime, around Christmas 8 vacation of the year 1998, to my recollection. But 9 I would have to check. 10 When it is she met Jeffrey Epstein in that 11 summer, it was the winter before that. That's the 12 only time I've ever been on the island, so her 13 statement that she had sex with me on the island is 14 totally, categorically made up. 15 BY MR. EDWARDS: 16 Q. My question is, where is the flight log of 17 that trip that you just described? 18 A. Neither flight -- neither flight was on 19 Jeffrey Epstein's airplane. The flight that we went 20 from Charleston to Guadalupe, somebody owed Jeffrey 21 Epstein several hours on an airplane, so Jeffrey 22 borrowed his Learjet, it was a Learjet, borrowed his 23 Learjet, two or three hours on the Learjet because 24 it would have taken us ten hours to fly from 25 Charleston to Atlanta, Atlanta to Puerto Rico and www.phi sre orting.com EFTA00615626 506 1 2 3 4 5 6 Miami, and Miami or Puerto Rico to Guadalupe. So Jeffrey offered to use the credit he had with someone else on a Learjet to fly us to Guadalupe, and then used -- then rented -- it was $1,200, I remember seeing the bill, to fly the small airplane from Guadalupe. He was anxious for us to 7 see his newly bought -- relatively newly bought 8 island, and so we went there with my daughter and we 9 dug around in the sand and we had dinner with the 10 various professors and that. Then we left. 11 Q. So there are no flight manifests -- 12 A. I have no idea. 13 Q. -- for the trip that you just described? 14 A. I have no idea. There probably are, 15 probably on the Learjet is probably the manifest. 16 Q. In fact, in the statements that the flight 17 manifests will conclusively and demonstratively 18 exonerate you -- 19 A. That's true. 20 Q. -- where can we get the full flight 21 manifests so that we can review and make that 22 determination for ourselves? Do you know? 23 A. I assume -- 24 MR. INDYKE: Objection. 25 www.phi sre orting.com EFTA00615627 50 1 BY MR. EDWARDS: 2 Q. What we have here -- 3 MR. INDYKE: Attorney-client, work product 4 and common interests. 5 BY MR. EDWARDS: 6 Q. What we have here is only the fraction of 7 flights where Dave Rogers was one of the pilots. 8 Can you help us get the flight logs from Larry 9 Visosky, Larry Morrison, any of the flight logs from 10 the helicopters, et cetera? 11 A. I would love to. It would all show that I 12 wasn't on the plane. 13 MR. INDYKE: Same objection, same 14 instruction. 15 A. I will do everything in my power 16 MR. SCOTT: You can make any request you 17 want to through counsel, and we'll take them 18 up. 19 A. But I will do everything in my power to 20 get you every flight manifest. 21 SPECIAL MASTER POZZUOLI: Move forward. 22 MR. INDYKE: We do not waive any 23 objection. 24 MR. SCAROLA: And that request has been 25 made. www.phi sre orting.com EFTA00615628 508 1 A. Is that a question? 2 MR. SCOTT: No. Just Mr. Scarola 3 MR. EDWARDS: Just that we made a request 4 for production. 5 BY MR. EDWARDS: 6 Q. Was lying when she says that she 7 was taken to Jeffrey Epstein's home in New York 8 while underage? 9 A. I have no idea. 10 MR. INDYKE: Same objection, same 11 instruction. 12 BY MR. EDWARDS: 13 Q. Was lying when she says she was 14 taken to Jeffrey Epstein's ranch in New Mexico while 15 underage? 16 MR. INDYKE: Same objection, same 17 instruction. 18 A. I can tell you this. She's lying when she 19 said she met me at the ranch. So I cannot believe 20 anything she says about the ranch. 21 BY MR. EDWARDS: 22 Q. Was she lying when she says Ghislaine 23 Maxwell and Jeffrey Epstein used sex toys on her 24 when she was underage? 25 MR. INDYKE: Same objection, same www.phi sre orting.com EFTA00615629 509 1 instruction. 2 BY MR. EDWARDS: 3 Q. Was she lying when she says Jeffrey 4 Epstein and Ghislaine Maxwell made her dress up in 5 outfits for them? 6 MR. INDYKE: Same objection, same 7 instruction. 8 A. Well, I can but I do have some material 9 outside of the record on that. 10 BY MR. EDWARDS: 11 Q. Okay. 12 A. I know that Sigrid McCawley said that she 13 said that Leslie Wexner made her dress up -- 14 MS. McCAWLEY: I am going to object to the 15 extent that you are trying to reveal 16 conversations that were part of a settlement 17 discussion which the judge has already sealed 18 the record on and there is a pending motion for 19 sanctions. And if you're going to start 20 revealing that information, we're going 21 directly to the Judge Lynch. 22 A. I am going to start revealing -- 23 SPECIAL MASTER POZZUOLI: No, I'm going to 24 stop you -- 25 THE WITNESS: Let me tell you why. www.phi sre orting.com EFTA00615630 510 1 Because I didn't get that from Sigrid or from 2 David Boise. I got it from Leslie Wexner's 3 lawyer in a totally nonprivileged 4 communication. 5 SPECIAL MASTER POZZUOLI: Let me stop you. 6 I don't believe it's responsive to the question 7 that's pending, so let's move forward. 8 BY MR. EDWARDS: 9 Q. My question was, was she lying -- was 10 lying when she says Jeffrey Epstein 11 and Ghislaine Maxwell made her dress up in outfits 12 for them? 13 A. I can only say that that allegation has 14 been made regarding Leslie Wexner as well. 15 Q. It has nothing to do with my question. 16 MR. SCAROLA: Move to strike. 17 A. Leslie Wexner's lawyer regards that as a 18 full statement and, therefore, I can only assume 19 that it's a false statement when made about someone 20 else. I think that's relevant. 21 SPECIAL MASTER POZZUOLI: So with respect 22 to the -- 23 MR. EDWARDS: I'm moving to strike the 24 nonresponsive portion of that answer. 25 THE WITNESS: He opened the door. www.phi sre orting.com EFTA00615631 511 1 SPECIAL MASTER POZZUOLI: I do believe it 2 was nonresponsive in its entirety. Move 3 forward. Go ahead. 4 BY MR. EDWARDS: 5 Q. Do you know Jean-Luc Brunel? 6 A. No. 7 Q. Have you ever met him? 8 MR. INDYKE: Same objection, same 9 instruction. 10 A. I have no memory of ever meeting a man by 11 that name. 12 BY MR. EDWARDS: 13 Q. Do you know what his role was in Jeffrey 14 Epstein's life? 15 A. No. 16 MR. INDYKE: Same objection, same 17 instruction. Mr. Dershowitz, if you would let 18 me make my objections before you respond. 19 THE WITNESS: Right. 20 BY MR. EDWARDS: 21 Q. Was lying when she said 22 Jeffrey Epstein socialized with Bill Clinton during 23 the relevant time period? 24 MR. INDYKE: Same objection, same 25 instructions. www.phi sre orting.com EFTA00615632 512 1 A. My information is that 2 was lying when she said that she saw Bill Clinton on 3 Jeffrey Epstein's island. That's all I can comment 4 about with that. And she's lying about that. And 5 she's lying about how Bill Clinton got to the 6 island. 7 MR. EDWARDS: I move to strike the 8 Nonresponsive portion of the answer. 9 SPECIAL MASTER POZZUOLI: No, it's 10 relevant to what you asked. Move forward. I'm 11 not going to strike it. 12 BY MR. EDWARDS: 13 Q. I'm going to go back to the question until 14 I get an answer, though. 15 SPECIAL MASTER POZZUOLI: Go ahead. 16 BY MR. EDWARDS: 17 Q. That is, when said that 18 during the relevant time period, which we defined as 19 1999 through 2002 -- 20 A. Let's be clear. Around August of both of 21 those years, right? 22 Q. I think August of '99 through October of 23 2002. 24 A. September, I think it is. 25 Q. Okay. Was she lying -- was www.phi sre orting.com EFTA00615633 513 1 lying when she said Jeffrey Epstein 2 socialized with Bill Clinton during that time 3 period? 4 A. I don't know. 5 MR. INDYKE: Same objection, same 6 instruction. 7 BY MR. EDWARDS: 8 Q. And you have no nonprivileged information 9 that would provide you the answer to that? 10 A. I have nonprivileged information that 11 provides me that they socialized together at some 12 point. I don't know whether it was within that 13 timeframe at all. I know they went to Africa 14 together on a mission of goodwill, but I don't know 15 the date of that. So I can't tell you whether it 16 was 17 know 18 19 20 21 immediately disprove her statement that Bill Clinton 22 and Jeffrey Epstein socialized during that time 23 period? 24 A. I don't understand that question. 25 Q. No? in the period or outside the period. You may that; I don't. Q. Well, if Jeffrey Epstein and Bill Clinton associated, but only at some time period either before or after the relevant time period, it would www.phi sre orting.com EFTA00615634 514 1 SPECIAL MASTER POZZUOLI: I don't 2 understand the question either. If you can 3 rephrase the question, that would be helpful. 4 MR. EDWARDS: Sure. 5 BY MR. EDWARDS: 6 Q. If you -- do you know from nonprivileged 7 information whether Jeffrey Epstein and Bill Clinton 8 ever socialized? 9 A. Yes. 10 Q. Do you know the beginning -- when their 11 relationship began? 12 MR. INDYKE: Objection. Same objection, 13 same instruction. 14 SPECIAL MASTER POZZUOLI: Again, under 15 nonprivileged. 16 MR. EDWARDS: Under nonprivileged 17 information. 18 MR. SCOTT: Do you have any nonprivileged 19 information about that? 20 A. I remember having dinner at the home of 21 Caroline Kennedy and Ed Schlossberg with President 22 Clinton, and he basically asked me how Jeffrey was 23 doing, and led me to believe that he had some 24 relationship with Jeffrey. I don't remember whether 25 that dinner -- when that dinner was. I can probably www.phi sre orting.com EFTA00615635 515 1 find out. But that would be nonprivileged. 2 BY MR. EDWARDS: 3 Q. Was he still President at the time that 4 conversation was taking place? 5 A. I don't remember. 6 Q. Have you ever been, yourself, together 7 with Jeffrey Epstein and Bill Clinton? 8 A. No. 9 Q. Have you ever talked to Jeffrey Epstein 10 about Bill Clinton? 11 MR. INDYKE: Objection. Same objection, 12 same instruction. 13 SPECIAL MASTER POZZUOLI: Nonprivileged. 14 MR. EDWARDS: Yeah, nonprivileged. 15 A. It's hard to sort out the privileged and 16 the nonprivileged. 17 SPECIAL MASTER POZZUOLI: So based upon 18 the objection, I would ask that you -- unless 19 it's obvious, then no, until we sort that out. 20 A. I shouldn't answer that probably. 21 SPECIAL MASTER POZZUOLI: I'm going to 22 grant his objection at this point, again, as a 23 continuum because I want to make sure that we 24 preserve this issue for later on. 25 www.phi sre orting.com EFTA00615636 516 1 BY MR. EDWARDS: 2 Q. In a previous -- previously in this 3 deposition, you indicated your representation of 4 Jeffrey Epstein on this subject matter began in 5 2005, right? 6 A. It began, I think I said, when the first 7 allegations were. I don't have an exact date in 8 mind. 9 Q. The relevant time period for as we've defined, is 1999 through 2002. 11 A. That's correct, yes. 12 Q. So I'm asking if you know from Jeffrey 13 Epstein, in a time period prior to your 14 representation, whether he was socializing with Bill 15 Clinton. 16 MR. INDYKE: Same objection, same 17 instruction. 18 A. Yes, yes. 19 MR. SCOTT: As long as it's a 20 nonprivileged situation. 21 A. He was. 22 BY MR. EDWARDS: 23 Q. He was? 24 A. He was. 25 Q. So prior -- www.phi sre orting.com EFTA00615637 517 1 A. During the whole period of time up through 2 2005, you're saying? Yes. 3 Q. Right. 4 A. Yes, I think this dinner occurred before 5 2005, so I would -- yes. 6 Q. So what did Jeffrey Epstein tell you about 7 his relationship with Bill Clinton? 8 MR. INDYKE: Same objection, same 9 instruction. 10 BY MR. EDWARDS: 11 Q. Prior to 2005, obviously. 12 A. That they knew each other and that they 13 were doing some charitable work together. 14 Q. Had Bill Clinton ever been to Jeffrey 15 Epstein's home? 16 A. I'm not aware. 17 MR. INDYKE: Same objection, same 18 instruction. 19 BY MR. EDWARDS: 20 Q. What kind of charitable work was Jeffrey 21 Epstein -- 22 A. I can tell you Donald Trump has been to 23 Jeffrey Epstein's home, and I've seen him there. 24 Q. Okay. What question do you think that 25 you're answering? www.phi sre orting.com EFTA00615638 518 1 A. Well, you're asking about general things 2 people -- 3 SPECIAL MASTER POZZUOLI: Let's move 4 forward. 5 A. -- so I mean, I gave you an example of one 6 who has been there. 7 BY MR. EDWARDS: 8 Q. Okay. I'm specifically talking about 9 when -- we started with was lying when she 10 said that Jeffrey Epstein socialized with Bill 11 Clinton during the relevant time period. And now 12 I'm drilling it. 13 A. I don't know the answer to that. 14 Q. Okay. Did you understand -- did Bill 15 Clinton travel with Jeffrey Epstein? 16 A. My understanding from newspaper -- 17 MR. INDYKE: Same objection, same 18 instruction. 19 20 21 22 23 24 25 MR. SCOTT: Can we take a break in a few www.phi sre orting.com EFTA00615639 519 1 minutes? I would like -- in the afternoon, he 2 gets a little tired, so I would like to, every 3 hour or so, take -- an hour and ten minutes, 4 take a couple-minute break. 5 SPECIAL MASTER POZZUOLI: You tell me when 6 is a good -- 7 MR. EDWARDS: Maybe 15 minutes and we'll 8 switch topics, and we can take a break. Good, 9 Tom? 10 MR. SCOTT: Yes. 11 MR. EDWARDS: Okay. 12 BY MR. EDWARDS: 13 Q. Was lying when she says 14 she was introduced to Prince Andrew through Jeffrey 15 Epstein? 16 MR. INDYKE: Same objection, same 17 instruction. 18 SPECIAL MASTER POZZUOLI: Under 19 non-privileged information. 20 A. I have seen a photograph of Prince Andrew 21 and and Ghislaine Maxwell. I have 22 myself met Prince Andrew. He came to my class at 23 Harvard Law School and there was a dinner for him, 24 and he asked about Jeffrey Epstein. We discussed 25 Jeffrey Epstein. www.phi sre orting.com EFTA00615640 EFTA00615641 EFTA00615642 522 1 correct? 2 A. I do. 3 Q. And you know her through Jeffrey Epstein, 4 right? 5 MR. INDYKE: Same objection, same 6 instruction. 7 A. I wrote an article about her father's 8 death years ago, and I don't remember if I met her 9 independently. I do remember meeting her through 10 her -- I remember that the Lady Rothschild asked me 11 to meet Jeffrey Epstein, and when Jeffrey Epstein 12 came to meet me, he was with Ghislaine Maxwell. 13 BY MR. EDWARDS: 14 Q. And when was that? 15 A. The first time I Jeffrey Epstein, which 16 would have been in the summer of Leslie Wexner's 17 59th birthday. That's all I can tell you is the 18 summer of his 59th birthday because I then flew with 19 Jeffrey Epstein to Leslie Wexner's 59th birthday. I 20 was presented to Leslie Wexner. Leslie would like 21 to get as birthday gifts interesting people that his 22 friends had met during the year, and so I was 23 Jeffrey Epstein's intellectual gift to Leslie 24 Wexner. And it was that year that I met Jeffrey 25 Epstein. That's the best I can date it. www.phi sre orting.com EFTA00615643 523 1 2 4 5 6 7 8 9 10 11 12 13 14 15 Q. I'm asking about your conversations with 16 Ghislaine Maxwell, who's in a separate litigation, 17 civil litigation for defamation. Have you 18 personally spoken with Ghislaine Maxwell since these 19 allegations? 20 A. If there's no objection, I will answer. 21 MR. INDYKE: There was an objection. Same 22 objection, same instruction. 23 BY MR. EDWARDS: 24 Q. Is there a joint defense agreement related 25 to the civil allegation -- actions regarding the www.phi sre orting.com EFTA00615644 524 1 defamation actions that involve Ghislaine Maxwell 2 and yourself? 3 MR. INDYKE: Same objection. 4 SPECIAL MASTER POZZUOLI: What's the 5 basis -- can you explain to me what the basis 6 of the objection is -- and what was the 7 question? 8 MR. EDWARDS: Has Mr. Dershowitz spoken 9 with Ghislaine Maxwell since the allegations -- 10 since this defamation suit came about as well 11 as the defamation suit with Ghislaine Maxwell. 12 BY MR. EDWARDS: 13 Q. Let me ask it cleaner. Have you spoken 14 with Ghislaine Maxwell since January 2015? 15 MR. INDYKE: Same objection, same 16 instruction. 