EFTA00601154

121 
1 
So, yes, I did -- you know, Mr. Edwards, 
12:28:55 
2 
your client, is shaking his head, but when he's 
3 
deposed under oath, he's not going to be able to 
4 
simply shake his head. He's going to have to answer 
5 
specific and direct questions. 
6 
BY MR. SCAROLA: 
12:29:11 
7 
Q. 
Let me try my question. 
12:29:12 
8 
Did you charge Bradley Edwards and 
12:29:16 
9 
Professor Paul Cassell in your mass media 
10 
appearances with fabricating false charges against 
11 
you? 
12 
MR. SCOTT: Objection, form. 
12:29:29 
13 
A. 
My media appearances were largely in 
12:29:33 
14 
response to media requests of me. I did not conduct 
15 
a media campaign. The object of my speaking to the 
16 
media was to respond to their questions. Their 
17 
questions were, number 1, did you ever have any 
18 
sexual contact with 
? And I 
19 
unequivocally stated no. 
20 
I stated that I knew there were no videos 
12:30:01 
21 
or photographs because the event didn't occur. 
22 
stated that I would submit a sworn affidavit, which 
23 
in effect waived the statute of limitations. I 
24 
stated unequivocally that I was innocent of those 
25 
false charges. 
EFTA00601274

122 
1 
I was then asked by the media, well, why 
12:30:29 
2 
would somebody who is a former federal judge and 
3 
professor at a law school make these false charges? 
4 
I responded to those questions. Why would somebody 
5 
like a distinguished personal injury lawyer make 
6 
those false charges? And I responded to those 
7 
questions. And everything I said was the truth as I 
8 
believed it to be at the time. 
9 
BY MR. SCAROLA: 
12:30:55 
10 
Q. 
Do you remember the question that was 
12:30:57 
11 
asked of you? 
12 
A. 
Yes, I've answered it. 
12:30:58 
13 
Q. 
What was the question? 
12:31:00 
14 
A. 
As part of massive media campaign, did I 
12:31:03 
15 
charge your clients with deliberately falsifying a 
16 
charge against me, and my answer satisfies that 
17 
question. 
18 
Q. 
No, I don't think it does. Can you tell 
12:31:18 
19 
us whether that's what you did, did you charge --
20 
A. 
I just did. 
12:31:22 
21 
Q. 
-- them with having intentionally 
12:31:23 
22 
fabricated false charges against you? 
23 
A. 
I believe that they intentionally 
12:31:28 
24 
fabricated false evidence against me. I believe 
25 
that they pressured their client into fabricating 
EFTA00601275

123 
1 
false evidence against me. I believe that they 
2 
helped to draft a perjurious affidavit that was 
3 
filed in court, after they knew that I said I could 
4 
prove that I couldn't have been there four of the 
5 
five places that the alleged acts could have 
6 
occurred. 
7 
I believe that when they recently sought 
12:31:59 
8 
to submit an additional claim repeating these 
9 
charges into the federal court, that they did it 
10 
knowing full well that these charges were false. 
11 
That's my belief, yes. 
12 
Q. 
Are you aware that your lawyers filed a 
12:32:14 
13 
pleading on your behalf in this case with the title 
14 
Defendant Alan M. Dershowitz's Answer to the 
15 
Complaint and Counterclaim? 
16 
A. 
I'm not aware of that. 
12:32:23 
17 
Q. 
Pardon me? 
12:32:24 
18 
A. 
I'm not aware of the title of any legal 
12:32:25 
19 
pleadings. 
20 
Q. 
Do you know that an answer has been filed 
12:32:28 
21 
to the defamation action that has been brought 
22 
against you? 
23 
A. 
Of course. I mean, I'm sure there's been 
12:32:34 
24 
a legal answer prepared. Of course, that's what 
25 
lawyers do. 
EFTA00601276

