EFTA00601154

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1 
MR. SCOTT: Objection -- 
10:57:01 
2 
A. 
-- broken that promise. 
10:57:01 
3 
BY MR. SCAROLA: 
10:57:02 
4 
Q. 
You have not? 
10:57:02 
5 
A. 
No. 
10:57:02 
6 
Q. 
You don't think that they will be able to 
10:57:02 
7 
be identified by the first names that you have 
8 
given? The fact that they live in Palm Beach, and 
9 
the fact that 
lived together with 
10 
them for some period of time, that's not identifying 
11 
information? 
12 
A. 
Not -- 
10:57:18 
13 
MR. SCOTT: Objection. 
10:57:19 
14 
A. 
Not for the media, which is what they're 
10:57:19 
15 
concerned about. They're concerned about getting 
16 
calls from the media and being harassed. 
17 
BY MR. SCAROLA: 
10:57:25 
18 
Q. 
Well, you are aware of the fact that 
10:57:25 
19 
there's a press representative sitting in this room, 
20 
aren't you? 
21 
A. 
Yes. I don't think there's enough 
10:57:29 
22 
information for them to identify these folks unless 
23 
you provide them with that information. 
24 
Q. 
How long have you been a member of the 
10:57:37 
25 
Bar? 
EFTA00601214

62 
1 
A. 
Over 50 years. 
10:57:47 
2 
Q. 
And during that period of time, you've 
10:57:48 
3 
been involved in many, many litigated matters, 
4 
correct? 
5 
A. 
I'm mostly an appellate lawyer, but I have 
10:57:56 
6 
been involved in many appeals, yes. 
7 
Q. 
You do understand that you cannot make a 
10:58:01 
8 
binding promise to a potential witness that would 
9 
authorize you to withhold information that you are 
10 
required to give in the course of discovery 
11 
MR. SCOTT: Objection, form. 
10:58:22 
12 
BY MR. SCAROLA: 
10:58:22 
13 
Q. 
-- correct? 
10:58:22 
14 
A. 
I told them in the course of my 
10:58:23 
15 
conversations with them that I would not violate any 
16 
court orders, that I would not break the law, that I 
17 
would do my best to maintain what they wanted 
18 
because it was very important for me to get as much 
19 
information from them as I could. I did not want to 
20 
cut off my sources of information. I think I have a 
21 
right to obtain that information. 
22 
And so there was a back and forth. And 
10:58:49 
23 
ultimately I think we all realized ultimately 
24 
probably their names will be revealed, yes. 
25 
EFTA00601215

63 
1 
BY MR. SCAROLA: 
10:59:02 
2 
Q. 
What is their phone number? 
10:59:02 
3 
A. 
I don't have it. 
10:59:04 
4 
MR. SCOTT: You can make a request when 
10:59:06 
5 
you want to and we'll take it under 
6 
consideration for the information that you've 
7 
asked my client about. He's not the lawyer. I 
8 
am. There's confidentiality orders. I have to 
9 
review all of that. You can take whatever 
10 
appropriate discovery you want on that. 
11 
MR. SCAROLA: What -- what confidentiality 
10:59:17 
12 
orders? 
13 
MR. SCOTT: There's a confidentiality 
10:59:19 
14 
order by the Court. 
15 
MR. SCAROLA: That covers the phone number 
10:59:21 
16 
of a witness? 
17 
MR. SCOTT: That covers various issues and 
10:59:24 
18 
I have to review it. And so you can -- I'm 
19 
just telling you that you can make any formal 
20 
request you want and we will take it up. 
21 
BY MR. SCAROLA: 
10:59:33 
22 
Q. 
Was it your understanding in February of 
10:59:37 
23 
this year that you had the authority to withhold in 
24 
answers to interrogatories the names of these 
25 
individuals if questions were asked that called for 
EFTA00601216