17 BY MR. EDWARDS: 18 Q. So that I'm clear, there is a joint 19 defense of the allegations regarding Ghislaine 20 Maxwell that's New York litigation and this 21 defamation case? 22 MR. INDYKE: There's a common interest 23 agreement in effect with respect to the 24 New York case and a common interest agreement 25 with respect to this case. www.phi sre orting.com EFTA00615645 525 1 BY MR. EDWARDS: 2 Q. Okay. Was lying when she 3 says that she was taken by Ghislaine Maxwell and 4 MR. SCAROLA: Who negotiated the agreement 5 and when? 6 BY MR. EDWARDS: 7 Q. Is there a common interest agreement in 8 existence with respect to the allegations that have 9 arisen since January of 2015 or that you contend 10 covers that? 11 MR. INDYKE: Same objection, same 12 instruction. 13 BY MR. EDWARDS: 14 Q. If there is, who negotiated this 15 agreement? 16 MR. SCAROLA: Can we have a ruling on 17 propriety? 18 SPECIAL MASTER POZZUOLI: You haven't 19 pushed me, so I let you go. 20 MR. SCAROLA: Can we have a ruling as to 21 whether we get to know whether Mr. Dershowitz 22 is a party to a common interest agreement with 23 Ghislaine Maxwell? 24 SPECIAL MASTER POZZUOLI: Counsel 25 MS. McCAWLEY: Also, just this is Sigrid www.phi sre orting.com EFTA00615646 526 1 McCawley, if any of the individuals on the 2 phone are representing Ghislaine Maxwell, my 3 understanding is the person on the phone is 4 representing Jeffrey Epstein, not Ghislaine 5 Maxwell. That needs to be clarified. 6 MR. INDYKE: Correct. Correct. 7 SPECIAL MASTER POZZUOLI: The answer is 8 correct? 9 MR. INDYKE: With respect to Mr. Epstein, 10 I can tell you there's a common interest 11 agreement with respect to this matter and a 12 common interest agreement with respect to the 13 Ghislaine Maxwell suit in New York. 14 SPECIAL MASTER POZZUOLI: Is 15 Mr. Dershowitz party to that? 16 MR. INDYKE: Mr. Dershowitz is party to a 17 common interest agreement with Jeffrey in this 18 case. And I believe -- I'd have to check, but 19 I believe that that would extend 20 MR. SCAROLA: We want an answer from the 21 witness as to whether the witness is a party to 22 a common interest agreement with Ghislaine 23 Maxwell. 24 SPECIAL MASTER POZZUOLI: Then ask the 25 question, because I haven't seen the question www.phi sre orting.com EFTA00615647 527 1 asked yet. 2 BY MR. EDWARDS: 3 Q. Are you a party to a common interest 4 agreement with Ghislaine Maxwell? 5 A. If there's no objection, I'll answer it. 6 MR. INDYKE: I apologize. I thought we 7 were still operating under the original set of 8 objections. So I will repeat it. Same 9 objection, same instruction. 10 SPECIAL MASTER POZZUOLI: With respect to 11 that question, you can answer 12 A. My understanding is that I am still 13 Jeffrey Epstein's lawyer. Jeffrey Epstein, I 14 understand, has a common interest or joint defense 15 agreement with Ghislaine Maxwell, so I have -- my 16 understanding is that I am bound by a common 17 agreement. 18 BY MR. EDWARDS: 19 Q. Is this the same common interest agreement 20 that we were talking about from 2005, or is this a 21 separate common interest agreement that has been 22 signed as a consequence of the lawsuits that have 23 been filed since January 2015? 24 MR. INDYKE: If this is a new question, 25 I'll assert the same objection and the same www.phi sre orting.com EFTA00615648 528 1 instruction. 2 SPECIAL MASTER POZZUOLI: And I'm going to 3 overrule the objection. And you can answer 4 that. 5 A. My understanding is that it's a 6 combination; that is, it reflects the previous 7 agreement and that there is a new agreement that 8 supplemented the previous agreement. 9 BY MR. EDWARDS: 10 Q. When you say it's your understanding, is 11 this understanding in writing; meaning, is there a 12 written common interest agreement that has been put 13 in place since January of 2015? 14 A. I don't know. 15 MR. INDYKE: Same objection, same 16 instruction. 17 MR. SCOTT: Can we take a recess when we 18 get a chance? 19 SPECIAL MASTER POZZUOLI: Yes, but I'm 20 going to instruct you -- 21 A. I don't know. I don't know the answer to 22 that, whether there's additional writing or not. 23 BY MR. EDWARDS: 24 Q. Last question, then we take a break. Have 25 you signed any such agreement www.phi sre orting.com EFTA00615649 529 1 MR. INDYKE: Same objection, same 2 instruction. 3 BY MR. EDWARDS: 4 Q. -- since January 2015? 5 A. Since January? Not to my recollection. 6 MR. EDWARDS: We can take a break. 7 VIDEOGRAPHER: Going off the record. The 8 time is approximately 2:09 p.m. 9 (Recess was held from 2:09 p.m. until 2:26 p.m.) 10 VIDEOGRAPHER: Going back on the record. 11 Time is approximately 2:26 p.m. 12 13 15 16 17 18 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615650 530 12 says that she was paid to have sex with Prince 13 Andrew? 14 A. I have no idea. 15 Q. You have met Prince Andrew, right? 16 A. I have. 17 Q. He sat in the back of your classrooms? 18 MR. SCOTT: Objection, asked and answered 19 twice. 20 A. Once, yes. 21 BY MR. EDWARDS: 22 Q. I think we went to Jeffrey Epstein sitting 23 in your classrooms, but now I'm talking about Prince 24 Andrew sat in your classroom as well, right? 25 A. Yes, once. www.phi sre orting.com EFTA00615651 531 1 MR. SCOTT: I thought we went through 2 Andrew before; maybe I'm wrong. 3 BY MR. EDWARDS: 4 Q. Have you, since the -- since January of 5 2015, have you contacted Prince Andrew? 6 A. No. I got a Christmas card from him. 7 Q. Have you spoke with him about the 8 allegations that were alleged against Prince Andrew? 9 A. Not to him, but to -- not to him. 10 Q. Have you spoke to some representative of 11 his, of Prince Andrew? 12 A. I need to know whether -- 13 MR. INDYKE: Guy, sorry, I was just cut 14 off for some reason. 15 SPECIAL MASTER POZZUOLI: Hold on a 16 second. Go ahead and restate your question 17 so -- Darren, can you hear now? 18 MR. INDYKE: Yes, I can. 19 BY MR. EDWARDS: 20 Q. My question is, have you spoken with 21 Prince Andrew or any representative of or for Prince 22 Andrew since January of 2015? 23 MR. SCOTT: If any of that involved work 24 product on our part, I am instructing you not 25 to answer. www.phi sre orting.com EFTA00615652 532 1 MR. INDYKE: Same objection, same 2 instruction on my end as well. 3 BY MR. EDWARDS: 4 Q. Whether or not you have spoken with him 5 would not be protected. 6 A. I have not spoken to him. 7 MR. SCOTT: That, I don't have a problem 8 with. 9 BY MR. EDWARDS: 10 Q. Have you spoken with any representative of 11 Prince Andrew since January of 2015? 12 A. Is there any objection? I don't think I 13 have, but I think my lawyers have. But I don't 14 think I have. 15 MR. SCOTT: Don't go into any work 16 product. 17 A. I don't think I have. 18 BY MR. EDWARDS: 19 Q. Do you know that some representative of 20 yours has spoken with some representative of Prince 21 Andrew since January of 2015? 22 A. I think so, yes. 23 Q. Is Prince Andrew a party to any joint 24 defense agreement? 25 A. Not that I am -- www.phi sre orting.com EFTA00615653 533 1 MR. INDYKE: Same objection, same 2 instruction. 3 A. I'm not aware of any. 4 BY MR. EDWARDS: 5 Q. Okay. Do you know which representative 6 which of your representatives communicated with 7 which of Prince Andrew's representatives? 8 A. No. I do remember being told, though, 9 that there was a call from Prince Andrew's people to 10 one of my lawyers, but that's all I know. 11 Q. So when I'm asking you whether ■ is lying about having sex with Prince Andrew 13 when she was under the age of 18, do you know the 14 answer to that question from -- 15 MR. INDYKE: Same objection, same 16 instruction. 17 A. Same answer. If it's based on her own 18 statement, I have no reason to believe it. If 19 there's other objective evidence, I'm not aware of 20 it. 21 I have no 22 reason to believe she would be telling the truth. 23 But I don't have any personal knowledge of that. 24 BY MR. EDWARDS: 25 Q. What information do you have from Prince www.phi sre orting.com EFTA00615654 534 1 2 3 4 Andrew's representative on that subject? MR. SCOTT: Don't answer that question. MR. INDYKE: Same objection, same instruction. 5 A. I can say publicly -- 6 MR. SCOTT: Don't answer that. You've 7 been told. 8 A. Okay, I'm sorry. 9 BY MR. EDWARDS: 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615655 535 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615656 536 1 2 3 Q. Ghislaine Maxwell has been friends and 4 acquaintances of Prince Andrew for a very long time. 5 You know that, right? 6 MR. INDYKE: Same objection, same 7 instruction. 8 BY MR. EDWARDS: 9 Q. Is that privileged, the answer to that 10 question, Ghislaine Maxwell's relationship with 11 Prince Andrew? Let me ask it this ■ -- 12 MR. INDYKE: To the extent that 13 Mr. Dershowitz obtained that information in 14 connection with his representation of Jeffrey 15 Epstein, of course it is. 16 BY MR. EDWARDS: 17 Q. I have a better ■ to go about this, 18 then. Ghislaine Maxwell and you met her well 19 before 2005, didn't you? 20 A. I did, yes. 21 Q. And Prince Andrew you met before 2005 as 22 well, correct? 23 A. I think it was before 2005, yeah. 24 Q. And prior to 2005, you understood that 25 Ghislaine Maxwell and Prince Andrew were social www.phi sre orting.com EFTA00615657 537 1 acquaintances, didn't you? 2 MR. INDYKE: Same objection, same 3 instruction. 4 SPECIAL MASTER POZZUOLI: That deals with 5 if you have any nonprivileged. 6 A. I do. 7 SPECIAL MASTER POZZUOLI: Then I would 8 overrule the objection to that extent. 9 A. I've seen them together at a party on 10 Martha's Vineyard given by Lady Rothschild. 11 BY MR. EDWARDS: 12 Q. And back at that time, prior to your 13 representation of Jeffrey Epstein, did he tell you 14 that he had been introduced to Prince Andrew through 15 Ghislaine Maxwell? 16 MR. INDYKE: Same objection, same 17 instruction. As Mr. Dershowitz previously 18 responded to the question about representation, 19 he said it was -- maybe he did not represent 20 Mr. Epstein in this case, but he represented 21 him in other cases. 22 SPECIAL MASTER POZZUOLI: I will overrule 23 the objection to the extent that you have 24 nonprivileged information that you can base the 25 answer. www.phi sre orting.com EFTA00615658 538 1 A. Yes. And in a letter that Prince Andrew 2 wrote to me thanking me for inviting him to my class 3 and having the dinner for him at Harvard Law School, 4 he made a reference to Jeffrey Epstein. 5 BY MR. EDWARDS: 6 Q. And when was -- when did Prince Andrew 7 write a letter to you? 8 A. When he came to my class at Harvard Law 9 School, just a thank-you note. 10 Q. What was the approximate date of that 11 letter? 12 A. I don't know. 13 Q. What was the approximate year of the 14 letter? 15 A. I don't know. 16 Q. Do you still have the letter? 17 A. I'll check. 18 Q. Is there any reason why you haven't 19 personally contacted Prince Andrew to discuss these 20 allegations? 21 MR. SCOTT: Objection, hypothetical, 22 speculation. 23 A. Not easy to reach the Queen, not easy to 24 reach the Prince. I don't know who I would call. 25 www.phi sre orting.com EFTA00615659 539 1 BY MR. EDWARDS: 2 Q. Couldn't you just call Ghislaine Maxwell, 3 though? It's not that easy for many people. 4 Couldn't you call Ghislaine? 5 MR. INDYKE: Objection. 6 MR. SCOTT: Argumentative. 7 BY MR. EDWARDS: 8 Q. Do you know the circumstances -- as you 9 sit here, the circumstances that led to this 10 photograph being taken in London? 11 A. No. 12 MR. INDYKE: Same objection, same 13 instruction. 14 BY MR. EDWARDS: 15 Q. Have you ever seen photographs or the 16 copies of photographs of young naked teenage girls 17 that were taken from within the closet of Jeffrey 18 Epstein's home in Palm Beach? 19 A. Absolutely not. 20 MR. INDYKE: Same objection, same 21 instruction. 22 BY MR. EDWARDS: 23 Q. Have you ever attempted to get those 24 photographs from the law enforcement 25 MR. SCOTT: Let the lawyer make his www.phi sre orting.com EFTA00615660 540 1 objection before you respond, Professor 2 Dershowitz. 3 MR. INDYKE: Finish your question, please. 4 BY MR. EDWARDS: 5 Q. Have you ever attempted to obtain those 6 photographs taken through the search warrant of 7 Jeffrey Epstein's home from law enforcement? 8 MR. INDYKE: Same objection, same 9 instruction. 10 MR. EDWARDS: He's being instructed not to 11 answer whether he's ever attempted to obtain 12 the photographs? 13 MR. INDYKE: If it was done in connection 14 with his representation of Mr. Epstein, it's 15 work product. 16 BY MR. EDWARDS: 17 Q. But I'm asking about communication that 18 you had with law enforcement. Are you claiming that 19 the communication you had with law enforcement is 20 protected by privilege? 21 MR. SCOTT: He's not claiming anything. 22 He's being instructed by a lawyer. 23 MR. EDWARDS: Okay. Well, I want to 24 understand what the record is -- 25 MR. SCOTT: Then ask the lawyer, not my www.phi sre orting.com EFTA00615661 541 1 client. 2 MR. EDWARDS: Darren, is that you? 3 MR. INDYKE: That is me, yes. 4 MR. EDWARDS: Are you saying that 5 Mr. Dershowitz or any of Jeffrey Epstein's 6 legal team, that their communication with law 7 enforcement is privileged? 8 MR. INDYKE: Whether or not such 9 communication exists and if they've never been 10 used, yes. 11 BY MR. EDWARDS: 12 Q. Do you know whether the photographs of 13 young, naked teenage girls that were taken within 14 Jeffrey Epstein's home contain photographs of 15 while she was a young girl? 16 MR. INDYKE: Same objection, same 17 instruction. 18 A. Of course not. I've never seen those 19 photographs. But here I can answer nowhere, if I 20 ever was with Jeffrey Epstein in any of his homes, 21 did I ever see a naked photograph of anybody except 22 for a Rodin model, which was a sepia print in the 23 entranceway, kind of a classic Rodin model print, 24 but I've never, ever seen any photograph of any 25 naked, underage, inappropriate -- my grandchildren www.phi sre orting.com EFTA00615662 542 1 visited his house. My wife visited his house. I 2 never would have permitted anybody to visit a home 3 that had those kinds of pictures displayed. 4 BY MR. EDWARDS: 5 Q. Was lying when she said 6 that Epstein sent girls to some of his friends? 7 MR. INDYKE: Same objection, same 8 instruction. 9 BY MR. EDWARDS: 10 Q. To any of his friends? 11 MR. SCOTT: Only on nonprivileged. 12 A. To the extent that she said that I was one 13 of those friends, which I know is a categorical 14 absolute lie, I would not believe anything she said 15 about having been sent to others of his friends. 16 But I don't have personal knowledge of that. All I 17 have is personal knowledge that lied when she said 18 she was sent to me. 19 MR. INDYKE: Same objection. 20 BY MR. EDWARDS: 21 Q. Have you at any time obtained personal 22 knowledge of Jeffrey Epstein having sent any girls 23 to any of his friends? 24 A. No. 25 MR. INDYKE: Same objection, same www.phi sre orting.com EFTA00615663 543 1 instruction. Please wait for the objection. 2 MR. SCOTT: Please listen. 3 THE WITNESS: I'm sorry. 4 BY MR. EDWARDS: 5 Q. When and under what circumstances did you 6 first hear ' name? 7 A. My recollection -- 8 MR. INDYKE: Same objection, same 9 instruction. 10 A. My answer will show it's not privileged. 11 My current recollection is the first time I heard 12 the name was when I was called and told that she was 13 accusing me. The name was not familiar to me at the 14 time. 15 BY MR. EDWARDS: 16 Q. Were you ever familiar with the list of 17 victims that were listed as a part of the criminal 18 investigation -- the federal criminal investigation? 19 MR. SCOTT: Asked and answered in the last 20 depo and earlier today. 21 MR. INDYKE: Same objection, same 22 instruction. 23 BY MR. EDWARDS: 24 Q. Was lying when she said that 25 Jeffrey Epstein's code word for sexual encounters www.phi sre orting.com EFTA00615664 544 1 with minors was "massage"? 2 A. I have no idea. 3 MR. INDYKE: Same objection, same 4 instruction. 