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Epstein and then we see on the flight logs one female, 
that's kind of an odd notation for a flight log because, 
you know, typically, I understand flight logs, the 
purpose is, well, if something happens with the flight, 
or there's some question about who was on and you want 
to know who the person was who was on the flight. 
So, to my mind, when I started to see on 
these flight logs entries like one female, I view that 
as a potential device for obscuring the fact that there 
was interstate trafficking of underage girls for 
purposes of sexual activity. Serious federal offenses. 
But then the evidence extended, you know, 
more broadly than that. The evidence also started to 
show again if we talk just about flight logs, that 
the -- that underage girls such as 
were 
being flown internationally from, for example, Teterboro 
in New York to locations just to pick one, for example, 
in London, where again sexual abuse was occurring. 
And so you started to put together this 
pattern of criminality that was started in this, you 
know, I don't know what the right word is here, I don't 
know -- I don't want to -- you know, you've heard 
discussions of hyperbole and things like that, but we 
have got this nest of, I won't say snakes, but we have 
this nest of criminals in Florida, but it seems to be 
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spreading to Epstein's mansion in New York, it seems to 
be spreading to Ghislane Maxwell's flat in London, 
and -- and it goes on. 
So those are the kinds of things that would 
have formed the -- the -- the basis. Particularly when 
you start to add in this fact, what the Palm -- going 
back now to Florida with the Palm Beach Police 
Department, the Palm Beach Police Department had 
discovered, was a not one-off kind of event, one 
particular day, one particular girl had been sexually 
abused. What the Palm Beach Police Department had 
discovered was brazen, notorious, repetitive activity 
sometimes occurring as often as three times in a 
particular day. And so that led me to believe that the 
sexual activity that was going on in Florida was such 
that someone who was a regular house guest there would 
have immediately come to the conclusion that, well , 
look, gee, there are these underage girls coming in here 
and they seem to be -- you know, they don't seem to be 
here to be doing business activities, they might be here 
doing other kinds of activity. So those would be the 
kinds of things that would -- would have formed the 
factual basis. 
There are other things as well, but I'm sure 
you want to ask other questions in addition to that. So 
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I'll stop there, but those -- that's -- I think gives 
you a small flavor of the kind of evidence that, you 
know, was undergirding the allegations that were being 
presented here. 
Q. 
It sounds like you quite passionately believe 
that there was strong evidence that Mr. Epstein had 
engaged in sexual misconduct; is that right? 
A. 
I think "strong" understates it. 
Q. 
In the course of that long answer, you didn't 
mention Professor Dershowitz's name once. 
A. 
I said flight logs. Let's talk about flight 
logs. 
Q. 
Let me back up. You didn't answer his 
name -- mention his name once; is that your recollection 
as well? 
A. 
That's correct. We were talking about a 
factual basis and I'll be glad -- I told you that there 
were other things if you want, factual basis for 
Mr. Dershowitz, I'll be glad to add that in. Let me --
I would like to supplement my answer then if I could. 
Q. 
Do you want to look at a document? 
A. 
Yes. 
Q. 
Let me first -- have we exhausted your 
recollection without documents of all the evidence that 
you would refer to to support the allegation that 
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Professor Dershowitz abused other minors? 
A. 
No. 
MR. SCAROLA: And let me say that you have a 
right to refer to whatever documents you choose 
to refer to, to be sure that you give a complete 
response to the question that has been asked, as 
long as you understand that whatever you refer to 
is going to be available to the other side and we 
would be happy to make it available to you. 
MR. SIMPSON: And I'll give you an 
opportunity to look at that --
THE WITNESS: Sure --
BY MR. SIMPSON: 
Q. 
-- but I'm entitled to ask first about your 
recollection. 
A. 
Okay. 
Q. 
Based on your recollection, I want to know 
all the evidence you're relying on here? 
A. 
Right. So what I'm going to do, I'm going to 
make a list here on my notepad of all the things and 
then I'm going to compare that with notes I have here. 
There may be couple things I don't cover. 
Q. 
As long as your counsel is okay with that? 
A. 
Yeah. 