124 
1 
Q. 
Are you aware that there's also a 
12:32:40 
2 
counterclaim that has been filed on your behalf? 
3 
A. 
Yes, I authorized the counterclaim to be 
12:32:43 
4 
filed because I believe that your clients defamed me 
5 
and that Mr. Cassell wrote a letter to ABC, which 
6 
not even plausibly is within the claim of privilege, 
7 
which asserts that I had -- asserts falsely and in a 
8 
defamatory way that I had had sexual contact with 
9 
yes. 
10 
Q. 
Did you read the answer to the complaint 
12:33:06 
11 
and counterclaim --
12 
A. 
I'm sure I did. 
12:33:10 
13 
Q. 
-- before it was filed? 
12:33:11 
14 
A. 
I'm sure I did. 
12:33:11 
15 
Q. 
And I assume that you approved of it, 
12:33:13 
16 
correct? 
17 
A. 
I assume I did, yes. 
12:33:17 
18 
Q. 
Okay. 
12:33:18 
19 
MR. SCOTT: I object to anything as far as 
12:33:20 
20 
using pleadings like this, but go ahead and do 
21 
it. 
22 
BY MR. SCAROLA: 
12:33:23 
23 
Q. 
As a law professor, would it be fair for 
12:33:24 
24 
us to assume that you know the difference between 
25 
simple negligence and recklessness? 
EFTA00601277

125 
1 
A. 
That's something that you could spend an 
12:33:32 
2 
entire semester teaching the difference between 
3 
simple negligence and recklessness. That's very 
4 
much a matter of degree and the courts are 
are 
5 
split very much on what the meaning of 
6 
"recklessness" is, particularly in the context of 
7 
defamation. It's a very complicated subject. 
8 
Q. 
Do you personally recognize that there is 
12:33:51 
9 
a difference between simple negligence and 
10 
recklessness? 
11 
A. 
At the extremes, yes, simple negligence is 
12:33:58 
12 
failure to perform a duty and recklessness is 
13 
failure to perform a duty knowing that there 
14 
knowing or should know that there is a likelihood of 
15 
some harm being committed. That's just what I 
16 
remember from first year torts. 
17 
Q. 
And you do also recognize that there is a 
12:34:17 
18 
distinction between simple negligence and 
19 
recklessness on one hand and intentional wrongdoing 
20 
on the other, correct? 
21 
A. 
Again, I've argued cases about this issue. 
12:34:27 
22 
And it's a continuum. Sometimes courts say "that 
23 
should have known" is the equivalent of "knowing." 
24 
So it's a continuum. There's not an absolute 
25 
straight line between those two, yeah. 
EFTA00601278

126 
1 
Q. 
Well, what are you charging Professor Paul 
12:34:48 
2 
Cassell and Bradley Edwards with having done? Were 
3 
they negligent, reckless; or did they knowingly and 
4 
willfully fabricate false charges against you? 
5 
MR. SCOTT: Let me object to the form. 
12:35:11 
6 
It's compound. 
7 
And, Professor, if you would like to 
12:35:13 
8 
review the complaint and the counterclaim 
9 
before you respond to that, you have the 
10 
absolute right to do that. 
11 
THE WITNESS: I'd like to do that, yes. 
12:35:21 
12 
BY MR. SCAROLA: 
12:35:23 
13 
Q. 
Okay. Let me withdraw that question and 
12:35:23 
14 
let me ask this question. 
15 
MR. SCOTT: My position, just so we 
12:35:26 
16 
understand, is -- and this is a legal 
17 
objection -- is that while I don't think you 
18 
can use pleadings to cross-examine a witness, 
19 
if you're going to do it, he has the right to 
20 
see it, have it in front of him and respond to 
21 
it --
22 
MR. SCAROLA: That's why I was -- 
12:35:37 
23 
MR. SCOTT: -- as opposed to asking 
12:35:38 
24 
questions in the vagueness. 
25 
MR. SCAROLA: That's why I'm withdrawing 
12:35:40 
EFTA00601279

127 
1 
the question. 
2 
MR. SCOTT: Thank you. 
12:35:43 
3 
BY MR. SCAROLA: 
12:35:43 
4 
Q. 
What do you contend, independent of 
12:35:43 
5 
anything that may be in any pleadings, Bradley 
6 
Edwards and Paul Cassell are responsible for, 
7 
negligence, recklessness, or intentional and willful 
8 
fabrication of lies? 
9 
A. 
Let me answer that question in full. It 
12:36:02 
10 
is my belief as I sit here today that 
11 
never accused me of having any sexual 
12 
contact with her because I never did have any sexual 
13 
contact with her. And that your clients, Edwards 
14 
and Cassell, sat with her and said to her, look, if 
15 
we want to get the NPA knocked out, we have to find 
16 
a lawyer who worked on the NPA, but who you also had 
17 
sexual contact with. The only lawyer who fits that 
18 
description is Alan Dershowitz. Think back, think 
19 
hard, did you ever have any sexual contact with Alan 
20 
Dershowitz? 
21 
And they pressured her into falsely 
12:36:48 
22 
stating something that they knew or should have 
23 
known was an absolute and deliberate lie. They 
24 
could have easily found that out. They could have 
25 
pressed her very hard on why she hadn't previously 
EFTA00601280