5 BY MR. EDWARDS: 6 Q. Have you reviewed the message pads that 7 were taken as a result of trash pulls conducted by 8 the Palm Beach Police Department on Jeffrey 9 Epstein's home? 10 A. Not to my knowledge. 11 MR. INDYKE: Same objection, same 12 instruction. 13 BY MR. EDWARDS: 14 Q. Have you reviewed the document that has 15 been at times referred to as the "Holy Grail," which 16 is a phone journal from Jeffrey Epstein's computer? 17 MR. INDYKE: Same objection, same 18 instruction to the extent it's privileged and 19 you got it other than from any kind of 20 disclosure by Mr. Edwards. 21 MR. SCOTT: Unless it's nonprivileged. 22 SPECIAL MASTER POZZUOLI: All these 23 questions -- with respect to nonprivileged, if 24 you can answer them, answer them. 25 A. I'm happy to answer them all. So the www.phi sre orting.com EFTA00615665 545 1 question is am I familiar with this -- is this the 2 one that has the circles? 3 BY MR. EDWARDS: 4 Q. Yes. 5 A. That has Donald Trump circled and Bill 6 Clinton circled and me circled? 7 Q. I didn't know that it had Bill Clinton 8 circled. 9 A. Maybe not. 10 Q. So, just so that the record is clear, the 11 journal -- was the journal 12 MR. SCOTT: Was this marked in the last 13 depo? I don't recall. I don't think so. 14 MR. SCAROLA: I don't think that it was. 15 MR. INDYKE: To the extent that those 16 items are from -- I think the exhibits are a 17 statement of undisputed facts, obviously my 18 objection would apply to those items. To the 19 extent that they came out of Mr. Dershowitz's 20 representation of Mr. Epstein, I would object 21 if the answer is based as to information in 22 them. 23 SPECIAL MASTER POZZUOLI: We haven't seen 24 the exhibit yet. I know you are on the other 25 end of the phone. www.phi sre orting.com EFTA00615666 546 1 THE WITNESS: Can I take a one-minute, 2 two-minute break? 3 VIDEOGRAPHER: Going off the record, 4 2:43 p.m. 5 (Recess was held from 2:43 p.m. until 2:45 p.m.) 6 VIDEOGRAPHER: Going back on the record. 7 The time is approximately 2:45 p.m. 8 BY MR. EDWARDS: 9 Q. Have you ever read the case documents 10 related to the arrest of Alfredo Rodriguez for the 11 Federal obstruction of justice charges? 12 A. No. 13 MR. INDYKE: Same objection, same 14 instruction. 15 MR. SIMPSON: Just pause for a second 16 before answering to let Mr. Indyke jump in if 17 he needs to. 18 BY MR. EDWARDS: 19 Q. The journal that we're talking about is 20 the one that has been disclosed in discovery in this 21 case and in prior cases where, as you mentioned 22 before, certain people's names are circled. Are you 23 familiar with that document? 24 A. I have perused the part of it that circled 25 me and some other prominent names. I have not read www.phi sre orting.com EFTA00615667 547 1 2 3 4 5 6 the whole document. Q. I'm going to show you the page from this journal that is for Bill Clinton just based off of your last comment, and then I'll ask you some questions about that. A. This doesn't say Bill Clinton, it says 7 Doug Band. That's what you're talking about. 8 (Thereupon, marked as Plaintiff 9 Exhibit 20.) 10 A. This doesn't have an entry for Bill 11 Clinton It has an entry for Douglas Band, who I 12 know. 13 BY MR. EDWARDS: 14 Q. You know Doug Band? 15 A. Sure. 16 Q. Is Doug Band affiliated with Bill Clinton? 17 A. Oh, yeah, he was. Not any longer. 18 Q. 19 A. 20 Q. 21 A. 22 23 24 25 A. How do you know Doug Band? Through Bill Clinton. How do you know Bill Clinton? I've known him for -- MR. INDYKE: Objection. Same objection, same instruction. MR. SIMPSON: Nonprivileged information. Well outside of my relationship with www.phi sre orting.com EFTA00615668 548 1 Jeffrey Epstein. I was -- supported him. I've been 2 to the White House at his invitation. I've had 3 dinner with him on numerous occasions. 4 BY MR. EDWARDS: 5 Q. Have you called Bill Clinton with respect 6 to the allegations that have been made in this 7 lawsuit? 8 A. I've tried to. 9 Q. Has Bill Clinton given you any comment 10 whatsoever on any of the allegations? 11 A. Not personally, but Doug Band has. And 12 13 14 15 16 17 18 with Doug Band? 19 A. Very shortly after the accusation, as soon 20 as I could reach him. 21 Q. January 2015? 22 A. Probably January. 23 Q. Is Doug Band somebody who traveled with 24 Jeffrey Epstein as well? 25 A. That's true -- no, he traveled -- Q. When was that conversation that you had www.phi sre orting.com EFTA00615669 549 1 MR. INDYKE: Same objection, same 2 instruction. 3 A. He traveled with Bill Clinton always. I 4 mean, he was his body man. He was the guy who 5 traveled with him wherever he went. 6 BY MR. EDWARDS: 7 Q. My question is, did Doug Band ever travel 8 with Bill Clinton -- I mean with Jeffrey Epstein? 9 A. I don't know the answer to that. 10 Q. Well, did Bill Clinton ever travel with 11 Jeffrey Epstein? 12 MR. SIMPSON: Asked and answered. 13 MR. INDYKE: Same objection, same 14 instruction. 15 A. According to public information, yes. 16 BY MR. EDWARDS: 17 Q. And Doug Band, you are saying, was always 18 with Bill Clinton? 19 A. Not always, but he was the guy who 20 traveled with him. Nobody can be with anybody 24/7. 21 Q. The flight logs will speak for themselves 22 whether the two were traveling together, correct? 23 A. I have no idea. 24 Q. That entry -- I believe the comment that 25 you made was that was Alfredo Rodriguez had circled www.phi sre orting.com EFTA00615670 550 1 Bill Clinton's name. 2 A. I thought he had. He circled a lot of 3 prominent people's names, Hollywood actors. 4 MR. INDYKE: Objection. Do you know that 5 outside of your relationship with Mr. Epstein? 6 THE WITNESS: Yes, I saw the -- 7 MR. INDYKE: I'm asking Mr. Dershowitz if 8 he's answering that question outside of his 9 relationship with -- his attorney-client 10 relationship or work product relationship or 11 common interest relationship with Mr. Epstein. 12 THE WITNESS: Yes. 13 MR. SIMPSON: The document was produced in 14 discovery. 15 MR. INDYKE: The question is as for the 16 circles in the document. 17 A. The document I saw had circles in it, and 18 I saw that in discovery in this case. I hadn't seen 19 it previously. 20 MR. INDYKE: Okay. 21 BY MR. EDWARDS: 22 Q. So you have seen the notations that 23 Alfredo Rodriguez made to the document during the 24 time he was turning the document over to the FBI? 25 A. The only notations that I saw that I www.phi sre orting.com EFTA00615671 551 1 recall are circles. 2 Q. Okay. And is it your understanding that 3 Alfredo Rodriguez was indicating to the FBI who was 4 involved in the illegal activity with minors along 5 with Jeffrey Epstein? 6 A. Absolutely not. Categorically absolutely 7 not. 8 MR. INDYKE: Same objection, same 9 instruction. 10 BY MR. EDWARDS: 11 Q. That's not your understanding? 12 A. Not only is it not my understanding, it is 13 a totally false statement because if it were true, 14 Donald Trump would be standing accused of having 15 improper sexual conduct and many other Hollywood 16 actors, actresses and other people who have never 17 been accused by your lying client would also stand 18 accused. 19 SPECIAL MASTER POZZUOLI: Let's move -- 20 MR. EDWARDS: That was not my question. 21 SPECIAL MASTER POZZUOLI: Let me stop 22 before we get too far down this. The document 23 that -- the portion of the document that you're 24 asking questions upon, let's understand the 25 context of the questions, and Mr. Dershowitz's www.phi sre orting.com EFTA00615672 552 1 answer so far has been that because it's been 2 produced in this case. So let's stay focused 3 on that. 4 A. Can I see that document, please. 5 MR. INDYKE: Just for clarification, I 6 don't want to interrupt, but for clarification, 7 I wasn't objecting to the document. I was 8 objecting to the foundation upon which 9 Mr. Dershowitz may or may not know why they 10 were circled, how that information came 11 through. 12 A. I know that independently. 13 BY MR. EDWARDS: 14 Q. You know why the various circles were made 15 independently? 16 A. No, but I know what the allegation is. 17 Q. The allegation -- you know what the 18 allegation is why the circles were made? 19 A. I know that it was not that the people 20 whose name were circled were involved in any illegal 21 activity. Can you please show me the document. 22 MR. SCOTT: Can he see the exhibit? 23 MR. SCAROLA: I -- 24 MR. EDWARDS: I don't have it. I mean, I 25 only have the piece of the page that he just www.phi sre orting.com EFTA00615673 553 1 talked about, which is Bill Clinton. I mean, I 2 have it and I'll copy it for you and I'll give 3 it to you tomorrow and we can talk about the 4 whole document. 5 A. It is a categorical lie -- 6 MR. SCOTT: Let's put it over until 7 tomorrow, then, when we have the exhibit. 8 BY MR. EDWARDS: 9 Q. Well, that before you -- you just 10 indicated that one of the people who was circled was 11 Bill Clinton. 12 A. I said I thought. 13 MR. SCOTT: He also indicated he would 14 like to see the whole exhibit. 15 BY MR. EDWARDS: 16 Q. On that page that's before you that's 17 listed Doug Band, is Bill Clinton's name listed 18 under that? 19 A. It says Office of William J. Clinton. 20 Q. Are there numbers for Bill Clinton listed 21 under that entry? 22 A. I assume they're numbers of Bill Clinton. 23 I assume so. 24 Q. When you talked to Doug Band, can you tell 25 us what that conversation was that you had with Doug www.phi sre orting.com EFTA00615674 554 1 Band? 2 A. Yes. 12 Q. Go on. What did Doug Band tell you? 13 A. That it wasn't true. 14 Q. Did Doug Band tell you whether Bill 15 Clinton had ever been to Jeffrey Epstein's island? 16 A. He told me that to his knowledge, 17 President Clinton had never been to Jeffrey 18 Epstein's island. 19 Q. Did he tell you whether Bill Clinton and 20 Jeffrey Epstein had ever shared a meal together? 21 A. I didn't ask him that question. I only 22 asked him about the island. I think I only asked 23 him -- I'm not positive whether I asked him during 24 the relevant period or ever. I think I asked him 25 ever. www.phi sre orting.com EFTA00615675 555 1 Q. Had -- has Bill Clinton ever flown on an 2 airplane -- or sorry, on a helicopter with Ghislaine 3 Maxwell? 4 A. Not to my knowledge. 5 MR. INDYKE: Objection. Same objection, 6 same instructions. 7 A. I cannot imagine the former President or a 8 President of the United States being allowed by the 9 Secret Service to fly on a helicopter with a pilot 10 who had just barely been licensed. 11 BY MR. EDWARDS: 12 Q. I'm just asking what you know. Do you 13 know whether or not 14 A. I know -- I know that Bill Clinton never 15 flew never was flown by Ghislaine Maxwell to the 16 island. I know it based on my common sense 17 experience. 18 Q. Not my question. My question is, do you 19 know whether Bill Clinton ever flew on a helicopter 20 with Ghislaine Maxwell? 21 MR. SCOTT: On the phone, there's 22 background. Thank you. 23 A. I don't know for sure, but I would 24 seriously doubt it. 25 www.phi sre orting.com EFTA00615676 556 1 BY MR. EDWARDS: 2 Q. Okay. 3 A. We're going to get tomorrow the circled 4 document that we can look at? 5 Q. I can find it now and I can get it and we 6 can look at it today. 7 MR. SCOTT: Take a minute. 8 A. I want to make sure we see all the circled 9 names. 10 MR. EDWARDS: Here's a copy right here 11 that we can copy at the next break. 12 MR. SCOTT: Sure. 13 BY MR. EDWARDS: 14 Q. Was lying when she says 15 that Ghislaine Maxwell served as Jeffrey Epstein's 16 madam? 17 MR. INDYKE: Same objection, same 18 instruction. 19 A. I would have no knowledge that would 20 establish that. Certainly I wouldn't believe it 21 just because she said it. 22 BY MR. EDWARDS: 23 Q. Have you asked Ghislaine Maxwell about 24 that? 25 A. No. www.phi sre orting.com EFTA00615677 557 1 MR. INDYKE: Same objection, same 2 instruction. 3 BY MR. EDWARDS: 4 Q. One of the things -- one of the statements 5 that we began the day with was that something that 6 Paul and I could have done was call you and ask you, 7 right, we could have picked up the phone and called 8 you? 9 A. You and Mr. Cassell, yeah. Yeah. 10 Q. When you were representing Jeffrey Epstein 11 back in 2007, did you ever insist that Jeffrey 12 Epstein had paid for massages, but had not engaged 13 in sex or erotic massages with any minors? 14 MR. INDYKE: Same objection, same 15 instruction to the extent that you can 16 specify -- 17 BY MR. EDWARDS: 18 Q. I'm asking whether you ever made that 19 statement. 20 MR. INDYKE: Same objection, same 21 instruction. 22 A. Can you repeat the question for me? 23 THE REPORTER: "When you were representing 24 Jeffrey Epstein back in 2007, did you ever 25 insist that Jeffrey Epstein had paid for www.phi sre orting.com EFTA00615678 558 1 massages, but had not engaged in sex or erotic 2 massages with any minors?" 3 SPECIAL MASTER POZZUOLI: By definition of 4 your question, it's within the representation 5 of Jeffrey Epstein, right? So in a -- without 6 any further clarification, I would agree with 7 the objection. 8 MR. SCAROLA: I'm sorry, this is about a 9 public statement. 10 MS. McCAWLEY: It's a public statement. 11 MR. EDWARDS: It's a public statement that 12 he makes to the New York -- 13 SPECIAL MASTER POZZUOLI: So then make 14 your question limited to that. Then I can rule 15 on that. That's why looked at the question. 16 MR. SCOTT: If you specify where the 17 statement came from, it would be helpful. 18 BY MR. EDWARDS: 19 Q. Did you ever make a public statement -- 20 did you ever make a statement in public that Jeffrey 21 Epstein had paid for massages, but had not engaged 22 in sex or erotic massages with any minors? 23 A. May I see the statement? 24 Q. Sure. 25 MR. SCAROLA: No. www.phi sre orting.com EFTA00615679 559 1 BY MR. EDWARDS: 2 Q. Well, did you make that statement? 3 A. I have no recollection of whether I made a 4 statement like that ten years ago. I'd like to see 5 the statement. 6 MR. SCAROLA: Now you can refresh his 7 recollection. 8 MR. INDYKE: Same objection, same 9 instruction. 10 BY MR. EDWARDS: 11 Q. Did you make a public statement that 12 Epstein was innocent of all allegations? 13 MR. SCOTT: Let me object to this in the 14 context that he's asking him statements from 15 ten years ago without specifying date, time and 16 place. It's just unfair. 17 SPECIAL MASTER POZZUOLI: If you're 18 reading from an article, published article, 19 then show him that. Let's stop for a second. 20 Do you recall making that statement? 21 THE WITNESS: I do not recall. 22 SPECIAL MASTER POZZUOLI: Will you show 23 him something that might 24 BY MR. EDWARDS: 25 Q. Sure. I'm going to go through each of the www.phi sre orting.com EFTA00615680 560 1 2 3 4 three statements and then I'm going to show you the document. SPECIAL MASTER POZZUOLI: These all deal with public statements, right? 5 Q. Yes. 6 BY MR. EDWARDS: 7 8 9 10 11 12 • ^ou e p o re res your reco ec ion 13 if I showed you the statement? 14 A. Yes. 15 16 17 18 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615681 61 www.phi sre orting.com So your -- MR. SCOTT: Are we going to mark that? MR. EDWARDS: Yes, we can mark that. 5 BY MR. EDWARDS: 6 9 10 11 12 BY MR. EDWARDS: 13 14 15 16 17 18 19 20 21 22 23 24 25 EFTA00615682 562 1 Q. Hypothetically, if you had made those 2 statements, those statements would be false, 3 correct? 4 MR. SCOTT: Objection. Hypothetical -- 5 we're not even talking -- we have no knowledge 6 of who this woman is. 7 SPECIAL MASTER POZZUOLI: I'm going to 8 grant the objection. Move on. Rephrase the 9 question. 10 BY MR. EDWARDS: 11 12 13 14 15 16 17 18 19 Q. This is not my deposition. 20 A. I understand that, but you're giving a 21 hypothetical and I'm giving a hypothetical answer. 22 One would have to know whether or not the lawyers 23 who should have called me knew about the statement. 