Q. 
You understand you'll have to give that to 
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me? 
A. 
Yeah, I'll give you the notes and then I will 
compare with what I've got there. 
Q. 
All right. 
A. 
So I mentioned the Palm Beach Police 
Department report. The next thing that I want to 
mention is the Jane Doe 102 complaint. In August of 
2009, Bob Josefsburg, who is from what I understood a 
very well -regarded lawyer here in Florida; in fact, a 
lawyer that was selected by the United States Government 
to represent a number of the girls that had been 
sexually abused by Jeffrey Epstein. He was part of the 
procedure that was including the nonprosecution 
agreement. 
In August of 2009 he filed a complaint on 
behalf of 
. That complaint indicated 
that 
had been sexually abused in 
Florida, in New York, and in other places as I recall. 
The thing that I particularly recall was that 
Mr. Josefsburg had said 
was abused 
by -- he gave some categories of people. 
He mentioned, I think, business people, he 
mentioned royalty, and he mentioned academicians. And 
so to tie into your question, I knew that Professor 
Dershowitz was an academician, and so what I was seeing 
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now was, that according to a very, very respected 
attorney here in Florida, he had found 
to be credible. And had filed a lawsuit against 
Mr. Epstein saying that she had been trafficked, 
sexually trafficked, you know, not just abused by 
Mr. Epstein, but now being forcibly sent to, you know, 
other people to abuse. And in the categories of people 
that were sexually abusing her were academicians and I 
knew that Mr. Dershowitz fell within that category of 
being an academician. 
That complaint also indicated that there 
might be flight logs that would show that 
had been sexually abused in these various 
locations. And that started to indicate to me that 
there might be what the law refers to as a common scheme 
or plan. And that just as 
was being 
trafficked to these powerful people in various places, 
there might well be other girls. 
And so I have mentioned a flight log and you 
wanted to talk about Mr. Dershowitz. On December 30th, 
2009, I was aware that there was a flight log showing 
Mr. Dershowitz flying with Tatiana (indicating), who as 
far as I can tell was not a business person, was not 
providing financial advice or something else. 
I understood that Mr. Epstein was a 
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billionaire who was heavily involved in financial 
issues. I knew that Tatiana was on plane with 
Mr. Dershowitz and then there was also, if I recall 
correctly working from memory as you were wondering 
about, there was a notation that Mr. Dershowitz was on a 
plane with one female. 
And so I was -- when I looked at that, I'm 
seeing Mr. Dershowitz on a flight with a women who 
doesn't seem to be there for, frankly, anything other 
than sexual purposes or something along those lines with 
Mr. Epstein, with Mr. Epstein, who is a sex trafficker, 
and with one female which seemed to me to be a 
potentially entry for disguising international sex 
trafficking. So that was of concern. 
I then began to look at, well , I wonder, how 
would I find out if Mr. Dershowitz had been abusing 
other girls? Let's see, I knew that 
had been forced to -- to -- to do this sort of thing. . . 
MS. McCAWLEY: You're okay as long as 
you're -- if you're revealing something in an 
affidavit, that she submitted, you're fine. 
THE WITNESS: Right. So -- so what. . . let's 
see. At this point --
BY MR. SIMPSON: 
Q. 
Do you want the question back? 
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A. 
No, I'm just trying to remember what I was 
thinking about with -- with regard to --
MR. SCAROLA: Do you need the response read 
back up to the point --
THE WITNESS: If you would do that. 
MR. SCAROLA: -- about privilege. Just read 
the last couple of sentences back or the last two 
sentences. 
THE WITNESS: Oh, I'm sorry, now I remember 
exactly. 
How would we go find out whether Mr. Epstein 
was lending women, or in this case, underage 
girls to Mr. Dershowitz for sexual purposes? 
Well , the first thing I want to do was ask -- I 
will ask go Jeffrey Epstein. 