64 
1 
the disclosure of those names? 
2 
MR. SCOTT: Objection, asked and answered 
10:59:58 
3 
several times. 
4 
A. 
Obviously I confer with my lawyers about 
11:00:00 
5 
matters of that kind. 
6 
BY MR. SCAROLA: 
11:00:05 
7 
Q. 
That's not my question to you. Was it 
11:00:05 
8 
your understanding in February of 2015, on 
9 
February 23, 2015, when you signed these answers to 
10 
interrogatories under oath, that you had the 
11 
authority to withhold the names of these individuals 
12 
who you claim to be witnesses? 
13 
MR. SCOTT: Objection, legal conclusion. 
11:00:27 
14 
A. 
I don't believe I had their names on 
11:00:28 
15 
February 23. I would have to check. But my belief 
16 
is that I didn't have their names. It took quite 
17 
quite a bit of effort for me to obtain their names 
18 
under promises of confidentiality. 
19 
I think these are very, very hard legal 
11:00:41 
20 
and ethical questions. There's obviously a right to 
21 
investigate and to try to get information, 
22 
particularly information that would proffer that 
23 
your clients had engaged in criminal actions, 
24 
subornation of perjury and pressuring witnesses. 
25 
And I know that many of you are former 
11:01:00 
EFTA00601217

65 
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 
prosecutors. I know that prosecutors also try very 
hard to obtain such information and make promises 
and the Courts have varying approaches to how these 
promises will be dealt with. 
So it was a complicated question. And I 
sought my legal advice based on it being a 
complicated question. 
BY MR. SCAROLA: 
Q. 
When did you first seek legal advice with 
regards to these matters? 
A. 
When I first found out about it, I told my 
lawyers that the information had come -- that it 
hadn't been -- I hadn't gotten permission. That I 
was getting it in dribs and drabs. And that I was 
anxious to pursue it. I told my lawyers not to call 
her at all, not to call them. Because I thought 
that would shut down the flow of information. 
Q. 
Which lawyers did you take these 
disclosures to? 
MR. SCOTT: Let him ask that question. 
MR. SIMPSON: Just the names. 
A. 
My recollection is Ken Sweder, and I would 
have to check my records but probably -- probably 
Mr. Simpson, probably. Probably Mr. Scott. But I'm 
not positive about Mr. Scott at this point, about 
11:01:18 
11:01:24 
11:01:25 
11:01:29 
11:01:53 
11:02:02 
11:02:04 
11:02:05 
EFTA00601218

66 
1 
Judge Scott. I'm not positive about that. 
2 
BY MR. SCAROLA: 
11:02:32 
3 
Q. 
And what is it that you disclosed to 
11:02:33 
4 
Mr. Sweder? 
5 
MR. SCOTT: Objection. Don't answer that. 
11:02:38 
6 
Attorney-client privilege and work product. 
7 
MR. SCAROLA: Our position is that it's 
11:02:41 
8 
already been waived voluntarily by virtue of 
9 
the testimony that was just given. 
10 
MR. SCOTT: I understand your position. 
11:02:45 
11 
We don't agree. 
12 
MR. SCAROLA: That's fine. I know you 
11:02:47 
13 
don't. 
14 
MR. SCOTT: Okay. 
11:02:49 
15 
BY MR. SCAROLA: 
11:02:49 
16 
Q. 
What information did you give to 
11:02:50 
17 
Mr. Simpson with regard to this --
18 
MR. SCOTT: Same objection. 
11:02:54 
19 
BY MR. SCAROLA: 
11:02:54 
20 
Q. 
-- communication? 
11:02:55 
21 
MR. SCOTT: Don't answer that. 
11:02:57 
22 
BY MR. SCAROLA: 
11:02:59 
23 
Q. 
And since you don't remember whether you 
11:03:00 
24 
did or did not tell Mr. Scott, I assume you don't 
25 
remember what information you may have given to 
EFTA00601219

67 
1 
Mr. Scott if you did speak to him; is that correct? 
2 
MR. SCOTT: The same objection. Don't 
11:03:08 
3 
answer that. 
4 
BY MR. SCAROLA: 
11:03:14 
5 
Q. 
Since you were -- well, did you make these 
11:03:15 
6 
disclosures to your lawyers as soon as you got the 
7 
first phone call? 
8 
MR. SCOTT: Objection. Don't answer that. 
11:03:29 
9 
BY MR. SCAROLA: 
11:03:33 
10 
Q. 
You obviously considered this to be a 
11:03:37 
11 
significant communication, correct? 
12 
A. 
Potentially -- 
11:03:41 
13 
MR. SCOTT: Objection, repetitious. 
11:03:42 
14 
You've asked that several times. 
15 
A. 
Potentially significant, but I did not 
11:03:44 
16 
know -- well, it was significant to me because it 
17 
confirmed my own knowledge that your clients had 
18 
engaged in behavior which was unprofessional and 
19 
possibly criminal. And it confirmed it in my own 
20 
mind. So it was very gratifying to me. 
21 
But I had -- didn't know at that point 
11:04:07 
22 
whether I could in any way use that information to 
23 
produce the truth in the litigation. I wasn't sure 
24 
of that. 
25 
EFTA00601220