24 Q. In this hypothetical, suppose that we were 25 aware of every one of your public statements that www.phi sre orting.com EFTA00615683 563 1 you have ever made on this case of this subject 2 matter as well as related subject matter whatsoever 3 at the time. 4 A. You would find that I was a truth-telling 5 person who never has ever deliberately stated an 6 untruth in my professional life. 7 Q. We're going to get through this -- 8 SPECIAL MASTER POZZUOLI: Go ahead and ask 9 the question now based on that hypothetical you 10 just laid out. 11 BY MR. EDWARDS: 12 Q. If we hypothetically assumed that you had 13 made these statements, would these statements, given 14 your knowledge of the facts of this case, be false? 15 A. Let me see the statements again, please. 16 MR. INDYKE: Objection. To the extent the 17 knowledge of the facts of this case derive from 18 Mr. Dershowitz's representation of Mr. Epstein, 19 I don't think he can answer that question 20 without violating the privilege. 21 SPECIAL MASTER POZZUOLI: Hang on one 22 second. Did we hop over the hypothetical to 23 reality? 24 MR. INDYKE: I think we may have. 25 SPECIAL MASTER POZZUOLI: That's my www.phi sre orting.com EFTA00615684 564 1 question to you. 2 MR. EDWARDS: We're still operating in 3 hypothetical. 4 SPECIAL MASTER POZZUOLI: So now go back 5 and describe your hypothetical specifically so 6 he understand the question that you are asking. 7 A. Is this hypothetical still? 8 BY MR. EDWARDS: 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. I can understand it. What I would have 23 done as a responsible lawyer, what you should have 24 done, is you should have called me and asked me 25 about these statements, and I might have told you I www.phi sre orting.com EFTA00615685 565 1 said them, I might have told you I didn't say them, 2 I would have to have checked. 3 4 5 6 7 8 9 MR. INDYKE: Objection if you're talking 10 about actual facts. 11 SPECIAL MASTER POZZUOLI: He's answering a 12 hypothetical, so it's within -- move forward on 13 the hypothetical basis only. 14 15 16 17 It says that I said that he had passed a 18 lie detector test. I don't recall that. I don't 19 recall that he took a lie detector test. But if he 20 had taken a lie detector test and I was told he 21 passed it, that statement would be true. 22 If I had been told hypothetically that he 23 had paid for massages and had not engaged in 24 massages with underage minors, at that point in time 25 in 1907 [sic], that statement would be true. But as www.phi sre orting.com EFTA00615686 566 1 a lawyer, I wouldn't necessarily, A, take the word 2 of the Daily Mail without calling or, B, assume that 3 the statements quoted in the Daily Mail were false. 4 BY MR. EDWARDS: 5 Q. Would you agree it is a fair assumption or 6 a fair presumption that when you are making public 7 statements on behalf of the client, that you have at 8 least reviewed the available evidence that may exist 9 against that client? 10 A. That's too broad a question. It really 11 depends. I mean, I get called on day one of a case, 12 I don't know the evidence, and I'm called by the 13 press. I talk about my client being presumed 14 innocent, my client being innocent. That's part of 15 the role of a criminal defense lawyer. Justice 16 Blackmun has said that the criminal defense lawyer's 17 role does not end in a courtroom, it continues to 18 the courthouse steps. 19 And so when my client is being accused of 20 something, I have the right to -- 21 MR. SCAROLA: Excuse me one moment. Rick, 22 could you step outside with me. 23 A. to express my clients' views on the 24 matter. I'm speaking in a representative capacity. 25 www.phi sre orting.com EFTA00615687 1 BY MR. EDWARDS: 2 Q. Can we now remove ourselves from that 3 hypothetical and go to the allegations in this 4 Complaint, which include the various allegations 5 made in the statements at the beginning of this 6 deposition? 7 A. Which Complaint are we talking about? 8 9 10 11 BY MR. EDWARDS: 12 13 14 15 16 17 18 19 20 21 22 23 24 THE WITNESS: I don't think so, based on a 25 combination of factors, including material that www.phi sre orting.com EFTA00615688 568 1 I got in a lawyer-client and work product 2 fashion. 3 BY MR. EDWARDS: 4 Q. Okay. Let's take it a different III. One 5 of the things you said we should have done is just 6 called you. 7 A. That's right. 8 Q. If we had called you, isn't it more 9 likely, based on what we've seen today, that what we 10 would have had is just a bunch of objections and you 11 not being able to tell us anything? 12 A. Absolutely not. 13 MR. SCOTT: Objection -- 14 A. This requires a long answer because you've 15 asked me what you would have found out had you 16 called me. So let me tell you what you would have 17 found out. 18 MR. SCOTT: Do you want a long answer? 19 BY MR. EDWARDS: 20 Q. I don't want a long answer. I'm asking 21 wouldn't Jeffrey Epstein have had a say in what you 22 tell us, the same way that he has a say apparently 23 today in what you're telling us? 24 A. No. When it comes to me defending myself, 25 I will make the ultimate decision as to -- I'm an www.phi sre orting.com EFTA00615689 569 1 expert on lawyer-client privilege. I'm an expert on 2 work product. I'm an expert on the exceptions. I 3 can tell you exactly what I would have told you. 4 What I would have told you was that I have 5 documentation that could prove categorically that I 6 could not have been on Jeffrey Epstein's island 7 during the three-year period that is relevant. 8 I can prove categorically that I could not 9 have had sex or any contact with her at the ranch. 10 I can prove categorically that I couldn't have had 11 sexual contact with her on the airplane. I can 12 prove categorically that I couldn't have had sexual 13 contact with her in Palm Beach. And that I could 14 not prove categorically that at least I wasn't in 15 the same city with her in New York because I was in 16 New York for a long period of time. 17 I would have told you what that 18 documentation was. I would have asked you for an 19 opportunity to produce the documentation. I would 20 have provided you with other information. 21 No, I would not have raised any privilege. 22 I would have told you exactly what the evidence is, 23 and you would have believed me and you would have 24 not made these allegations if you're a responsible 25 lawyer. www.phi sre orting.com EFTA00615690 570 1 Q. Is this the documentation that you have 2 now produced in this litigation, the documentation 3 you're talking about? 4 A. Yes. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615691 571 1 anything is missing, I regret it much more than you 2 do because I am positive that they would provide 3 exculpatory information. 4 Q. The same way 5 A. I'm hoping that you can find it. Please 6 go ahead with my blessing. Please go find it. 7 MR. INDYKE: Objection. In connection 8 with Mr. Dershowitz's response, Mr. Epstein 9 waives no such objections that he's raised. 10 He's not waiving privilege. He's not waiving 11 work product. He's not waiving 12 attorney-client, common interest, joint 13 defense. 14 SPECIAL MASTER POZZUOLI: I've got it. 15 M•v f rw r 16 17 18 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615692 572 1 2 3 4 5 6 7 8 A. First of all, I did not rely on -- MR. INDYKE: To the extent that your response requires you to invade privilege, I would instruct you not to respond. 9 10 11 12 13 14 15 16 17 Q. Is this related to answering my question? 18 A. Yes, it is very directly. 19 SPECIAL MASTER POZZUOLI: What you're 20 looking at there is related? 21 A. Yes. Her statement -- here's what I would 22 look at. 23 MR. EDWARDS: Can we attach this to the 24 deposition that he's reviewing this? 25 SPECIAL MASTER POZZUOLI: Yeah, yeah. www.phi sre orting.com EFTA00615693 573 1 A. I am simply quoting from her affidavit. 2 SPECIAL MASTER POZZUOLI: Who "her"? 3 A. That's what I looked 4 at, her affidavit, which says that 5 SPECIAL MASTER POZZUOLI: Hang on one 6 second. Tom, before he quotes, let's 7 understand, I do think we need a copy of that 8 now. 9 THE WITNESS: It's in the affidavit. 10 SPECIAL MASTER POZZUOLI: But I do think 11 in fairness to these guys, I think that what 12 you're reading from, they need to have it. 13 A. I won't read from it. In her affidavit, 14 she states that she had sex with Presidents, plural, 15 of countries, a well-known prime minister of a 16 country, prominent American politicians, prominent 17 American businessmen, academics, and more. 18 And when I read that and read other 19 information about what she was reported to have 20 said, that's not from newspapers, that's from her 21 own affidavit. 22 BY MR. EDWARDS: 23 24 25 www.phi sre orting.com EFTA00615694 574 1 2 3 4 5 6 7 8 MR. SCOTT: You've been quoting from 9 newspapers all along, and now you have a 10 problem with a newspaper? 11 MR. EDWARDS: I don't have a problem with 12 a newspaper. 13 SPECIAL MASTER POZZUOLI: Wait a second. 14 Move on. You don't need to respond. 15 BY MR. EDWARDS: 16 17 18 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615695 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Q. But by throwing that last piece in there 18 that it's also on the basis of conversations you've 19 had with your client, it implies that those 20 conversations somehow justified those statements. 21 And if that's what you're sticking to, I want to 22 understand what it is that you learned from him that 23 could possibly justify those public statements in 24 2007. 25 MR. INDYKE: Same objection, same www.phi sre orting.com EFTA00615696 576 1 instruction. 2 A. What I'm saying is that lawyers, 3 particularly criminal defense lawyers, whether in 4 court or out of court -- I don't know whether these 5 statements were made in court of out of court -- are 6 entitled to assert the innocence of their clients. 7 That's what lawyers do all the time. I'm 8 sure you've done it. I'm sure Professor Cassell has 9 done it. I'm sure Mr. Scarola has done it. And 10 none of us ever want to be judged on our credibility 11 by pleading a client nonguilty or asserting a 12 client's innocence, and then it turns out perhaps 13 later that the client -- I'm not suggesting that 14 that happened here, but that the evidence 15 contradicts it. 16 First of all, we don't know what the 17 evidence is we're talking about here because we're 18 dealing with a timeframe that's very, very different 19 from the timeframe that ultimately was available 20 later on in the case. 21 BY MR. EDWARDS: 22 Q. Let me ask it to you this way, then: 23 First let me ask, is a Massachusetts rule of 24 professional conduct on truthfulness in statements, 25 are you familiar with that rule? www.phi sre orting.com EFTA00615697 577 1 A. Yes. 2 Q. And doesn't it indicate that in the course 3 of representing a client, a lawyer shall not 4 knowingly make a false statement of material fact or 5 law to a third person? 6 A. And I've never done anything that even 7 comes close to violating that rule. 8 Q. Okay. So let's take the statement, the 9 public statement that we are discussing from the 10 Daily Mail April 2007 article. 11 A. Right. 12 Q. The statement that the financier had paid 13 for massages, but had not engaged in sex or erotic 14 massages with any minors, do you, as you sit here 15 today, believe that statement to have been true at 16 the time that you made it? 17 A. Absolutely. 18 MR. INDYKE: Same objection, same 19 instruction. 20 BY MR. EDWARDS: 21 Q. The 87-page police report that has already 22 been marked to this deposition was generated in 2005 23 and 2006 prior to that statement that you made; is 24 that right? 25 A. I have no idea. Let me qualify my answer. www.phi sre orting.com EFTA00615698 578 1 I don't recall having used those words. I don't 2 recall an interview with the Daily Mail. My current 3 recollection is I did not have an interview with the 4 Daily Mail. 5 Had I had an interview with the Daily 6 Mail, it would have had to have been authorized by 7 my client. I don't think he would have authorized 8 such an interview, so I am now not acknowledging -- 9 I just don't know, but I am not acknowledging that I 10 actually said those words to the Daily Mail. You 11 are going to have to demonstrate that. I don't 12 remember speaking to Ms. Churchhill or whatever her 13 name is. It's possible, but I don't remember it. 14 Q. So if somebody is attributing those 15 statements to you, are you saying that they are 16 lying? 17 A. I don't remember having made those 18 statements. 19 MR. SCOTT: I would like to object to the 20 entire relevancy of this entire line because 21 this doesn't even establish which lady he's 22 talking about. That article doesn't even 23 establish anything about your client. 24 MR. EDWARDS: I hear your objection. But 25 the article actually says that Jeffrey Epstein www.phi sre orting.com EFTA00615699 579 1 was innocent of all allegations. So it's 2 apparently talking to at least -- 3 BY MR. EDWARDS: 4 Q. Wouldn't you agree it's reasonable to 5 presume that it's talking about all of the 6 allegations -- 7 A. Allegations against him that I recall at 8 the time that I was representing him involve two 9 women, two young women, is my recollection of the 10 allegations. And we were taking the position, and 11 we took the position with the State Attorney that he 12 was not guilty of those allegations. 13 There were many defenses that were being 14 raised, some dealing with credibility, some dealing 15 with -- 16 MR. INDYKE: Objection, objection. 17 A. -- whether or not some of the women showed 18 him IDs. 19 MR. INDYKE: You're getting into 20 attorney-client. 21 SPECIAL MASTER POZZUOLI: Go ahead ad make 22 your point. 23 MR. INDYKE: My point is that it sounds to 24 me that Alan is now discussing attorney-client 25 matters and internal decisions and strategies www.phi sre orting.com EFTA00615700 580 1 2 3 4 5 6 7 and statements that may not have been a matter of public record. SPECIAL MASTER POZZUOLI: I think you responded to the question. MR. INDYKE: And therefore they're subject to privilege, and we object and instruct him not -- 8 MR. SCOTT: Again, I'm going to object to 9 relevancy. It's been going on for hours. It 10 doesn't even involve his client. 11 SPECIAL MASTER POZZUOLI: I'm not going to 12 rule on the relevancy objection. This is 13 something that you can take up later at a 14 deposition. So move forward. He gets to take 15 his own deposition. 16 BY MR. EDWARDS: 17 Q. Do you remember that one of the alleged 18 victims that you were -- do you remember trying to 19 discredit one of the alleged victims named -- hold 20 on, this is difficult here. What I'm having trouble 21 with is what we are going to do with the identity of 22 underage sex abuse victims. I'm a little nervous to 23 say it on the record on a video. So can we just 24 take a two-minute break, five-minute break so that I 25 can figure out how we're going to work this out? www.phi sre orting.com EFTA00615701 581 1 SPECIAL MASTER POZZUOLI: We're on break. 2 VIDEOGRAPHER: Going off the record. The 3 time is approximately 3:23 p.m. 4 (Recess was held from 3:23 p.m. until 3:38 p.m.) 5 VIDEOGRAPHER: Going back on the record. 6 The time is approximately 3:38 p.m. 7 BY MR. EDWARDS: 8 Q. I'm going to give you the police report 9 that has been moved in as Exhibit 18, and I have 10 included a sticky note that we'll throw away. I'm 11 going to refer to her by the normal'. but I've 12 marked her real name so that you will know it, and 13 I'll ask if you remember her and things of that 14 nature. But here you go. 15 A. While I'm doing that, may I amend the 16 previous answer? 17 MR. INDYKE: If you're asking if he knows 18 her name, then I would object to -- on the same 19 basis I objected previously. 20 MR. SIMPSON: Why don't we discuss that on 21 the next break before you amend an answer. 22 SPECIAL MASTER POZZUOLI: Go ahead again. 