And so what I discovered when I started to 
look at the transcripts, there were a number of 
transcripts where Mr. Epstein was asked about 
Alan Dershowitz. And rather than say, well , no, 
he wasn't involved in any of these illegal 
activities, Jeffrey Epstein took the Fifth as the 
phrase, you know, to be more precise, he 
exercised his right against compelled 
self-incrimination and refused to answer the 
question, which since these were civil cases 
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indicated to me, since he was being represented 
by very experienced legal counsel , that there was 
more than an insignificant risk of incriminating 
himself if he answered that. 
And so Jeffrey Epstein now had taken the 
Fifth. And one of the things that I was aware of 
having been involved in, you know, civil 
litigation and criminal litigation in other 
cases, once somebody refuses to answer a question 
like, you know: Do you know Mr. Dershowitz, and 
they take the Fifth on that, that you're then 
entitled to draw what's called an adverse 
inference. You can infer that, well, if they 
answered that question --
MR. SCAROLA: Excuse me. 
MS. McCAWLEY: Yeah, I want to make an 
objection here --
MR. SCAROLA: Pardon me. Could you please 
try to control your client who keeps jumping up 
and down and distracting everybody in the room? 
MS. McCAWLEY: Yeah, and there was also 
profanity used earlier. I mean, we just have to 
settle down on this side, take a deep breath, and 
let him answer his questions. 
MR. SIMPSON: Look, I mean, the same thing 
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was happening on the other side. 
MR. SCAROLA: No, sir. No, no, no. There 
was never anyone who jumped to their feet at any 
time during the course of the last two days. The 
only person who keeps jumping up is Alan 
Dershowitz. Have him pass you a note quietly if 
you would, please. 
MR. SIMPSON: I will disagree with your 
characterization, but let me say the 
argumentation --
MR. SCAROLA: Are you making the 
representation --
MR. SIMPSON: No, I'm not. 
MR. SCAROLA: -- that somebody on this side 
of the room jumped up? 
MR. SIMPSON: No, no, no, I'm not. 
MR. SCAROLA: Okay. Thank you. I appreciate 
that. 
MR. SIMPSON: And I --
MR. SCAROLA: And you do acknowledge that 
Mr. Dershowitz has repeatedly been jumping up in 
the middle of testimony, correct? 
MR. SIMPSON: That's -- he just got up and 
came over to me, that's the only time I'm aware 
of because I'm looking at the witness, but he did 
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just do that, and I will pass notes. We won't 
get up. 
MR. SCAROLA: Okay. Well , I will -- I will 
for the record, as an officer of the court, 
represent that there have been multiple times 
during the course of Professor Cassell's 
deposition when Alan Dershowitz has jumped up in 
the middle of the testimony and excitedly 
whispered in your ear. 
You may not have realized it because you were 
focusing on the witness, but everybody on this 
side of the room has been distracted by his 
unprofessional conduct. 
MR. SIMPSON: I'm not going to argue with 
you. 
MR. SCAROLA: Thank you. 
MR. SIMPSON: I disagree with that 
characterization. There is another attorney 
sitting between us. We will pass notes. 
MR. SCAROLA: Thank you. 
MR. SIMPSON: And I believe, Ms. McCawley, 
were you instructing not to answer or what was 
happening? What did you -- what were you 
raising? 
MS. McCAWLEY: No. There was a lot of 
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yelling going on here, so I was trying to make 
sure that everybody was quiet so that the client 
could answer. 
MR. SIMPSON: All right. Let me back up. 
Professor Cassell, I think you were in the middle 
of an answer? 
THE WITNESS: Yeah, I was. 
MR. SIMPSON: Could the court reporter read 
me the last two lines of your answer? 
(Thereupon, a portion of the record was read 
by the reporter.) 
BY MR. SIMPSON: 
Q. 
Can you pick up then? 
A. 
Sure. I'll pick up the ans -- so I was 
beginning to draw an adverse inference when Jeffrey 
Epstein, who is at the heart of the sexual abuse of not 
only 
, but dozens and dozens and dozens 
of girls literally scattered across the globe, takes the 
Fifth, refuses to answer the question. 
Off the top of my head, I can't recall 
exactly, but something along lines of: Do you know Alan 
Dershowitz? And he says, I take the Fifth. That sort 
of, frankly, startled me, that this international sex 
trafficker was taking the Fifth now when asked about 
Mr. Dershowitz. 