68 
1 
BY MR. SCAROLA: 
11:04:16 
2 
Q. 
You knew that you might be able to and so 
11:04:17 
3 
it was significant to you 
4 
MR. SCOTT: Object. 
11:04:21 
5 
BY MR. SCAROLA: 
11:04:21 
6 
Q. 
-- is that correct? 
11:04:22 
7 
MR. SCOTT: Form. 
11:04:23 
8 
A. 
It was significant to me psychologically 
11:04:24 
9 
because it confirmed my firm belief that your 
10 
clients had engaged in unethical behavior, yes. 
11 
BY MR. SCAROLA: 
11:04:34 
12 
Q. 
As an experienced criminal defense lawyer, 
11:04:34 
13 
you certainly recognize the importance of a 
14 
contemporaneous record of significant 
15 
communications, don't you? 
16 
A. 
Sometimes. But it's more important to me 
11:04:45 
17 
to have the conversation and to try to be in the 
18 
moment and elicit the information. And that was 
19 
what my focus was at the time. 
20 
Q. 
Was there something that prevented you 
11:04:56 
21 
from taking contemporaneous notes with regard to 
22 
these communications? 
23 
A. 
I -- I generally don't take 
11:05:04 
24 
contemporaneous notes. 
25 
Q. 
That's not my question, sir. 
11:05:07 
EFTA00601221

69 
1 
MR. SCOTT: Don't cut him off, please. 
11:05:07 
2 
A. 
I generally don't take notes. I find that 
11:05:08 
3 
it's much more important to concentrate. In fact, I 
4 
tell my students in my classes not to take notes but 
5 
rather to listen, listen carefully to what's being 
6 
said. I'm not a particular advocate of note taking. 
7 
BY MR. SCAROLA: 
11:05:23 
8 
Q. 
And since you have a superb memory, the 
11:05:23 
9 
notes don't have much value to you? 
10 
A. 
In fact -- 
11:05:28 
11 
MR. SCOTT: Objection, form. 
11:05:29 
12 
A. 
In fact, my memory is one of the reasons 
11:05:30 
13 
that I don't focus on notes as much as some other 
14 
people may. 
15 
BY MR. SCAROLA: 
11:05:37 
16 
Q. 
So let's go through these conversations 
11:05:37 
17 
one at a time then. 
18 
A. 
Okay. 
11:05:40 
19 
Q. 
And I want you to tell us, based upon your 
11:05:41 
20 
superb memory, as best you are able to relate, 
21 
word-for-word exactly how the first conversation 
22 
went. 
23 
A. 
Okay. 
11:05:55 
24 
Q. 
Who placed the call to whom? 
11:05:56 
25 
A. 
The first conversation came as a result of 
11:05:59 
EFTA00601222

70 
1 
me getting a phone number from them by an e-mail or 
2 
text correspondence. I then placed -- this is my 
3 
best memory. I then placed the conversation and I 
4 
spoke to Michael. 
5 
Q. 
You then placed the phone call? 
11:06:19 
6 
A. 
I then placed the phone call. And I spoke 
11:06:20 
7 
to Michael. Michael told me that his wife, Rebecca, 
8 
felt terrible about what was going on in relation to 
9 
me, but that she was not willing to talk to me about 
10 
it. But he then said to me that if she did talk to 
11 
me, she would tell me that I was not mentioned by 
12 
ever previously until this case occurred, 
13 
and that she was pressured into mentioning me. 
14 
I said that would be important to me, I 
11:07:04 
15 
would really like to talk to Rebecca. 
16 
Well, he said, she's very emotional about 
11:07:07 
17 
this, she's a very close friend of 
, she 
18 
likes 
, and she just doesn't want to get 
19 
involved. 
20 
And I said, well, let's have -- please 
11:07:21 
21 
have her think about it. And let's see if we can 
22 
talk again. 
23 
I then made a second phone call. 
11:07:29 
24 
Q. 
I'm sorry, I was still on the first one. 
11:07:31 
25 
A. 
Okay. That was the first phone call. 
11:07:33 
EFTA00601223