23 I lost it. 24 MR. INDYKE: If you're asking whether or 25 not he knows this person I'll, if that's the www.phi sre orting.com EFTA00615702 582 1 question, I would object on the basis of work 2 product, attorney-client, common interests, and 3 instruct you not to answer to the extent it 4 invades any of those privileges. 5 A. What am I looking at here? 6 BY MR. EDWARDS: 7 Q. This is the Palm Beach Police Department 8 police report. 9 A. What do you want me to look at? 10 Q. Sure. It's page 40. 11 A. I have it, yes. 12 Q. We're going to go to the paragraph -- 13 second paragraph, "Detective and I met with 14 on October 11, 2005." 15 A. "Detective and I met with . and 16 her friend." 17 Q. I'm going to tell you that the person 18 under that redaction is 19 A. Okay. That doesn't mean anything to me. 20 Q. Is that somebody that -- whose name that 21 you -- 22 A. Oh, that person. 23 SPECIAL MASTER POZZUOLI: Go ahead and 24 make your objection. 25 MR. INDYKE: Same objection, same www.phi sre orting.com EFTA00615703 583 1 instruction. 2 SPECIAL MASTER POZZUOLI: Do you know this 3 person? 4 A. Only through my work with Jeffrey Epstein. 5 BY MR. EDWARDS: 0 7 8 9 10 11 12 13 14 15 16 Q. That you produced to the State Attorney's 17 Office? 18 A. I don't know how to use a computer, so I 19 couldn't pull down anything. But I was presented 20 with these within the lawyer-client representation. 21 And I don't know how much further to go. 22 Q. And didn't you take that information -- 23 MR. INDYKE: Instruct you not to answer. 24 BY MR. EDWARDS: 25 Q. Didn't you take that information, whatever www.phi sre orting.com EFTA00615704 584 1 information that you pulled from .'s MySpace page 2 to the State Attorney's Office to convince the State 3 Attorney's Office that this witness was not 4 credible? 5 SPECIAL MASTER POZZUOLI: Do you have an 6 objection, or no? 7 MR. INDYKE: No. 8 A. For 50 years, I've taught my students in 9 criminal law that their job is to present evidence 10 that would raise questions about the credibility of 11 a witness against their criminal defendant. And, of 12 course, every criminal lawyer does that. And I, 13 along with my co-defendants [sic), did the very same 14 thing in this case. 15 MR. SIMPSON: I believe you misspoke. You 16 said "co-defendants." Co-counsel? 17 MR. SCAROLA: Freudian slip. 18 BY MR. EDWARDS: 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615705 585 1 2 3 4 5 6 7 8 9 10 11 12 Q. After you made the statement that 13 Mr. Cassell and I had fabricated the allegations 14 against you and believed in the story of a 15 incredible, serial liar, and had failed to call you, 16 did you read our responsive pleading which I believe 17 was more than 150 pages long outlining some of our 18 investigation of the surrounding allegations? Just 19 did you read that response? I believe it was filed 20 January 21, 2015, in Judge Marra's courtroom. 21 A. I don't recall reading a 150-page 22 document. My lawyer Kendall Coffey would have read 23 it. It's possible I read it. But -- can you show 24 it to me? 25 Q. I don't have it here, but I assumed that www.phi sre orting.com EFTA00615706 586 1 you had read it. 2 A. I would be happy to look at it and see if 3 it's something I read. I know I'm familiar with 4 what -- some of the things you said you did, and 5 they didn't make me change my opinion at all. 6 Q. Did you read Detective 's 7 deposition that was taken in the civil cases against 8 Mr. Epstein? 9 MR. INDYKE: Objection. 10 SPECIAL MASTER POZZUOLI: There's no 11 grounds for an objection as to whether he read 12 a deposition. 13 MR. INDYKE: Well, there is when they 14 didn't place it within a timeframe. 15 SPECIAL MASTER POZZUOLI: Okay. 16 MR. INDYKE: Same objection, same 17 instruction. 18 BY MR. EDWARDS: 19 Q. In production we had produced many 20 depositions not only in this case, but have been 21 filed in other cases, which is why I asked you about 22 that January 21st pleading. 23 Is one of the documents that you have read 24 regarding our investigation of the allegations 25 Detective deposition? www.phi sre orting.com EFTA00615707 587 1 A. When -- when was Detective Recarey's 2 deposition? 3 Q. It was taken sometime in 2010. I don't 4 have the entire document. 5 A. I doubt that I read it. I wouldn't have 6 had any reason to read it back in 2010. 7 Q. If -- 8 MR. INDYKE: If are you talking about what 9 he did in 2010 rather than in response to 10 pleadings in this case, then I would object. 11 Same objection, same instruction. 12 BY MR. EDWARDS: 13 Q. I don't need to ask you if you've read the 14 deposition. If Detective has testified that 15 the State Attorney, very early on in the 16 investigation, was gung-ho up until the meeting with 17 Alan Dershowitz, would that be a true statement? 18 MR. SCOTT: Objection, form, totally 19 irrelevant to anything. 20 MR. INDYKE: Same objection, same 21 instruction. 22 A. I sure hope so. I mean, if I did a good 23 job in persuading a very distinguished State 24 Attorney about being less gung-ho about going after 25 my client, that's my job, that's what I get paid for www.phi sre orting.com EFTA00615708 588 1 as a criminal defense lawyer. So I'm proud to 2 have -- if it's true, have had him be less than 3 gung-ho. 4 I have tell you my negotiations with him 5 were very tough, very arm's length and very 6 difficult to the point where I was replaced at one 7 point for not getting a good enough deal. 8 BY MR. EDWARDS: 9 Q. If -- 10 MR. INDYKE: Objection. Alan, please do 11 not go into the substance of any kind of 12 interactions between you and any of on 13 Mr. Epstein's counsel in connection with your 14 representation. 15 BY MR. EDWARDS: 16 Q. At some point in time, were your services 17 terminated by Mr. Epstein? 18 A. I was replaced. 19 MR. INDYKE: Same objection, same 20 instruction. 21 BY MR. EDWARDS: 22 Q. At what point in time were you terminated? 23 MR. SCOTT: He didn't say that. 24 MR. INDYKE: Same objection, same 25 instruction. www.phi sre orting.com EFTA00615709 589 1 A. I wasn't terminated. A lawyer was added 2 to the team. And I think the record will show when 3 that happened, and negotiations continued with a new 4 lawyer who was seeking to get a better deal. 5 BY MR. EDWARDS: 6 Q. If Detective Detective l testified that the 7 point of your meeting with the State Attorney's 8 Office was to show that the character of the girls 9 was not to be believed, would that be a fair and 10 accurate description of that? 11 A. Well, the purpose of the meeting was 12 multiple. The purpose of the meeting, I remember we 13 brought forth every single -- 14 MR. INDYKE: Same objection, same 15 instruction, please. And, Professor Cassell, 16 I'm having some difficulty hearing you. 17 MR. SCOTT: He's having a hard time 18 hearing you. 19 MR. INDYKE: Yes. 20 A. The plain purpose of my meeting and the 21 work that did I together with my research assistant 22 was to gather all the cases in Palm Beach County and 23 maybe some other surrounding counties involving the 24 allegations, allegations similar to those against my 25 client, and to show that in none of the cases had www.phi sre orting.com EFTA00615710 590 1 prison time been given for the kinds of activities 2 that were alleged against my client. So, I 3 presented him with hundreds of -- 4 MR. INDYKE: I have to interrupt you. If 5 you are talking about what you did for 6 Mr. Epstein, which it sounds like you are, then 7 you are invading the attorney-client privilege 8 and work product. 9 A. I gave it to the prosecutor. 10 MR. INDYKE: I object, and I instruct you 11 not to answer. 12 BY MR. EDWARDS: 13 Q. My question is very narrow. 14 Do you remember attending a meeting with 15 Detective yourself and the State Attorney 16 wherein you made presentations using the website of 17 some of the victims, including 18 A. The three people that you mentioned were 19 not the only people at that meeting. 20 Q. I'm not insinuating that they are. Do you 21 remember those people being at the meeting? 22 A. I remember others as well, including 23 Mitchell Webber, who had done some of the research 24 for me on the case. 25 Q. I'm just asking do you remember this www.phi sre orting.com EFTA00615711 591 1 meeting? 2 A. I do, yes. 3 Q. If Detective says that the point 4 of your presentation was to attack the credibility 5 of the witnesses, is that accurate? 6 A. No. The point of my meeting 7 Q. I'm only asking for yes or no. 8 A. I have to do more than yes or no. 9 SPECIAL MASTER POZZUOLI: The initial 10 answer was? 11 A. No. And now explain. The point was to 12 get a reduction in sentence and to get the best 13 possible deal I could get for my client. That 14 included giving comparative sentencing data about 15 other cases and included raising questions about the 16 17 18 19 20 21 against my client, which is -- I've done that many, 22 many times, and so has every other criminal lawyer I 23 know. 24 BY MR. EDWARDS: 25 Q. And if Detective says it was Alan credibility of the witnesses and included showing documentation that some of the witnesses had provided false documentation about their age. It was a general presentation to a prosecutor to try to mitigate the allegations www.phi sre orting.com EFTA00615712 592 1 Dershowitz that was making the presentation on 2 Mr. Epstein's behalf to discredit the victims, that 3 would be a true statement in part? 4 A. Alan Dershowitz made a presentation in 5 general that included truthful statements about the 6 witnesses, the truth of which tended to discredit 7 some of their testimony, yes. 8 Q. If Detective IIIIIII was asked, in fact, 9 "Was he, Alan, trying to convey to the State 10 Attorney's Office that you should not believe these 11 girls that they were at his house at all because 12 they have credibility problems," and he answered, 13 "That was the impression I received, yes" 14 A. Totally false impression. 15 Q. This is something that Detective 16 if he said that, he's lying? 17 A. No, I didn't say he's lying. You're 18 putting words in my mouth. I said it's a false 19 impression. He didn't say it definitely happened. 20 He said that's the impression he had. 21 I didn't ever say that these people were 22 not at Jeffrey Epstein's house. That was not part 23 of my defense. I never said that to anybody about 24 any of the people involved in this case. The 25 defense was very different. And Mitch Webber, who www.phi sre orting.com EFTA00615713 593 1 was there, and probably the State Attorney will 2 confirm that. 3 Q. Okay. Going to the police report of 4 on page 40 it begins, is she one of the victims that 5 you tried to discredit during this meeting we're 6 discussing? 7 A. My recollection is that was one of 8 the accusers, and we had -- 9 MR. INDYKE: Objection. I'm sorry, I'm 10 trying to give you some leeway, but I object on 11 the same basis that I objected previously. And 12 I believe this was also treading settlement 13 negotiations on behalf of Mr. Epstein with the 14 police department. Again, this is -- so I 15 instruct you not to answer to the extent it 16 invades privilege. 17 THE WITNESS: So I just understand, are 18 you alleging a negotiation privilege, too? 19 MR. INDYKE: Yes. I don't want you 20 talking about -- 21 THE WITNESS: Clearly, it's covered by 22 negotiation, and it would take incredible -- 23 well, I'm not going to say it. This was 24 clearly a negotiation. Are they asserting a 25 negotiation privilege? I would like to hear www.phi sre orting.com EFTA00615714 594 1 that. 2 MR. INDYKE: Yes. 3 MR. SCAROLA: It's being asserted by 4 Mr. Epstein's counsel. 5 THE WITNESS: Are you challenging the 6 negotiation privilege? 7 MR. SCAROLA: We're asking the question. 8 MR. EDWARDS: Are we challenging it? 9 Absolutely. 10 THE WITNESS: Good. 11 MR. SIMPSON: Just wait for a question. 12 MR. EDWARDS: It's not getting us 13 anywhere. 14 MR. INDYKE: I would instruct you not to 15 answer that question to the extent it invades 16 that privilege. 17 THE WITNESS: I think we need a ruling on 18 negotiation privilege. 19 MR. SCAROLA: I don't think we get that 20 ruling in the context of this deposition. 21 THE WITNESS: Well, you're asking me a 22 question -- 23 MR. SCOTT: There's no question pending. 24 BY MR. EDWARDS: 25 Q. Do you remember . as being one of the www.phi sre orting.com EFTA00615715 595 1 victims that explained that she was also made to 2 have sexual relations with 3 A. No, I have no recollection. 4 MR. INDYKE: Same objection, same 5 instruction. 6 BY MR. EDWARDS: 7 Q. Do you remember ■ being one of the 8 victims sa in that Epstein bragged that he bought 9 from her family in to be 10 his sex slave? 11 MR. INDYKE: Same objection, same 12 instruction. 13 BY MR. EDWARDS: 14 Q. Do you remember -- do you know how it was 15 that obtained a visa in this 16 country? 17 A. No, absolutely not. 18 MR. INDYKE: Same objection, same 19 instruction. 20 BY MR. EDWARDS: 21 Q. Were you a part of the negotiation with 22 the U.S. Attorney's Office to protect against immigration charges? 24 A. I was not aware that there was any 25 negotiation relating to her. www.phi sre orting.com EFTA00615716 596 1 MR. INDYKE: Same objection, same 2 instruction. 3 BY MR. EDWARDS: 4 Q. Are you aware that told the police 5 that she had massagers, vibrators and strap-on 6 rubber penises used on her? 7 MR. INDYKE: Same objection, same 8 instruction. 9 MR. SCOTT: If that is privileged, then 10 don't answer it. 11 BY MR. EDWARDS: 12 Q. You're refusing to answer? 13 A. I'm not refusing to answer anything. I 14 have not refused to answer a single question today. 15 I'm instructed, I await the judge's ruling, and 16 whatever the judge says, I do. 17 SPECIAL MASTER POZZUOLI: There are now, I 18 count, four privilege issues that have been 19 raised separately. One deals with the 20 privilege issue directly and under the 21 representation of Mr. Epstein, the work product 22 issue that deals with the scope of the 23 representation of Mr. Epstein, the joint 24 defense agreement and common interest 25 privilege, and now as well as a negotiation www.phi sre orting.com EFTA00615717 597 1 privilege. 2 And for my purposes, in fairness to all 3 the parties, I do think that is something that 4 has to be subject to a set of facts on some of 5 them and fuller briefing of law, and that 6 requires -- I'm happy to hear it, but I think 7 it would be even in the purview of a separate 8 hearing from today, whether it's in front of me 9 or in front of directly Judge Lynch. 10 BY MR. EDWARDS: 11 Q. Do you remember III. saying that Epstein 12 turned her on her stomach on the massage bed and 13 began to pump his penis in her vagina? 14 MR. INDYKE: Same objection, same 15 instruction. 16 BY MR. EDWARDS: 17 Q. I'm going to read this into the record and 18 then we'll get the objection and then we'll -- 19 MR. INDYKE: I apologize. I'm not there, 20 so I'm not clear when you're finished. I just 21 want to make sure I make the objection before 22 Mr. Dershowitz responds. 23 BY MR. EDWARDS: 24 Q. then became upset over this. She 25 said her head was being held against the bed www.phi sre orting.com EFTA00615718 598 1 forcibly as he continued to pump inside her. She 2 screamed no, and Epstein stopped. She told him that 3 she did not want to have him inside of her. Epstein 4 apologized and subsequently paid her a thousand 5 dollars." 6 Does that refresh your recollection as to 7 8 MR. INDYKE: Same objection, same 9 instruction. 10 BY MR. EDWARDS: 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615719 599 1 BY MR. EDWARDS: 2 Q. Do you believe, then, that it was a 3 different victim that Jeffrey Epstein forcibly raped 4 and that had a long history of lying, theft and 5 blaming others for her crimes other than 6 MR. SCOTT: Object to the form. 7 MR. INDYKE: Same objection, same 8 instruction. 9 MR. SCOTT: Argumentative and relevancy. 