128 
1 
named me. They could have pressed her very hard on 
2 
dates and times and specifics of where these alleged 
3 
acts could have occurred. And they didn't do that. 
4 
So I think that it comes much closer to 
12:37:18 
5 
the intentional side of the continuum than the 
6 
negligence side of the continuum. 
7 
Q. 
Well, you've described it earlier as 
12:37:35 
8 
suborning perjury. That's absolutely intentional, 
9 
isn't it? 
10 
MR. SCOTT: Objection, argumentative, 
12:37:40 
11 
repetitious. Go ahead, you can answer it. 
12 
A. 
I believe that when the time came to file 
12:37:44 
13 
the affidavit in which she described six -- at least 
14 
six alleged incidents of sexual misconduct with me, 
15 
including having me standing next to Jeffrey Epstein 
16 
while he was receiving oral sex, that they knew that 
17 
that was false. And that I believe that they 
18 
probably drafted the affidavit. And to my mind, 
19 
that is subornation of perjury, yes. A criminal 
20 
act. 
21 
BY MR. SCAROLA: 
12:38:20 
22 
Q. 
They encouraged 
to make 
12:38:21 
23 
up lies about you and provided the details of those 
24 
lies to her? 
25 
A. 
No, no -- 
12:38:30 
EFTA00601281

129 
1 
MR. SCOTT: Objection, argumentative, 
12:38:32 
2 
repetitious. 
3 
A. 
I believe they encouraged 
12:38:33 
4 
to make up lies about me and -- and pressed her and 
5 
asked her to put in details. She would never on her 
6 
own have come up with some of the details. They're 
7 
absurd details. 
8 
I mean, it's very, very bad lawyering on 
12:38:49 
9 
their part, by the way. Very bad lawyering for 
10 
having her put in details that were so clearly and 
11 
demonstrably false, such as, for example, meeting 
12 
Bill Clinton on the island. And they should have 
13 
known, by the way, when they put in an allegation 
14 
against me that she had also said that she twice met 
15 
Al Gore with his wife, once on an air -- once on 
16 
Jeffrey Epstein's airplane and once on the island. 
17 
And it is completely clear, and David 
12:39:21 
18 
Boies was the lawyer for -- for Al Gore, as was 
19 
as was I, we worked together on that case, that a 
20 
simple phone call from -- from David Boies to 
21 
Al Gore would have established that they don't know 
22 
each other, that he's never been on the island, 
23 
never been on his airplane. 
24 
I made a simple phone call on day one and 
12:39:46 
25 
established that. So your clients could have easily 
EFTA00601282

130 
1 
determined that she just lied, lied, lied, lied. 
2 
She lied about Al Gore. She lied about Ehud Barak, 
3 
she lied about Bill Clinton. She lied about many, 
4 
many other people. 
5 
This is something that your clients could 
12:40:06 
6 
easily have found out about, but they closed their 
7 
eyes. They willfully blinded themself to a long 
8 
history of lying by your client and willingly put in 
9 
an affidavit that they knew would destroy my career, 
10 
my 50-year career which I worked so hard to build, 
11 
coming from a poor background, with no college 
12 
education, being the first member of my family to go 
13 
to college, working so hard to build a career, 
14 
having an unblemished personal life, and then they 
15 
willingly put in these false allegations without 
16 
checking. Shame on them. 
17 
BY MR. SCAROLA: 
12:40:49 
18 
Q. 
During the period of time between 1998 and 
12:40:50 
19 
2002, you owned a home in the Cambridge area, 
20 
correct? 
21 
A. 
Yes. 
12:41:04 
22 
Q. 
Single-family home in a residential area? 
12:41:04 
23 
A. 
Yes. 
12:41:07 
24 
Q. 
Would you please describe the exterior of 
12:41:07 
25 
that home to us? 
EFTA00601283