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1 
That's about the first phone call. 
2 
Q. 
Thank you. All right. Now, during the 
11:07:36 
3 
course of that phone call, did you ever ask Michael, 
4 
why did you ask me to contact you if your wife 
5 
doesn't want to talk to me? 
6 
MR. SCOTT: Objection, form, 
11:07:46 
7 
argumentative. 
8 
A. 
I did not. 
11:07:48 
9 
BY MR. SCAROLA: 
11:07:48 
10 
Q. 
Why not? 
11:07:49 
11 
MR. SCOTT: Same objection. 
11:07:51 
12 
BY MR. SCAROLA: 
11:07:51 
13 
Q. 
Did that seem strange to you? 
11:07:51 
14 
A. 
No, never occurred to me. He was 
11:07:53 
15 
obviously reaching out to me. There was obviously 
16 
some ambivalence. They wanted to talk to me. They 
17 
didn't want to get involved. They were testing the 
18 
waters. They wanted to see if I was a reliable 
19 
person. I think they wanted to get a sense of me, 
20 
just as I was trying to get a sense of them. 
21 
Q. 
Did they tell you at that point in time 
11:08:16 
22 
that they lived in the Palm Beach area in the first 
23 
conversation? 
24 
MR. SCOTT: Same objection. 
11:08:25 
25 
A. 
I don't recall, but I think they did. I 
11:08:26 
EFTA00601224

72 
1 
think they did. 
2 
BY MR. SCAROLA: 
11:08:31 
3 
Q. 
They or he? 
11:08:31 
4 
A. 
He. He's the only one who spoke to me. I 
11:08:32 
5 
also had their phone number, which I think I recall 
6 
is in that area generally. I didn't know 
7 
specifically where they lived. I did not have their 
8 
address. 
9 
Q. 
Were arrangements made during the first 
11:08:52 
10 
conversation for a subsequent communication? 
11 
A. 
No. 
11:08:56 
12 
Q. 
Was any request made by you for a meeting? 
11:08:59 
13 
A. 
Yes. 
11:09:02 
14 
Q. 
Let me back up then, if I could, please. 
11:09:05 
15 
Because what I want you to do, based upon your 
16 
superb memory, is to tell us in as much detail as 
17 
you possibly can recall everything that was said. 
18 
And when I asked you to do that, you didn't say 
19 
anything about a request for a meeting. 
20 
A. 
I'm not sure -- 
11:09:28 
21 
MR. SCOTT: Objection, asked and answered. 
11:09:29 
22 
A. 
I'm not sure the request for the meeting 
11:09:30 
23 
came in the first call or the second call. But 
24 
there was ultimately a request for a meeting. It 
25 
wouldn't surprise me if it came in the first call. 
EFTA00601225

73 
1 
The first call was basically, I'd really 
11:09:41 
2 
like to talk to your wife about this. I'm happy to 
3 
fly down. I'm happy to talk to you on the phone. 
4 
And we left it that they would think -- that she 
5 
would -- that he would ask her to think about it. 
6 
And that I could call back in a -- in a few days and 
7 
find out what her -- what her current feelings were. 
8 
BY MR. SCAROLA: 
11:10:09 
9 
Q. 
Where were you when you received this 
11:10:09 
10 
phone call -- or when you made this phone call? 
11 
Sorry. 
12 
A. 
I think I was in New York. 
11:10:14 
13 
Q. 
Do you know whether that phone call was 
11:10:23 
14 
made on a cell phone or a landline? 
15 
A. 
I don't remember. 
11:10:26 
16 
Q. 
Have you attempted to gather your 
11:10:37 
17 
telephone records for purposes of responding to 
18 
discovery requests in this case? 
19 
A. 
I left that to my lawyers. I know that we 
11:10:47 
20 
did produce telephone records during the relevant 
21 
periods of time when 
knew Jeffrey 
22 
Epstein and those telephone records established that 
23 
I could not have been at the locations and at the 
24 
times that 
claimed to have had --
25 
falsely claimed to have sexual contact with me. 
EFTA00601226