10 This whole line. 11 A. I guess I have to answer? 12 SPECIAL MASTER POZZUOLI: No. 13 A. I just want to make one point in response, 14 though, and that is the quotes from the Mail, of the 15 three paragraphs, the first two are not in quotation 16 marks, they are not quoting me directly, they're not 17 in quotation marks, and I do not remember saying 18 those. 19 Only the third one is in quotation marks, 20 and only had a long record of lying, theft and 21 blaming others for her crimes, and I think that 22 comes from a court document. And I think if you 23 check, you would see that quotation comes from a 24 court document. So I have not been quoted by the 25 Daily Mail, and I do not think I ever spoke to www.phi sre orting.com EFTA00615720 600 1 Ms. Churchill. 2 BY MR. EDWARDS: 3 Q. You don't deny, though, that in reading 4 the Daily Mail article in your hand that the Daily 5 Mail has attributed each of those statements to you, 6 whether quoted or not? 7 MR. SCOTT: Objection, form, totally 8 improper examination. 9 BY MR. EDWARDS: 10 Q. You can answer. 11 SPECIAL MASTER POZZUOLI: You can answer. 12 A. Oh, sure. I have no memory of having had 13 an interview with the Daily Mail. They do attribute 14 statements to me, but not in quotes, and that's 15 always a red flag. When you see statements 16 attributed to somebody in the newspaper and there 17 are no quotes, any reasonable lawyer or reader would 18 question whether there, in fact, had been such a 19 conversation because if there had been such a 20 conversation, any good journalist would put it in 21 quotes. And many of the things article are in 22 quotes, but my statements are not in quotes other 23 than the last statement, which I think comes from a 24 legal document. 25 And at the time I made any statement about www.phi sre orting.com EFTA00615721 601 1 this -- about a woman with a long record of lying, I 2 don't think I was making it about somebody who 3 claimed to have been raped. I have no recollection 4 as I sit here now that anybody ever claimed to have 5 been raped by Jeffrey Epstein. I mean forcibly 6 raped in the way that you described it in that 7 document. That was not part of my negotiation with 8 the D.A. The D.A. never accused -- 9 MR. INDYKE: Objection. 10 BY MR. EDWARDS: 11 Q. But that document that I was reading from 12 is the public police report that is available to 13 everybody. You recognize that, right? 14 A. But the D.A. obviously didn't put much 15 credit in that because he never charged him with 16 that. So that was not one of the things that I was 17 dealing with. 18 What I was dealing with was two charges -- 19 MR. INDYKE: Objection. 20 A. -- of massages with underage sex. That 21 was what I was dealing with. That's what any 22 comments I may have made dealt with. There was 23 never an allegation of forcible rape made by any 24 responsible prosecutor in this case. 25 www.phi sre orting.com EFTA00615722 602 1 BY MR. EDWARDS: 2 Q. Isn't the comment, that's attributed to 3 you, doesn't it specifically say he, talking about 4 Alan Dershowitz, said that the girl who accused 5 Epstein of forcible sex had a long record of lying, 6 theft and blaming others for her crimes? That's -- 7 A. I categorically deny having said that in a 8 context of a statement about forcible sex. What the 9 Mail probably did is they juxtaposed their view 10 based on these articles that it was forcible sex and 11 assumed somehow that what I was saying related to 12 her. That's not what I said. That I remember quite 13 unequivocally. 14 Q. is particularly one of the victims -- 15 A. is not mentioned in this article. 16 Q. No, no, is one of the victims whose 17 MySpace page you used to give a presentation to the 18 State Attorney's Office about her credibility, isn't 19 it? 20 MR. SCOTT: Let me object. Argumentative. 21 We've been through this five times. 22 MR. INDYKE: Objection, same instruction. 23 SPECIAL MASTER POZZUOLI: How much further 24 do you have on this line of questions because I 25 will be -- www.phi sre orting.com EFTA00615723 603 1 MR. EDWARDS: I just want to get an 2 answer, that's it. I want to get answers. 3 SPECIAL MASTER POZZUOLI: But the point is 4 well made that the way this article is 5 constructed, it's meant to -- really the only 6 thing that's quoted here based upon this 7 article is "had a long record of lying, theft 8 and blaming others for her crimes." 9 The rest of it is not. And so you don't 10 know the source. Based upon what you've 11 already elicited from the witness, he doesn't 12 remember even talking to the Mail. And so I 13 don't want impact your line of questioning. 14 I've let you go on this. But how much further 15 do you have? 16 MR. EDWARDS: Okay, but I think I need to 17 put this in context, then, so that we kind of 18 understand what the point of this is. 19 This is a defamation action where we've 20 been accused of not performing any 21 investigation. So part of what we had to do is 22 what has she told us and what can we prove, and 23 what has he said in light of the evidence. 24 When we're weighing credibility, this is 25 one of the public statements that we have to www.phi sre orting.com EFTA00615724 604 1 weigh against the evidence. 2 SPECIAL MASTER POZZUOLI: And I've read 3 the pleadings, I've read the various arguments, 4 I've read the summary judgment that was filed, 5 and so I agree, that's why I've kind of let 6 this continue. But how much further? Because 7 I'm not so sure how much more information you 8 can get from him that you haven't gotten 9 already. 10 BY MR. EDWARDS: 11 Q. Are the three statements that are 12 attributed to you in the Daily Mail true or false? 13 MR. SCOTT: Asked and answered three 14 times. 15 MR. INDYKE: Same objection, same 16 instruction. 17 A. I have no knowledge, as I said today, as 18 to whether or not Jeffrey Epstein passed a lie 19 detector test. If I said it, and I don't recall 20 saying it, I assume it's true. I can check that. 21 So I assume statement one is true. Statement two, 22 "'The financier had paid for massages, but did not 23 engage in sex or erotic massages with any minors,' 24 the lawyer insisted," I have no recollection of 25 saying that. www.phi sre orting.com EFTA00615725 605 1 BY MR. EDWARDS: 2 Q. Can we start over and go back to the first 3 statement and finish that whole statement, and then 4 you tell me whether it's true or false? 5 A. Right. 6 Q. So the first statement is told the Mail -- 7 MR. INDYKE: If you are speaking about the 8 truth or falsity about these statements in any 9 manner to which I have I inserted my 10 objections, I would ask you not to answer the 11 question. 12 SPECIAL MASTER POZZUOLI: So in the 13 context of privilege that Mr. Epstein is 14 asserting, can you answer the question any 15 further than you have already? 16 THE WITNESS: Yes. I can. 17 SPECIAL MASTER POZZUOLI: Go ahead. 18 A. Our position was that he was innocent of 19 the allegations against him. They did not include 20 any allegations relating to forcible sex, they did 21 not include any of the things that you just read. 22 And our position was, and we stated it to 23 the State Attorney, that he was innocent of those 24 allegations, innocent of those statements. 25 I don't want to ever be held to statements www.phi sre orting.com EFTA00615726 606 1 that are not quoted, because particularly the Daily 2 Mail and other newspapers take tremendous liberties 3 with what you say. And therefore -- 4 BY MR. EDWARDS: 5 Q. I'm asking are they true or false? 6 A. Say it again. 7 Q. Are the statements true or false? 8 A. Statement one is passed the lie detector 9 test. 10 MR. INDYKE: Objection again. 11 A. I don't know the answer to that, but I 12 assume if I said it, it was true at the time. 13 Statement two, he was innocent of all the 14 allegations, that was the position that we took as 15 to the two women who had allegation against them. 16 the State Attorney obviously did not credit 17 .'s testimony because he never -- it would be 18 irresponsible for a State Attorney not to bring rape 19 charges against somebody who had done what you 20 allege from that police report had been done. 21 Obviously the State Attorney came to the conclusion 22 that there were real questions about her 23 credibility. 24 BY MR. EDWARDS: 25 Q. Is it true or false? www.phi sre orting.com EFTA00615727 607 1 A. The statements are true. 2 Q. All of them are true? 3 A. All of these statements, to the extent 4 that I made them, are true. 5 MR. INDYKE: Objection. 6 A. To the extent that I made these 7 statements, they are true, yes. And you should have 8 been on your guard when you saw that there were no 9 quotes, and you should have checked to see that the 10 one statement that was quoted probably appeared in a 11 legal document. And you should have checked with 12 Churchill to see if I ever spoke with her, because I 13 have absolutely no recollection of speaking with her 14 and I'm fairly confident I did not. 15 MR. EDWARDS: I move to strike the 16 unresponsive aspects of that answer beyond 17 whether they were true or false, which I 18 believe the witness has said the statements are 19 true. 20 A. That's not -- 21 MR. INDYKE: To the extent that the 22 witness was making that statement from 23 privileged information, I move to strike the 24 remainder of it. 25 SPECIAL MASTER POZZUOLI: To the extent www.phi sre orting.com EFTA00615728 608 1 that -- your motion on the privilege piece is 2 granted to the extent that that's what it's 3 based upon. 4 However, I would say to you that the 5 balance of the statement is in response to your 6 continued questions on it, so I'm going to 7 leave it be. You can be put in context in 8 argument with the Court. 9 MR. INDYKE: Okay. Thank you. 10 BY MR. EDWARDS: 11 Q. Did you write a letter or communicate to 12 the U.S. Attorney's Office that Mr. Epstein never 13 targeted minors? 14 A. I have no 15 MR. INDYKE: Same objection as to 16 settlement negotiations. 17 BY MR. EDWARDS: 18 Q. Is that a true statement that Mr. Epstein 19 never targeted minors? 20 SPECIAL MASTER POZZUOLI: Let me ask a 21 question about that. 22 Is there a copy of the letter? 23 MR. EDWARDS: Yes. 24 SPECIAL MASTER POZZUOLI: Is it in the 25 context of the negotiation between -- under the www.phi sre orting.com EFTA00615729 609 1 context of either Mr. Dershowitz or his team 2 representing Mr. Epstein with the State 3 Attorney's Office? 4 MR. EDWARDS: It is. And I will put on 5 the record something that everyone in this room 6 knows, which is that we have litigated in the 7 context of that case whether or not a privilege 8 extended between the defense attorneys for 9 Mr. Epstein and the government. 10 We had to battle both the government and 11 his defense attorneys on that all the way to 12 the 11th Circuit, and we have an 11th Circuit 13 opinion indicating that there is no such 14 privilege. 15 So to the extent it is being claimed, it 16 was already ruled there is no such privilege by 17 the 11th Circuit. 18 A. But -- 19 SPECIAL MASTER POZZUOLI: Hang on one 20 second. I'm at a disadvantage because you've 21 lived the case and this is my second day in the 22 case. So what who was party to the 11th 23 Circuit? Darren, were you involved with that, 24 or were you, Tom? 25 MR. SCOTT: No. www.phi sre orting.com EFTA00615730 610 1 MR. INDYKE: No, not directly. 2 MR. EDWARDS: Martin Weinberg and Roy 3 Black represented Jeffrey Epstein there. The 4 government, I believe, was represented by 5 in the argument. And we were the 6 other party. And we prevailed by written 7 opinion. I think that it -- 8 THE WITNESS: I'm personally delighted if 9 there is no negotiation privilege because the 10 negotiation privilege only has been invoked 11 against me -- 12 MR. SCAROLA: There's no question pending. 13 THE WITNESS: Sorry. Sorry. 14 MR. SCAROLA: We move to strike. 15 SPECIAL MASTER POZZUOLI: I would agree 16 with. Strike that last portion from the 17 witness. 18 If you can share the 11th Circuit opinion, 19 that would be appreciated. 20 MR. EDWARDS: Okay. 21 THE WITNESS: With us, too. 22 MR. SCOTT: I've never seen it. 23 MR. SIMPSON: I'm aware there is one. 24 MR. EDWARDS: Okay. Thank you, Rick. 25 MR. SCOTT: I've never seen or read the www.phi sre orting.com EFTA00615731 611 1 opinion, that's all I'm telling you. 2 BY MR. EDWARDS: 3 Q. Do you know Gerald Lefcourt? 4 A. I do. 5 Q. One of the cases -- when you were 6 outlining the five pieces of litigation, one of the 7 cases was the Crime Victim Rights Act that you 8 outlined? 9 A. I don't think I included that. That 10 brings it up to seven. Unless you're talking about 11 the case in front of Judge Marra. 12 Q. I'm going to show you what we'll mark as 13 the next consecutive exhibit, and I don't have a 14 clean copy, but it's okay. We can mark mine. 15 MR. SCOTT: Well, while we're doing that, 16 can we get the exhibits actually marked and 17 make sure we know which is which for the 18 record? 19 (Discussion off the record.) 20 (Thereupon, marked as Plaintiff 21 Exhibit 22.) 22 BY MR. EDWARDS: 23 Q. Can we go to page 13? Can we go to the 24 last page? And is that your signature? 25 A. No, it's not. www.phi sre orting.com EFTA00615732 612 1 Q. On the last page. 2 A. It is not. 3 Q. That's not your signature? 4 A. No. 5 Q. Who signed your name to this document? 6 A. I don't know, but I didn't sign it. It's 7 not my signature. It's not even close. 8 Q. Somebody forged your signature to this 9 document? 10 A. No, no, I don't know. It's not my 11 signature. You asked me the question is it my 12 signature. It is not my signature. You can check 13 it against hundreds of signatures. 14 Q. Did you have anything do with the 15 authoring of this letter? 16 A. My recollection -- I'd have to read the 17 letter -- is that I did some of the legal research. 18 My job was primarily to be the legal research 19 person. 20 MR. INDYKE: Objection. 21 BY MR. EDWARDS: 22 Q. I'm really just asking about this letter 23 and the authenticity of it. 24 A. I did not sign this letter. 25 Q. Did you authorize someone to sign your www.phi sre orting.com EFTA00615733 613 1 signature to this letter? 2 A. I have no recollection. But probably. I 3 can't imagine somebody sending a letter with my name 4 on it that wasn't somehow authorized. 5 Q. Is that something that you would do is 6 authorize somebody to sign your name to a letter? 7 A. I'm not responsible for who signed this 8 letter. I did not sign this letter. All I can tell 9 you is I know my signature, and nobody who knows my 10 signature would know this is not my signature. 11 Q. Okay. You do know Gerald Lefcourt? 12 A. Yeah. In fact, my name is even spelled 13 wrong, but it's okay. I know Gerald Lefcourt very 14 well, yeah. 15 Q. Was he authorized to sign your name to the 16 bottom of a letter? 17 A. I'm sure he must have been. I'm sure I 18 saw a draft of the letter at some point and said, 19 that's okay, or maybe he just assumed he can sign my 20 name because I had done the research, legal 21 research, the III you do of counsel, outside counsel 22 letters -- 23 MR. INDYKE: Objection. 24 A. but I don't have any distinct 25 recollection of this. www.phi sre orting.com EFTA00615734 614 1 BY MR. EDWARDS: 2 Q. You agree that the recipient of that 3 letter would believe that that was a letter authored 4 by you, given that it was purported to be your 5 signature at the bottom, wouldn't you agree? 6 A. A letter that I had some input to. No, 7 not necessarily. The first signature is Lefcourt. 8 I'm senior to him, older than him. Normally if I 9 wrote a letter, my name would come first. 10 Probably what should have been -- probably 11 it should have included my name as of counsel. 12 But -- but, again, I don't have any real 13 recollection of this letter. 14 Q. If we go to page 13, second paragraph -- 15 A. I don't see pages. 