EFTA00615583

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