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1 
Q. 
I promise you we're going to get to those. 
11:11:15 
2 
A. 
Good. 
11:11:18 
3 
Q. 
Promise you. Along with all the flight 
11:11:18 
4 
logs that you claim exonerate you. 
5 
A. 
Is that a question? 
11:11:25 
6 
Q. 
It wasn't. It was a comment. 
11:11:26 
7 
MR. SCOTT: I object. 
11:11:28 
8 
BY MR. SCAROLA: 
11:11:29 
9 
Q. 
In response to your comment. 
11:11:29 
10 
MR. SCOTT: Let me just say this to you, I 
11:11:31 
11 
think it's inappropriate to have comments by 
12 
counsel. 
13 
BY MR. SCAROLA: 
11:11:36 
14 
Q. 
Let's go to the very second contact that 
11:11:37 
15 
you had with either Michael or Rebecca. Who 
16 
initiated the second contact? 
17 
A. 
I think I did. I called and got Michael 
11:11:48 
18 
on the phone. 
19 
Q. 
Where did you call from? 
11:11:53 
20 
A. 
I think New York. 
11:11:54 
21 
Q. 
Tell me in as much detail as your superb 
11:12:02 
22 
memory allows you to recall everything that was said 
23 
during the course of that phone conversation. 
24 
MR. SCOTT: Let's object to the form and 
11:12:14 
25 
the continued use of the word "superb." He's 
EFTA00601227

75 
1 
described his memory. That's your 
2 
characterization. Go ahead. 
3 
MR. SCAROLA: No, I think that that was 
11:12:24 
4 
Mr. Dershowitz's characterization, which I have 
5 
adopted. 
6 
MR. SCOTT: Okay. Go ahead. 
11:12:29 
7 
A. 
I called, spoke to Michael. I asked 
11:12:31 
8 
Michael if he had spoken to his wife. She said yes 
9 
and she was still reluctant to talk to me. 
10 
BY MR. SCAROLA: 
11:12:41 
11 
Q. 
I'm sorry, she said yes when you asked 
11:12:41 
12 
Michael if he had spoken to his wife? 
13 
A. 
He said yes. And that she was still 
11:12:46 
14 
reluctant to talk to me. I suggested to him that 
15 
perhaps she could talk to me briefly just so that 
16 
she hears what I have to say. And he could listen 
17 
and remain on the phone and she could stop at any 
18 
time she wanted. 
19 
And there came a time during that 
11:13:07 
20 
conversation when she did get on the phone, and 
21 
here's what she told me. She said she had grown up 
22 
with 
. That they were very, very 
23 
close friends as young people. That 
24 
came to stay with her for a number of days, 
25 
I think it was over Halloween, and they had gone out 
EFTA00601228

76 
1 
and had dinner, just the two of them. And that she 
2 
confided in her, 
confided in 
3 
Rebecca that she had never wanted to mention me in 
4 
any of the pleadings, but she was pressured by her 
5 
lawyer into doing so. 
6 
Rebecca then said that I was not the 
11:14:09 
7 
object of this effort. The object of the effort was 
8 
a billionaire who lives in Columbus, Ohio and who 
9 
owns Victoria's Secret and the Limited, Too. 
10 
Rebecca told me she did not know the name of that 
11 
billionaire, but that 
and her lawyers hoped 
12 
to get 1 billion, B-I-I-I-I-O-N, $1 billion or half 
13 
of his net worth from him by alleging that he had 
14 
improperly engaged in sexual misconduct with 
15 
16 
That that money would be divided three 
11:15:12 
17 
ways: A third of it to 
, a third of 
18 
it to a charity that she and her lawyers were 
19 
setting up for battered women, and a third of it to 
20 
the lawyers. 
21 
She then told me that they were trying to 
11:15:35 
22 
get ABC News to interview 
so as to 
23 
give her credibility in order to pressure the 
24 
billionaire from Columbus, Ohio into paying a large 
25 
sum of money. And that I was named as an effort to 
EFTA00601229

77 
1 
try to show the billionaire what could happen to 
2 
somebody if they were accused of sexual misconduct. 
3 
And that would encourage him to settle a lawsuit or 
4 
pay money in exchange for his name not being 
5 
mentioned or revealed. 
6 
I had no idea about this. And I didn't -- 
11:16:44 
7 
I didn't ask about this. She just stated this. And 
8 
I then corroborated the fact that she was absolutely 
9 
correct in everything she had said to me. 
10 
Q. 
You corroborated the fact that she was 
11:17:09 
11 
absolutely correct in everything that she had said 
12 
to you? 
13 
A. 
That's right. 
11:17:15 
14 
Q. 
How? 
11:17:20 
15 
A. 
Okay. Let me answer that question. I was 
11:17:21 
16 
very -- I wasn't sure, so I called Leslie Wexner. I 
17 
got his wife on the phone, Abigail Wexner. 
18 
Obviously I knew that the only billionaire in 
19 
Columbus, Ohio who owned Limited, Too and who owned 
20 
Victoria's Secret was Leslie Wexner. 
21 
I had met Leslie Wexner on two occasions, 
11:17:47 
22 
I think, and his wife. I called Abigail on the 
23 
phone and I said, I think you ought to know that 
24 
there is an extortion plot being directed against 
25 
your husband by unscrupulous lawyers in -- in 
EFTA00601230