16 MR. SCOTT: Do you need time to review 17 this letter? 18 A. It's a long, long letter It would take 19 me over an hour to review it, probably take me an 20 hour to review it. There are no pages. Yours may 21 have pages; mine don't have pages. 22 BY MR. EDWARDS: 23 Q. In the top right, it starts "Jeffrey 24 Sloman," if you go down to that -- 25 A. Would you find it for me. www.phi sre orting.com EFTA00615735 615 1 2 3 4 5 6 7 Q. Sure. MR. SCOTT: Do you want to review the letter for few a minutes? Professor, do you want to review the letter for a few minutes? THE WITNESS: I see where it is. Let me first hear the question, and then I might want to review it. I think it's basically a legal 8 brief, if I recall correctly. Page 13. 9 BY MR. EDWARDS: 10 Q. Second paragraph. 11 A. I see it. 12 Q. Second sentence, "As we believe we 13 persuaded you at the June 26 meeting..." 14 Were you at the June 26 meeting? 15 A. I don't remember. I've been at several of 16 the meetings, but I can't give you a date. I can go 17 back in my calendars and see if I was at the June 26 18 meeting, 19 Q. 20 wouldn't 21 sentence 22 A. 23 Q. 24 A. 25 Q. but I don't have a current recollection. Given the two signatures at the bottom, a reasonable interpretation of that be "as we" Yes. -- "Alan and Gerald"? Yes. Comma, "Mr. Epstein never targeted www.phi sre orting.com EFTA00615736 616 1 minors." 2 Do you see that? 3 A. Yes. 4 Q. Is that a true statement? 5 A. That was the position -- 6 MR. INDYKE: Objection. Same objection on 7 any privilege, attorney-client, settlement 8 9 10 11 12 13 14 15 privilege. SPECIAL MASTER POZZUOLI: Can I see the document? MR. INDYKE: Object and instruct him not to answer. SPECIAL MASTER POZZUOLI: Hang on one second. THE WITNESS: Do you want to give it to me 16 overnight and we do it tomorrow? 17 MR. SCOTT: He needs to read the letter 18 MR. EDWARDS: To know whether that's a 19 truthful statement? 20 MR. SCOTT: He wants to read the letter 21 before he's examined on it. 22 MR. EDWARDS: He can read the statement 23 I'm going to ask him is that a truthful 24 statement. 25 MR. SCOTT: But he needs to read it in the www.phi sre orting.com EFTA00615737 617 1 1 context of the whole letter. That's what 2 you're entitled to do. He's entitled to read 3 the exhibits before he answers that. 4 MR. SCAROLA: We'll move on and we'll deal 5 with it tomorrow. He can read it overnight. 6 MR. SCOTT: You seem to be laughing at 7 things I say or smiling at them, and I 8 apologize if you do that, because I'm just 9 10 11 12 13 14 15 16 trying to protect my client -- MR. EDWARDS: I understand. MR. SCOTT: -- like you're trying to protect yours. And I wasn't laughing at you when we took Mr. Cassell's deposition. Seriously, I don't understand why you laughed several times. I don't get it. This is serious, and nobody is enjoying this. 17 SPECIAL MASTER POZZUOLI: Okay. 18 THE WITNESS: One laughs, one cries. 19 MR. EDWARDS: I think we're just waiting, 20 right? 21 MR. SCOTT: So he can make a copy 22 overnight and look at it. 23 SPECIAL MASTER POZZUOLI: That's fine. I 24 would suggest for purposes of tomorrow that a 25 copy of the letter be sent to counsel that's on www.phi sre orting.com EFTA00615738 618 1 the phone, too, so at least he can hear 2 argument around that letter rather than have 3 him be at a disadvantage. 4 MR. EDWARDS: It would have to be sent by 5 them. Jeffrey Epstein is not submitted to the 6 jurisdiction of the Court. 7 SPECIAL MASTER POZZUOLI: This is going to 8 be -- my guess is that it's going to be subject 9 to a full further inquiry, so let's just -- you 10 know, we'll skip to it. 11 MR. SCOTT: If I can have copies of the 12 exhibits ahead of time so we can look at them, 13 it would be helpful. We're going to be using 14 them to cross examine him. 15 MR. EDWARDS: I'm sorry, Tom. I will do 16 that. I was not prepared for the fact that 17 Mr. Dershowitz's signature's on the bottom of 18 something and he apparently didn't sign them. 19 I was blindsided, too. I thought this was a 20 letter he would be intimately familiar with 21 because I thought he had authored it. I didn't 22 realize somebody had signed his name to the 23 bottom of it. 24 And that's the cause of my laughter, 25 because I've personally never seen that before. www.phi sre orting.com EFTA00615739 619 9 10 BY 11 12 13 14 1 I've never seen that happen. 2 MR. SCOTT: I understand, but when you're 3 going to show -- I apologize, Mr. Pozzuoli, but 4 when you're going to show exhibits and ask 5 questions about them, you should anticipate 6 that the witness and his counsel would want to 7 see them. So you should have a copy of them. 8 I think that's basic good rules of a deposition. MR. EDWARDS: Q. Do you agree that in assessing your credibility on the subject matter of who was involved in the abuse of underage girls, that it would be fair and reasonable to assess the 15 statements that you made during and surrounding that 16 investigation against the available evidence? 17 MR. SCOTT: Objection -- 18 A. If that would be done, every criminal 19 defense lawyer in the country could be charged with 20 rape, with murder, with every other crime that he 21 defends his clients on the basis of. 22 I'm a criminal defense lawyer. I've been 23 teaching criminal defense law, I've been teaching 24 legal ethics in the context of criminal cases for 40 25 years. Lawyers are advocates. They assert www.phi sre orting.com EFTA00615740 620 1 positions given to them by clients. And the idea 2 that a lawyer asserts a position and, as a result of 3 that, is guilty of rape is the worst form of 4 McCarthyism imaginable. 5 Q. So your answer is you don't think it would 6 be fair to put your statements up against the 7 evidence when evaluating your credibility? 8 A. In the context that you've just stated, it 9 would be utterly unfair, in the context that you 10 have just stated, utterly unfair and unprofessional, 11 and you know better than that. If I were to judge 12 you by the same standards -- 13 SPECIAL MASTER POZZUOLI: Okay. 14 BY MR. EDWARDS: 15 Q. Because this case is about an initial 16 allegation of unprofessionalism, I want to 17 investigate that last statement. And let me make 18 sure that I got it correctly. It would be 19 unprofessional of me to assess or any lawyer to 20 assess your credibility by -- 21 MR. SCOTT: Listen to the question. 22 BY MR. EDWARDS: 23 Q. -- statements that you have made 24 surrounding this particular case against the 25 backdrop of the available evidence that would be www.phi sre orting.com EFTA00615741 621 1 unprofessional? 2 A. Not only would it be unprofessional, it 3 would involve you also to accuse Jerry Lefcourt, to 4 accuse Roy Black, to accuse Ken Starr. All of us 5 stood behind our client's defense, and we were 6 successful. We persuaded the United States 7 Attorney's Office, persuaded the State Attorney's 8 Office of our position. 9 And you're saying that our advocacy and 10 persuasion is evidence that I committed a crime of 11 rape. That that is so unprofessional, so goes 12 against what the legal system is all about. And 13 would basically make it impossible for anybody to 14 defend alleged criminals in any criminal context. 15 Yes. 16 Q. Can you find a public statement that was 17 made by Roy Black or any of Epstein's other lawyers 18 that says that Jeffrey Epstein was innocent of all 19 charges or never engaged in an erotic massage or sex 20 with minors? 21 A. Yes, I'm sure that those positions were 22 stated universally by all the lawyers in all the 23 contexts, if they were stated -- I mean those kinds 24 of statements. I'm not saying those statements in 25 specific, because I don't know who made those www.phi sre orting.com EFTA00615742 622 1 statements. 2 But defending a client against charges, 3 trying to minimize the charges, are made by all 4 lawyers, and were made by all the lawyers in this 5 case, and have been made by you in cases. I'm sure 6 if I go back, I will find them. 7 Q. Okay. 8 MR. EDWARDS: I have a document we'll mark 9 as -- what's the next consecutive exhibit? 10 COURT REPORTER: Number 23. 11 (Thereupon, marked as Plaintiff 12 Exhibit 23.) 13 SPECIAL MASTER POZZUOLI: Will you mark 14 that as 22 so we don't forget? 15 MR. SIMPSON: Yes. 16 BY MR. EDWARDS: 17 Q. Can you look at the document that we've 18 marked as number 23? 19 A. Yes. 20 Q. My only question is going to be, did you 21 go to that speaking engagement that was scheduled? 22 MR. INDYKE: I didn't hear the question. 23 This is Darren. 24 MR. EDWARDS: I've shown him a document, 25 and it is a public document about a scheduled www.phi sre orting.com EFTA00615743 623 1 speaking engagement for Mr. Dershowitz, and I'm 2 just asking him whether or not he gave that 3 speech. 4 A. I don't recall that I did. 5 MR. INDYKE: Thank you. 6 BY MR. EDWARDS: 7 Q. Do you recall it being canceled or you not 8 going? 9 A. I don't recall me doing that speech. 10 Q. Okay. Do you remember it being scheduled? 11 A. I remember -- I don't remember 12 specifically, but I remember some general statement 13 that I had some speeches scheduled, yeah. 14 MR. EDWARDS: Do we have an extra copy of 15 the Daily Mail article? I thought we -- 16 VIDEOGRAPHER: Going off the record. The 17 time is approximately 4:26 p.m. 18 (Recess was held from 4:26 p.m. until 4:29 p.m.) 19 VIDEOGRAPHER: Going back on the record. 20 The time is approximately 4:29 p.m. 21 BY MR. EDWARDS: 22 Q. Are you aware from any nonprivileged 23 document or information that Jeffrey Epstein 24 referred to sex with underage girls as massages, 25 that that was a code word? www.phi sre orting.com EFTA00615744 624 1 A. No. 2 Q. In reviewing the message pads that were 3 taken from his home and the public police report, 4 have you been able to learn that fact? 5 A. I think it's false. I think it's a false 6 fact. When I was offered a massage at Jeffrey 7 Epstein's house, I received a legitimate massage by 8 a professional masseuse who hurt me. And I called 9 my wife and told her about it. I didn't enjoy it. 10 And I've been told by numerous people that they have 11 gotten ordinary massages, so I don't believe it was 12 a code word. I think that's false. 13 Q. Who told that you that they got ordinary 14 massages at Jeffrey Epstein's house? 15 A. People who were guests at the house. 16 Q. Exactly. 17 MR. INDYKE: I'm sorry? 18 A. My wife -- 19 MR. INDYKE: Can you repeat the question, 20 please. 21 MR. EDWARDS: Yes, I was just asked for 22 the identity of the people who have told 23 Mr. Dershowitz that they have received 24 legitimate massages at Jeffrey Epstein's home. 25 MR. INDYKE: I object to that question and www.phi sre orting.com EFTA00615745 625 1 2 3 4 5 6 7 the response to the extent it would invade privileges that we've already discussed, and instruct Alan not to answer. SPECIAL MASTER POZZUOLI: I think you can answer it outside the privilege. A. Virtually everybody that -- when I was at Jeffrey Epstein's house in Palm Beach, not in 8 New York -- I never heard the word "massage" used in 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 New York, but in Palm Beach, he would offer -- you would get an offer of massage, and people would accept it or not. But I never heard massage being anything other than an ordinary therapeutic massage. And I think it's insulting to professional massage therapists to assume that every massage -- I mean, it was like -- BY MR. EDWARDS: Q. Maybe I communicated my question poorly. I was actually asking for the names of the people who told you -- A. I told you my wife, my daughter, myself. I'll try to think of other names, but I remember people telling me Jeffrey Epstein's Q. Anybody that they had received massages at house. outside of your immediate family? A. Yes, but I'm having trouble remembering www.phi sre orting.com EFTA00615746 626 1 specifically who they were. 2 Q. Okay. 3 MR. INDYKE: Outside of subject to not 4 privilege, you're saying? 5 A. Right, yeah. 6 BY MR. EDWARDS: 7 Q. Do you remember speaking with the Daily 8 Mail on or around January 21, 2015, and saying -- 9 Dershowitz said the statements are all lies and "I 10 never got a massage from anybody, it's made up out 11 of whole cloth"? 12 A. No, I never said. 13 Q. If I showed you the statement, would it 14 help refresh your recollection? 15 A. No, because it's false. I never said that 16 I never got a massage because I said immediately 17 from day one that I got one massage. I said that 18 immediately. I described the massage. I might have 19 been asked did I get a massage from . The answer would be no. Did I get massage 21 during the relevant period of time? The answer 22 would be no. 23 But I never stated, and I would challenge 24 you to come up with -- no, with a tape recording of 25 me saying that in full context because that's not www.phi sre orting.com EFTA00615747 627 1 what I said. I've always said that I received one 2 massage. 3 4 5 6 7 Q. What does the quote say? 8 A. And, in fact, I said specifically that I 9 kept my underpants on. I was very specific about 10 the massage that it was -- I think it was a woman 11 from a Russian background. I was very clear. So to 12 say that I said that I never got a massage is just 13 false. From day one, I said I got a massage. 14 SPECIAL MASTER POZZUOLI: You had another 15 question in the middle that. Go ahead. 16 BY MR. EDWARDS: 17 Q. Right. What does the quote attributed to 18 you in that article say? 19 MR. SIMPSON: The document hasn't even 20 been marked yet. 21 MR. EDWARDS: What are we up to, 24? 22 (Thereupon, marked as Plaintiff 23 Exhibit 24.) 24 A. It doesn't show what the question was. It 25 doesn't show the context. And like -- all lies. I said that, I think, on day one. And, again, you're dealing with the Daily Mail. The context would have to be did you get a massage from any underage girl or anything like that. I never said that. www.phi sre orting.com EFTA00615748 628 1 All lies. Obviously I was referring to what 2 said and what said 3 about me, so that was the "all lies." 4 BY MR. EDWARDS: 5 Q. I'm asking what is the quote about the 6 massages? What are the words that are used? 7 A. "I never got a massage from anybody, it's 8 made up out of whole cloth." I did not say that. 9 Q. Okay. So the reporter -- 10 A. Is wrong. 11 Q. -- is wrong? 12 A. Who is the reporter? Is it the same 13 Ms. Churchill? 14 So this is an article you said, again, 15 the Daily Mail. This sounds like it's the Daily 16 News, not the Daily Mail. 17 Q. Okay. 18 A. But it's not true. I never said in the 19 context of generally massage. Because why would I 20 say that if I said it on television, I said it on 21 the radio, I've said it over and over again that I 22 got a massage? 23 Q. You deny making the statement that was 24 attributed to you in the Daily Mail article that's 25 attached to the deposition as Exhibit 24? www.phi sre orting.com EFTA00615749 629 1 A. That's right. 2 Q. Okay. It does say the Daily News. 3 A. Or -- now, let me be very clear. If I 4 said it, I said it in the context of 5 Q. Daily News. 6 A. If I said it, I said it in the context of 7 ' massage or a massage during the 8 relevant period because I never would say that I 9 didn't get a massage when I got one, and I always 10 said I did. 11 Go back and check earlier statements, 12 statements before this, and you'll see that I said 13 it. So what sense would it make for me to say that 14 I didn't get it? 15 Q. So is your testimony that you only had one 16 massage at Mr. Epstein's home? 17 A. That's -- let me be very clear. I never 18 had a massage in the New York place. I of course 19 never had a massage in the -- in the ranch. I have 20 no recollection of having a massage -- I never had a 21 massage on airplane. And I had one massage in the 22 Palm Beach home. 23 Q. What year it was that you had the massage 24 in the Palm Beach home? 25 A. I don't know, but I suspect it was in -- www.phi sre orting.com EFTA00615750 630 1 very early in my friendship or my acquaintanceship 2 with Jeffrey Epstein, probably '96 or '97, but I 3 would be guessing. 