131 
1 
A. 
Yes. It was wooden home, built by an 
12:41:12 
2 
architect named Coolidge. Had a little basketball 
3 
hoop where I played basketball with my children on 
4 
one side. It had a swimming pool -- an indoor 
5 
swimming pool on the other side. The exterior was 
6 
gray/blue wood. 
7 
Q. 
If someone were to enter through the front 
12:41:41 
8 
door of your home, would they see some sort of stone 
9 
configuration outside the house? 
10 
A. 
After a period of time, we had a 
12:41:56 
11 
sculpture 
a sculptor from Martha's Vineyard make 
12 
a stone sculpture and a light that stood outside of 
13 
our house. You can probably see that on Google. 
14 
Q. 
When -- when was that stone sculpture 
12:42:10 
15 
installed? 
16 
A. 
I would have to check. I don't know. But 
12:42:16 
17 
anybody can see that on Google Maps. 
18 
MR. SCOTT: Let me object to the relevancy 
12:42:20 
19 
of all this. 
20 
BY MR. SCAROLA: 
12:42:23 
21 
Q. 
Describe the floor plan at the entry level 
12:42:24 
22 
of the house, please. 
23 
MR. SCOTT: Can you make a proffer as to 
12:42:26 
24 
what the relevancy to this is? 
25 
MR. SCAROLA: Not until after I get the 
12:42:29 
EFTA00601284

132 
1 
questions answered. 
2 
A. 
You walk into the house, and there's a 
12:42:33 
3 
foyer that extends probably about 6-foot wide and 
4 
maybe 20 feet long. Yeah. Yeah. 
5 
BY MR. SCAROLA: 
12:42:58 
6 
Q. 
Is there a kitchen at the entry level? 
12:42:59 
7 
A. 
There is only an entry level and so 
12:43:03 
8 
Q. 
One-story home? 
12:43:05 
9 
A. 
It's a one-story home. 
12:43:06 
10 
Q. 
And so the kitchen is on that first floor? 
12:43:07 
11 
A. 
Kitchen is on the first floor to the left, 
12:43:11 
12 
yes. 
13 
Q. 
And is there a living room or a lounge 
12:43:13 
14 
room adjacent to the kitchen? 
15 
A. 
Adjacent to the kitchen there is a large 
12:43:22 
16 
room which serves part of it as a dining area and 
17 
part of it as a living room, yes. 
18 
Q. 
And during this period of time that we're 
12:43:29 
19 
focusing on between 1998 and 
20 
A. 
1998? 
12:43:38 
21 
Q. 
Yes, sir. 
12:43:39 
22 
A. 
Okay, okay. 
12:43:40 
23 
Q. 
Between 1998 and 2002, how was the -- how 
12:43:42 
24 
was that room furnished? 
25 
A. 
Well, it would be easy to tell because 
12:43:47 
EFTA00601285

133 
1 
it's been the subject of many photographic essays 
2 
that appeared in magazines and newspapers. Our home 
3 
was often photographed. So anybody would know what 
4 
the interior of it looked like. Just a simple 
5 
Google search would show you what the interior of 
6 
the house looked like. 
7 
Q. 
Tell us what it looked like, please. 
12:44:07 
8 
A. 
Well, what specifically? 
12:44:08 
9 
Q. 
Well -- 
12:44:11 
10 
A. 
It had a couch when you walk in. 
12:44:12 
11 
Q. 
Okay. What other furniture? 
12:44:14 
12 
A. 
It had chairs. It had a dining room 
12:44:15 
13 
table, all of which have been pictured in various 
14 
magazines and newspapers. 
15 
Q. 
Was there a desk in that room? 
12:44:27 
16 
A. 
No. 
12:44:31 
17 
Q. 
Bookshelves? 
12:44:33 
18 
A. 
In the living room? 
12:44:34 
19 
Q. 
In the rooms adjacent to the kitchen. 
12:44:37 
20 
A. 
No, not to my recollection. 
12:44:41 
21 
Why, does 
claim to have 
12:44:47 
22 
been in my home? 
23 
Q. 
What kind of floor coverings are there on 
12:44:50 
24 
the entry level? 
25 
A. 
Floor coverings? 
12:44:57 
EFTA00601286

134 
1 
Q. 
Yes. 
12:44:59 
2 
A. 
In the entry level right as you walk in, 
12:45:02 
3 
there are no floor coverings. There are --
4 
Q. 
Tile, wood? 
12:45:09 
5 
A. 
Not a rug. Just a floor. 
12:45:13 
6 
Q. 
What kind of floor? 
12:45:16 
7 
A. 
I don't remember. 
12:45:18 
8 
Q. 
What was its composition? 
12:45:18 
9 
A. 
I don't remember. 
12:45:20 
10 
Q. 
How about the living room, what was the 
12:45:20 
11 
composition of the floor in the living room? 
12 
A. 
Cork, I think. Cork, yeah. 
12:45:26 
13 
Q. 
How many times has Jeffrey Epstein been a 
12:45:34 
14 
guest in that Cambridge, Massachusetts house? 
15 
A. 
Maybe -- 
12:45:44 
16 
MR. SWEDER: When you say "guest," you 
12:45:46 
17 
don't mean sleeping over? 
18 
A. 
He's never slept over. 
12:45:51 
19 
BY MR. SCAROLA: 
12:45:52 
20 
Q. 
I didn't say anything about sleeping over. 
12:45:52 
21 
MR. SWEDER: I just want to make sure the 
12:45:54 
22 
record is clear. 
23 
A. 
He has never slept over. Maybe three 
12:45:55 
24 
times. Maybe. Maybe three times. That would be a 
25 
rough estimate. Not very many. 
EFTA00601287