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And so I was stymied in trying to get 
information from Mr. Epstein at that point. I think 
there were two depositions, if I recall correctly off 
the top of my head, that I had an opportunity to review 
in which he took the 5th when asked questions about 
Dershowitz. 
So at that point in trying to figure out, you 
know, whether Mr. Dershowitz was involved in sexually 
abusing not only 
, but in other girls, 
then you go down to the next level, next layer of the 
criminal conspiracy. Epstein is at the top, so you go 
to the next layer. These are, you know, basically the 
women who, from what I could gather, were older than the 
age that Epstein wanted to sexually abuse. I think 
these were 22, 23-year-old girls, so they had, you know, 
essentially aged out of being his sexual abuse victims, 
but they continued to -- what they would do is collect 
girls for him under the age of 18, that I guess was in 
his target range. 
And so what -- so the next person I wanted to 
talk to, you know, and get information from was 
is on a lot of these flight logs 
with, you know, these girls that -- or women and with 
Epstein and others, and so I wanted to talk to 
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But what I discovered there was that when 
was asked about Alan Dershowitz, she took 
the Fifth and she wasn't the only one. There was 
Miss 
who also took the Fifth when asked 
questions about Alan Dershowitz. 
And then there was 
-- Miss 
who also took the Fifth. So what we -- what I had at 
this point was Jeffrey Epstein's international sex 
trafficking organization. I had the next echelon and 
both the top kingpin of the sex trafficking organization 
and the next echelon had taken the Fifth, had refused to 
answer questions about Alan Dershowitz. 
And so at that point, I was drawing an 
adverse inference, not just from one person, but from 
four persons and that adverse inference was being 
strengthened by the surrounding circumstances, some of 
which we have already talked about. 
One of the things that really bolstered the 
adverse inference that I was drawing in this case was 
that I've mentioned those three girls, 
and 
, they were all covered by a 
nonprosecution agreement. And the nonprosecution 
agreement was highly unusual. 
I had been a federal prosecutor for about 
four years, I had been a federal judge for about 
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five-and-a-half years, so I had seen a lot of, you know, 
nonprosecution types of arrangements. And one of the 
things that was very unusual in this one is, it has what 
I'll refer to as the blank check immunity provision. 
There was a provision in the nonprosecution 
agreement that said, this agreement will prevent federal 
prosecution for international and interstate sex 
trafficking, not only of Jeffrey Epstein, and not only 
of the four women who were identified, but -- and this 
is a direct quote: Any other potential co-conspirator, 
close quote. And so that was unusual because what it 
what it seemed to be doing was somehow this agreement 
was quite out of the normal and had been designed to 
extend immunity to other people that might have been 
associated with Epstein. 
And I knew that that category included the 
people that were involved in negotiating this highly 
unusual provision included Mr. Dershowitz who had been 
heavily involved, not only in the drafting of the 
agreement, but had also been involved remarkably in 
attacking the credibility of these girls and saying 
things like, you know, it was -- Epstein wasn't 
targeting minor girls, which just struck -- you know, I 
was -- I don't want to use a technical term, 
gob-smocked, that a defense attorney with an obligation 
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to tell the truth was making a factual representation 
that Jeffrey Epstein was not targeting minor girls, when 
the Palm Beach Police Department had collected, you 
know, 23 of them that had all given essentially 
interlocking stories about how they had all gone over 
this house, you know, the mansion, to give a massage and 
when they had gotten, there they had been sexually 
abused. 
So the kingpin wouldn't talk. The next 
echelon of the trafficking organization wouldn't talk. 
So the next step was to say, okay, let's see if we can 
find somebody, you know, lower level in there, you know, 
a household employee or something like that, maybe they 
will have some information about, you know, what this 
criminal organization is doing. 
Now, let's understand, you know, given the 
pervasiveness of the criminal activity, I wasn't 
convinced that they were going to be able to get in 
there and start saying exactly what was going on because 
they might well be exposing themselves to criminal , you 
know, criminal culpability. 
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