4 It was not during the relevant time period 5 because I was not in Jeffrey Epstein's -- my records 6 show I was not in Jeffrey Epstein's home in Palm 7 Beach during the relevant time period, so I couldn't 8 have had a massage during that period. 9 Q. So is it your testimony, then, that the 10 only massage we're getting some background from 11 the phone. 12 MR. SIMPSON: On the phone, there's some 13 background. 14 MR. INDYKE: Am I the only one on the 15 phone? This is Darren. Because if I'm not -- 16 (Discussion off the record.) 17 BY MR. EDWARDS: 18 Q. So is your testimony today that at any of 19 Jeffrey Epstein's homes, you have only had one 20 massage, and that was only at the Palm Beach home 21 and it was sometime in the mid to later '90s? 22 A. No, let me be very clear. I know for 23 absolute certainty I never had a massage in the 24 New York home. I know for absolute certainty I 25 never had a massage in the ranch. www.phi sre orting.com EFTA00615751 631 1 I do recall having one massage in the Palm 2 Beach home. I do know for certain that I never had 3 a massage in the airplane. And I'm fairly certain I 4 never had a massage at the -- on the island. 5 Q. And the one massage that you had at the 6 Palm Beach home was sometime early in your 7 relationship with Jeffrey Epstein, '96 or '97 8 approximately? 9 A. I'm not sure. I'm not sure about that. I 10 just don't remember exactly when it was. But it 11 wasn't -- obviously it was when I was in his house, 12 and the records show that I wasn't in his house 13 during the relevant time period. 14 Q. Is it your memory, though, that it was in 15 the '90s? 16 A. I can't remember. It could have been -- 17 it could have been later. I know that when my 18 children and grandchildren came to stay at Jeffrey 19 Epstein's house in 2005, I think there was some 20 massages that were -- oh, yeah, I think some of them 21 had massages. I did not -- 22 Q. But -- 23 A. -- is my recollection. 24 Q. But your massage was many years before 25 that experience in -- www.phi sre orting.com EFTA00615752 632 1 A. I think so, but I'm not sure. It could 2 have been later too. I just don't have any distinct 3 chronological frame of reference for when I had a 4 massage, but I do remember it very clearly and I 5 remember that it was painful and I remember that the 6 massage therapist wanted to put her knees on my 7 shoulder, and I called my wife immediately after I 8 had the massage and told her that this therapist 9 wanted to put her knees on my shoulder and I said I 10 wasn't really anxious to have that, because she had 11 hurt me. She was a very deep therapy massage 12 person. 13 Q. Have you seen Juan Alessi's testimony 14 wherein he indicates that you had massages at 15 Jeffrey Epstein's home? 16 A. Would you show it to me, please. 17 MR. INDYKE: Same objection and 18 instruction. 19 MR. SCOTT: Didn't we cover this with 20 Mr. Scarola the last time, the massage issue? 21 I could be wrong. 22 THE WITNESS: I was asked about it last 23 time. 24 MR. SCOTT: Last time I think I covered 25 this. www.phi sre orting.com EFTA00615753 633 1 SPECIAL MASTER POZZUOLI: Is this the 2 deposition from this matter? 3 MR. EDWARDS: The deposition that was in 4 the civil matters against Jeffrey Epstein, and 5 I think I've bracketed each of the pertinent 6 parts. 7 A. I don't see him saying more than one 8 massage. It says, "Did he have massages sometimes 9 when he was there? 10 "Yes. A massage was like a treat for 11 everybody. If they wanted, we called the massage 12 and they had a massage." 13 That doesn't sound to me like it's very 14 specific. I was offered massages on numerous 15 occasions by the house staff, and I said no. I did 16 have that one massage. And then you have bracketed 17 material about big dildos. That clearly refers to 18 an area of the house that I was never in, never 19 allowed into. Do you have any other brackets 20 material? 21 BY MR. EDWARDS: 22 Q. Not for this question. 23 A. So this is not any statement that I had 24 massages or multiple massages, doesn't contradict 25 what I said at all. He's testifying as to the www.phi sre orting.com EFTA00615754 634 1 general procedure, and he's right, people were 2 offered massages, and they were real massages, the 3 ones that I know about. 4 Q. Okay. Well -- 5 A. Let me say this. Jeffrey Epstein would 6 never dare to offer me an erotic massage. He would 7 know that I would walk out of that room so fast, I 8 would never speak to him again. He knows about my 9 relationship with my wife. He knows how much I love 10 her. He would never in a million years offer me 11 anything that was in any way improper, and he 12 didn't. 13 SPECIAL MASTER POZZUOLI: Brad, you have 14 five minutes before Jack smartly wants to get 15 out of here, so if you want to look for an 16 appropriate break. 17 MR. EDWARDS: I'll finish after -- a few 18 more questions on this, and then we're done. 19 BY MR. EDWARDS: 20 Q. Okay. The question was: 21 "Do you have any recollection of ■ coming to the house when Prince Andrew was 23 there? 24 "ANSWER: It could have been, but I'm not 25 sure." www.phi sre orting.com EFTA00615755 635 1 MR. INDYKE: Object -- 2 BY MR. EDWARDS: 3 Q. "QUESTION: When Mr. Dershowitz was 4 visiting 5 "ANSWER: Uh-huh. 6 "QUESTION -- how often did he come? 7 "ANSWER: He came pretty -- pretty often. 8 I would say at least four to five times a year. 9 "QUESTION: And how long would he 10 typically stay? 11 "ANSWER: Two, three days. 12 "QUESTION: Did he have massages sometimes 13 when he was there? 14 "ANSWER: Yes. A massage was like a treat 15 for everyone. If they wanted, we'd call the massage 16 and they have a massage." 17 He does indeed say that you stayed for two 18 or three days at a time and had plural massages, 19 right? That's his testimony. 20 A. No, he says I stayed for two or three 21 days. He doesn't say I was there with ■ And he says -- first of all, English is 23 not his first language, and he's talking about did 24 you have massages. "Yes, a massage is a treat for 25 everybody." www.phi sre orting.com EFTA00615756 636 1 I was offered massages. I had one 2 massage. Just -- I'm trying to think of something 3 else he said. Can I see it again, please? 4 BY MR. EDWARDS: 5 Q. The whole deposition? 6 A. Just that part of it. 7 The only time I stayed for -- he's right, 8 I stayed for two or three days with my wife, my 9 daughter-in-law, my son, and two grandchildren and 10 my daughter. We stayed for about five days. 11 Jeffrey Epstein was not in the house at that point 12 in time. 13 He found out we were looking for a 14 vacation place, and he offered his empty house with 15 the housekeeper and his wife, and we stayed there 16 during that period of time. 17 The only other time that I stayed for more 18 than one day was when I was involved in the case 19 with my research assistants. I stayed for two days 20 once with my nephew, Adam, who was coming to watch a 21 launch of the space shuttle. But I have no 22 recollection of ever staying three days alone. 23 There would be no reason I would do that. And I 24 didn't. 25 Q. While you were staying at the house, did www.phi sre orting.com EFTA00615757 637 1 Mr. Epstein have underage girls over to give him 2 massages? 3 A. Certainly not to my knowledge. If I had 4 seen a single underage girl in that house that 5 looked like she was there for any inappropriate 6 person, I would have been out of there 7 instantaneously. That would not be covered by the 8 lawyer-client privilege. And I would have called 9 the police and turned him in. That's how strongly I 10 feel about sex with underage people, male or female. 11 Q. Even though these girls were 14, 15, 16 12 years old? 13 A. I never saw -- not even though. 14 Especially. Of course. A fortiori. I never saw 15 anything like that, not on the airplane, not in the 16 ranch, not on the -- in the island, not in Palm 17 Beach, and not in New York. 18 MR. SCOTT: It's 4:45. 19 A. He did always travel with an entourage, 20 and he had people in his encourage who looked like 21 they were in their middle 20s. And, of course, 22 Mr. Scarola tried to accuse me of being on an plane 23 with an underage girl who turned out to be 25. 24 BY MR. EDWARDS: 25 www.phi sre orting.com EFTA00615758 638 1 Q. My last question, are you aware -- we can 2 pick back up here off of my last question. Are you 3 aware that another housekeeper, Alfredo Rodriguez, 4 put you in the home at a time when underage girls 5 were also in the home? 6 A. Would you please show me that? Because 7 your last question was a mischaracterization 8 MR. INDYKE: Same objection, same 9 instruction. 10 A. -- so let me see this one as well. 11 BY MR. EDWARDS: 12 Q. Sure. I'll just read it to you. 13 A. No, just let me see it. You can read it 14 to me. Let me see it. 15 Q. "And did you have knowledge of" -- 16 SPECIAL MASTER POZZUOLI: What are you 17 reading from? 18 MR. EDWARDS: Sure. It's the deposition 19 of Alfredo Rodriguez that was taken July 29, 20 2009. 21 BY MR. EDWARDS: 22 Q. "Was there a lawyer from Harvard named 23 Alan Dershowitz? 24 "Yes, ma'am. 25 "How often during the six months or so www.phi sre orting.com EFTA00615759 639 1 when you were there was Alan Dershowitz there?" 2 A. What were the six months, by the III? 3 Q. I don't know. We'll find out from his 4 employment with Jeffrey Epstein. Your client would 5 know. 6 "Two or three times. 7 "How did you have knowledge of why he was 10 11 12 friend? 13 14 15 at the time he was there? 16 17 18 instance, 19 20 21 22 23 24 25 8 visiting a -- and did you have knowledge of why he 9 was visiting? "No, ma'am. "Was he acting as a lawyer or there as a "ANSWER: I believe a friend. "Were there also young ladies in the house "ANSWER: Yes, ma'am. "And would those and have included, for "Yes, ma'am. "Were there other young ladies there when Mr. Dershowitz was there? "Yes, ma'am. "Do you have any idea who those young women were? "No, ma'am. www.phi sre orting.com EFTA00615760 640 1 "Were any of those young women that you 2 have said came to give massages? 3 "Yes, ma'am." 4 "Ms. Esell, who was representing at the time, asked you about Mr. Dershowitz 6 being present in Mr. Epstein's home, and I think she 7 said -- and I think you said Mr. Epstein was -- and 8 he and Mr. Dershowitz were friends? 9 "ANSWER: Yes. 10 "She also, I think, asked was 11 Mr. Dershowitz ever there when one of the women who 12 gave a massage was present in the home. 13 "ANSWER: I don't remember that. 14 "QUESTION: That's what I want to clear 15 up. Is it your testimony that Mr. Dershowitz was 16 there when any of the women came to Mr. Epstein's 17 home to give a massage? 18 "ANSWER: Yes. 19 "QUESTION: And when Mr. Dershowitz was at 20 the house, I understood you to say that these local 21 Palm Beach girls would come over to the house while 22 he was there, but you're not sure if he had a 23 massage from any of the girls. 24 "ANSWER: Exactly. 25 "QUESTION: And what would he do while the www.phi sre orting.com EFTA00615761 641 1 girls were in the house? 2 "He would read a book, glass of wine by 3 the pool or stay inside." 4 So my question is, are you aware that 5 Alfredo Rodriguez put you in Jeffrey Epstein's home 6 when the underage girls were coming to his home to 7 give massage? 8 A. Absolutely not. 9 MR. SIMPSON: Object to the form and 10 mischaracterizing and taking multiple separate 11 sections of a deposition and multiple different 12 pages read as though they were together. 13 Object to the form. 14 A. I'll answer. He talks about young 15 ladies -- 16 MR. SWEDER: I'm going to object to that, 17 too. This is Mr. Sweder. That is a misleading 18 reading of that deposition, leaving out a very 19 particular part of it -- 20 MR. EDWARDS: Okay. The whole 21 deposition -- 22 MR. SWEDER: -- that says that he didn't 23 know whether Dershowitz ever even saw these 24 young women. 25 MR. SCOTT: We covered this all in the www.phi sre orting.com EFTA00615762 642 1 last depo. 2 A. I never saw an underage person in Jeffrey 3 Epstein's house. I saw , who is a young 4 woman. I saw Giselle [sic] Maxwell, who is a young 5 woman. I saw women in their late 20s and 30s. 6 I never had a massage from any of these 7 young women. There's no mention of underage in the 8 entire deposition. And you again willfully and 9 deliberately misstated what you said the deposition 10 said, just like you misstated the deposition of 11 Mr. Rodriguez. 12 Q. Okay. The deposition will speak for 13 itself whether or not there's any mention of 14 underage women in the deposition. 15 A. Will you again point to met to the 16 underage? Point me to the word "underage" in that 17 deposition. 18 Q. I understand your statement that there is 19 not one. 20 A. There is not one, okay. I'm glad we have 21 that acknowledgment. 22 Q. I didn't acknowledge that. It's just not 23 true. 24 SPECIAL MASTER POZZUOLI: Is there any 25 other questions at this point? www.phi sre orting.com EFTA00615763 643 1 MR. EDWARDS: This is a good breaking 2 point. 3 VIDEOGRAPHER: Going off the record. The 4 time is approximately 4:49 p.m. 5 SPECIAL MASTER POZZUOLI: We're 6 reconvening 9:00 tomorrow? 7 MR. EDWARDS: Yes. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615764 644 CERTIFICATE OF OATH STATE OF FLORIDA COUNTY OF BROWARD I, the undersigned authority, certify that ALAN M. DERSHOWITZ personally appeared before me and was duly sworn on the 12th day of January, 2016. Signed this 14th day of January, 2016. 0 t a ( :4 • ,.. 6 g 4 ?-44c144,4/ . I BERLY FON::::RPR, CLR Notary Public, State of Florida My Commission No. FF 226848 Expires: 7/12/2019 www.phi sre orting.com EFTA00615765 645 CERTIFICATE OF REPORTER STATE OF FLORIDA COUNTY OF BROWARD I, KIMBERLY FONTALVO, Registered Professional Reporter, do hereby certify that I was authorized to and did stenographically report the foregoing videotape continued deposition of ALAN M. DERSHOWITZ; pages 462 through 455; that a review of the transcript was requested; and that the transcript is a true record of my stenographic notes. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. Dated this 14th day of January, 2016. KIMBERLY FONTALVO, RPR, CLR www.phi sre orting.com EFTA00615766 646 January 14, 2016 COLE, SCOTT & KISSANE, P.A. 10111111111111 BY: THOMAS EMERSON SCOTT, JR., ESQ. Re: Bradley Edwards, et al., v. Alan M. Dershowitz Please take notice that on the 12th day of January, 2016, you gave your deposition in the above cause. At that time, you did not waive your signature. The above-addressed attorney has ordered a copy of this transcript and will make arrangements with you to read their copy. Please execute the Errata Sheet, which can be found at the back of the transcript, and have it returned to us for distribution to all parties. If you do not read and sign the deposition within a reasonable amount of time, the original, which has already been forwarded to the ordering attorney, may be filed with the Clerk of the Court. If you wish to waive your signature now, please sign your name in the blank at the bottom of this letter and return to the address listed below. Very truly yours, KIMBERLY FONTALVO, RPR, CLR J101111. I do hereby waive my signature. ALAN M. DERSHOWITZ www.phi sre orting.com EFTA00615767 647 ERRATA SHEET DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE In Re: BRADLEY EDWARDS, ET AL., V. ALAN M. DERSHOWITZ Case No.: ALAN M. DERSHOWITZ January 12, 2016 PAGE LINE CHANGE REASON Under penalties of perjury, I declare that I have read the foregoing document and that the facts stated in it are true. Date ALAN M. 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