135 
1 
MR. SCOTT: During the relevant timeframe. 
12:46:12 
2 
A. 
During the relevant timeframe. 
12:46:15 
3 
MR. SCOTT: 1999 to 2002. 
12:46:16 
4 
A. 
1999 to 2002. Oh, either -- maybe once. 
12:46:17 
5 
Maybe once. Certainly not many times. 
6 
BY MR. SCAROLA: 
12:46:24 
7 
Q. 
At least once? 
12:46:27 
8 
A. 
I don't -- 
12:46:29 
9 
Q. 
Maybe two, maybe three? 
12:46:29 
10 
A. 
No, no, I have no recollection 
12:46:31 
11 
MR. SCOTT: Okay. 
12:46:32 
12 
A. 
I have no recollection of him being there 
12:46:33 
13 
at all during that relevant time period. But 
14 
remembering that he had been in my house on a couple 
15 
of occasions, it's certainly possible during that 
16 
relevant time period he had been there once or 
17 
twice. 
18 
BY MR. SCAROLA: 
12:46:46 
19 
Q. 
How many times -- excuse me. When he did 
12:46:47 
20 
visit, with whom -- who accompanied him? 
21 
MR. SCOTT: Let me ask you a question. 
12:46:55 
22 
Are we -- is this relevant timeframe or any 
23 
time? I'm just trying --
24 
MR. SCAROLA: Since we can't narrow it 
12:46:59 
25 
down to the relevant timeframe, I want to know 
EFTA00601288

136 
1 
any time. 
2 
BY MR. SCAROLA: 
12:47:02 
3 
Q. 
Any time that Jeffrey Epstein visited your 
12:47:03 
4 
home, who was with him? 
5 
A. 
Normally Ghislaine Maxwell and 
12:47:07 
6 
. And he may have had another assistant or 
7 
secretary or somebody. He usually traveled. 
8 
Usually he would fly in to Bedford 
12:47:20 
9 
Airport, have a car take him -- usually go to his 
10 
office. He had an office in Harvard Square, and if 
11 
he came by my house, he came by my house with 
12 
whoever was his entourage at any given point in 
13 
time. 
14 
BY MR. SCAROLA: 
12:47:41 
15 
Q. 
And that usually was? 
12:47:42 
16 
A. 
, Maxwell and sometimes 
12:47:43 
17 
another one or two people. 
18 
Q. 
How old was 
when she was part 
12:47:49 
19 
of Jeffrey Epstein's entourage? 
20 
A. 
If I had to estimate, I would say younger 
12:47:56 
21 
than 30 and older than 25. Somewhere between 25 and 
22 
30, probably closer to 30. 
23 
Q. 
You would describe her as a young woman? 
12:48:06 
24 
A. 
I would describe her as a woman between 
12:48:08 
25 
the ages of 25 and 30. 
EFTA00601289

137 
1 
Q. 
Does that in your mind fit the description 
12:48:15 
2 
of a young woman? 
3 
A. 
I don't want to categorize a woman by her 
12:48:19 
4 
age. It's a woman between 25 and 30. It's not a 
5 
teenager. It's not a middle-aged woman. It's a 
6 
woman between the ages of 25 and 30. 
7 
Q. 
What was 
role in Jeffrey 
12:48:32 
8 
Epstein's entourage? 
9 
A. 
She would, to my knowledge, arrange 
12:48:37 
10 
transportation, she would arrange meetings when 
11 
meetings were occurring. She worked, I think, at 
12 
the Harvard office where he would have meetings with 
13 
George Church, the man who developed the genome, 
14 
Larry Summers, the president of Harvard, Henry 
15 
Rosovsky, the provost, the former provost of 
16 
Harvard; Stephen Kosslyn, the chairman of the 
17 
psychology department at Harvard, a man who wrote 
18 
multiple intelligences, whose name is slipping my 
19 
mind now, but from the Ed School. 
20 
She would arrange some of those lunch 
12:49:23 
21 
meetings where we would discuss serious issues, some 
22 
of us were asked to present. I presented on one or 
23 
two occasions and we were asked to critique and she 
24 
would take notes and arrange transportation and do 
25 
things of that kind. 
EFTA00601290