78 
1 
Florida. 
2 
And she said, oh, we're aware of that, 
11:18:09 
3 
they've already been in contact with us, which 
4 
surprised me. But was confirmation of that. 
5 
I then also -- I can't give you the 
11:18:24 
6 
chronology of that. I then was in touch with ABC and 
7 
found out she was absolutely correct about her 
8 
efforts to try to get interviewed on ABC television. 
9 
In fact, I learned that your client, Brad 
11:18:41 
10 
Edwards, had sent a communication to people in 
11 
the -- in the area urging them to watch her 
12 
interview that was scheduled to be on three 
13 
television programs. If I'm not mistaken, it was 
14 
Good Day Show, the evening news, and the show 
15 
Nightline -- and Nightline. 
16 
I then was in communication with ABC and 
11:19:10 
17 
helped to persuade them that they would be putting 
18 
false information on the air if they allowed 
19 
to tell her false story. 
20 
So, I was able to corroborate that. I 
11:19:28 
21 
then also corroborated the fact that she had never 
22 
mentioned me when her boyfriend appeared on 
23 
television and publically stated that she had never 
24 
mentioned me in any of her description of people who 
25 
she had sexual contact with. 
EFTA00601231

79 
1 
So, I was then completely satisfied that 
11:19:53 
2 
Rebecca was telling me the complete truth. And that 
3 
in my view, there was an extortion plot directed 
4 
against Leslie Wexner, a criminal extortion plot 
5 
directed against Leslie Wexner, and that your 
6 
clients were involved in that extortion plot. 
7 
Q. 
If we were to try to fix the time of this 
11:20:16 
8 
second phone call, one way in which we would fix the 
9 
time of this second phone call, in addition to 
10 
getting your telephone records, would be to find out 
11 
when this ABC interview took place, correct? Since 
12 
the phone call you're telling us came after the ABC 
13 
interview, that you convinced ABC not to air? 
14 
A. 
No, I didn't state that. Let me be very 
11:20:51 
15 
clear. 
16 
I found out from her that there was going 
11:20:53 
17 
to be an ABC television interview. I don't think I 
18 
was aware of the fact that there was going to be a 
19 
television interview at that point. 
20 
I remember then getting a -- either a 
11:21:05 
21 
phone call or e-mail from ABC informing me of that. 
22 
And that corroborated to my mind the fact that she 
23 
was telling me the truth about the ABC interview. 
24 
She also told me -- and this was 
11:21:27 
25 
corroborated, she also told me that the television 
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80 
1 
interview with ABC had to be postponed because her 
2 
husband, 
' husband, had beaten her 
3 
up so badly that she was hospitalized and that she 
4 
could not appear on television with the bruises 
5 
because she didn't want to have to explain that her 
6 
husband had beaten her up. 
7 
And I ultimately corroborated that 
11:21:56 
8 
information as well by investigating the fact that 
9 
she, in fact, filed a complaint against her husband 
10 
and had been hospitalized. 
11 
So everything that Rebecca told me has 
11:22:08 
12 
proved to be absolutely true and absolutely 
13 
corroborated. And, therefore, I believe it and 
14 
believe that your clients were engaged in what I 
15 
believe is an extortion plot against Leslie Wexner, 
16 
conspiracy to commit extortion in which I was a 
17 
victim, as well as Leslie Wexner, of being a victim. 
18 
Q. 
Did you speak directly to Leslie Wexner or 
11:22:36 
19 
only to his wife? 
20 
A. 
Only to his wife and to his lawyers. 
11:22:41 
21 
Q. 
And you spoke by telephone? 
11:22:42 
22 
A. 
Yes. 
11:22:43 
23 
Q. 
Where were you and where was she? 
11:22:44 
24 
A. 
I called from, I think, New York and I 
11:22:48 
25 
spoke to her about it. I told her what I said I 
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