138 
1 
Q. 
How old was Ghislaine Maxwell? 
12:49:40 
2 
A. 
Ghislaine, Ghislaine Maxwell. I would 
12:49:45 
3 
estimate --
4 
MR. SCOTT: Your French isn't real high. 
12:49:48 
5 
A. 
I would estimate that she was at the time 
12:49:50 
6 
between 35 and 40. 
7 
BY MR. SCAROLA: 
12:49:55 
8 
Q. 
And what was her role in Jeffrey Epstein's 
12:49:55 
9 
entourage? 
10 
A. 
She was basically his major domo. She 
12:49:58 
11 
arranged travel as well. And she would tell you 
12 
when you could meet with him, when to come over. 
13 
She would call me at my office and say, Jeffrey 
14 
would like to meet with you at 4:10, and then she 
15 
would call back and say, could you make it at 4:30? 
16 
I would say that Ghislaine was the senior 
12:50:19 
17 
person organizing his kind of academic contacts and 
18 
was the junior person. They worked in 
19 
overlapping roles. 
20 
Q. 
Were there any other entourage members 
12:50:34 
21 
that traveled with Jeffrey Epstein when he came to 
22 
your home? 
23 
A. 
I have no recollection of any of them ever 
12:50:41 
24 
coming to my home. I don't remember. But if that's 
25 
who he traveled with. Sometimes he would travel --
EFTA00601291

139 
1 
he almost always had a regular girlfriend. And I 
2 
remember a few of them. One of them was a student 
3 
at the business school who's -- I may be merging two 
4 
of them. 
5 
One of them was a student at the business 
12:51:03 
6 
school. Another, maybe the same one, was a wealthy 
7 
woman whose father owned banks in Great Britain. 
8 
Another was a woman from either the Czech Republic 
9 
or Slovakia who was probably between 20 and 25, 
10 
probably closer to 25. And he would travel with a 
11 
posse, basically, an entourage of -- of people. But 
12 
I never met some of the people who are in the 
13 
entourage. They were just there. 
14 
Q. 
They were there at the same time that you 
12:51:38 
15 
were there and Jeffrey Epstein was there? 
16 
A. 
Well, they were -- 
12:51:42 
17 
MR. SCOTT: Wait a minute. That's vague. 
12:51:43 
18 
I mean, there in the house, there in 
19 
Massachusetts? 
20 
MR. SCAROLA: There wherever. 
12:51:47 
21 
BY MR. SCAROLA: 
12:51:47 
22 
Q. 
When you were in Jeffrey Epstein's 
12:51:48 
23 
presence, Jeffrey Epstein usually had what you have 
24 
described as some regular girlfriend. 
25 
A. 
That's right. 
12:51:58 
EFTA00601292

140 
1 
Q. 
And you have described a variety of 
12:51:59 
2 
different regular girlfriends who were with him, 
3 
correct? 
4 
A. 
Yes. 
12:52:06 
5 
Q. 
Usually in the age range, you would 
12:52:06 
6 
estimate, between 20 and 25; is that correct? 
7 
A. 
I would say -- 
12:52:13 
8 
MR. SCOTT: Objection. That's not it. 
12:52:14 
9 
A. 
I would say between 22 and 25 would be a 
12:52:15 
10 
closer -- closer estimate. But 23, in that range. 
11 
There were none that I ever believed were 
12:52:25 
12 
in any way teenagers. And they all performed tasks. 
13 
They were taking notes or they were arranging, 
14 
serving coffee or doing various things. And that's 
15 
the way Jeffrey would travel when he went to 
16 
academic meetings. 
17 
And these people were seen not only by me. 
12:52:45 
18 
They were seen by Larry Summers, they were seen by 
19 
Church, they were seen by Marvin Minsky, they were 
20 
seen by some of the most eminent academics and 
21 
scholars in the world. There was no hint or 
22 
suggestion of anything sexual or improper in the 
23 
presence of these people. 
24 
BY MR. SCAROLA: 
12:53:09 
25 
Q. 
Describe the motor vehicle that Jeffrey 
12:53:09 
EFTA00601293