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1 
A. 
I'm explaining -- 
15:59:35 
2 
Q. 
Is that part of the question that I 
15:59:35 
3 
asked --
4 
A. 
I'm explaining the couch. 
15:59:37 
5 
Q. 
or is that your effort to make speeches 
15:59:38 
6 
in an effort to consume the limited amount of time 
7 
that we have? 
8 
MR. SCOTT: I would object to that 
15:59:44 
9 
characterization. 
10 
A. 
I wanted to start at -- I wanted to start 
15:59:44 
11 
at 12:00 -- at 1:30 today. 
12 
MR. SCOTT: And the speech. 
15:59:48 
13 
MR. SIMPSON: Alan, Alan. 
15:59:48 
14 
A. 
All the delays have been caused by you, 
15:59:49 
15 
not me. And I'm ready to go to 5:30, but you're 
16 
quitting at 5 -- or 4:30. 
17 
BY MR. SCAROLA: 
15:59:55 
18 
Q. 
Yes, sir, I have -- 
15:59:55 
19 
A. 
So don't blame any delays on me, sir. 
15:59:56 
20 
Q. 
-- a commitment -- I have a commitment to 
15:59:58 
21 
chair an --
22 
A. 
Don't we all. 
15:59:59 
23 
Q. 
-- Easter Seals fundraiser. 
15:59:59 
24 
A. 
We all have commitments. 
16:00:00 
25 
Q. 
You've known -- 
16:00:02 
EFTA00601314

162 
1 
MR. SCOTT: Timeout. Timeout. Let's 
16:00:02 
2 
everybody --
3 
BY MR. SCAROLA: 
16:00:03 
4 
Q. 
-- that for three days. 
16:00:03 
5 
MR. SCOTT: Everybody cool down. 
16:00:05 
6 
Everybody cool down. It's late in the day. 
7 
That includes Mr. Scarola, my client. Let's do 
8 
question and answer. 
9 
BY MR. SCAROLA: 
16:00:14 
10 
Q. 
New question -- 
16:00:15 
11 
MR. SCOTT: Here we go, new question. 
16:00:15 
12 
BY MR. SCAROLA: 
16:00:15 
13 
Q. 
-- did you see a bed in the plane? 
16:00:15 
14 
A. 
I never saw a bed in the plane. As far as 
16:00:16 
15 
I know, there was no bed in the plane. And that's 
16 
what I was trying to explain. That the only time 
17 
I've seen that couch used is when two or three 
18 
people were sitting in it when we went down to watch 
19 
the launch of the satellite because that was the 
20 
only time I saw the plane filled. 
21 
Other than that, it was a plain, ordinary 
16:00:36 
22 
couch that was never used by anybody during the 
23 
flights. We were all sitting in our seats. I do 
24 
not know for a fact that that couch becomes a bed. 
25 
I never saw it as a bed. And the answer is 
EFTA00601315

163 
1 
categorically no. 
2 
Q. 
Well, the question was: Is there a bed on 
16:00:57 
3 
the plane? The answer to that question is not a 
4 
categorical no; the answer to that question is you 
5 
don't know; is that right? 
6 
A. 
The answer to that question is there is a 
16:01:05 
7 
couch on the plane like it is on all -- as far as I 
8 
know, all Gulfstream IVs. I have no idea whether or 
9 
not that couch becomes a bed. 
10 
Q. 
You told the American lawyer on 
16:01:15 
11 
January 15, 2015 a statement that you have repeated 
12 
on multiple occasions: "I've been married to the 
13 
same woman for 28 years. She goes with me 
14 
everywhere." 
15 
Do you acknowledge making that statement? 
16:01:29 
16 
A. 
Yes. My wife goes with me everywhere 
16:01:30 
17 
today. These days, now that our daughter is grown 
18 
up and went to high school and college, she travels 
19 
with me everywhere. It's a rare, rare occasion when 
20 
my wife doesn't travel with me. In fact, I have a 
21 
condition of my speakings engagements that the 
22 
speaking engagements have to pay for my wife to come 
23 
with me. 
24 
I hate traveling alone. I almost never do 
16:01:51 
25 
it unless there is an absolutely essential reason 
EFTA00601316

164 
1 
for Carolyn to be somewhere else, such as taking 
2 
care of her 96-year-old mother. But it is true, I 
3 
travel with my wife. 
4 
Q. 
In fact, the airplane manifests that have 
16:02:07 
5 
been produced reflect your having traveled on 
6 
Jeffrey Epstein's airplane on ten separate occasions 
7 
and on none of those occasions --
8 
A. 
Is that testimony, sir? 
16:02:22 
9 
Q. 
On none of those occasions -- 
16:02:23 
10 
MR. SCOTT: Wait a minute. 
16:02:25 
11 
BY MR. SCAROLA: 
16:02:25 
12 
Q. 
is your wife reflected as having been a 
16:02:26 
13 
passenger at the same time that you are were on 
14 
Jeffrey Epstein's airplane, right? 
15 
MR. SCOTT: Object to the form. There's 
16:02:32 
16 
no timeframe or anything of that nature. If 
17 
you can answer 
18 
BY MR. SCAROLA: 
16:02:35 
19 
Q. 
All of the manifests that have been 
16:02:35 
20 
produced in this litigation, the ones that you say 
21 
corroborate your testimony and exonerate you, 
22 
demonstrate that you never flew on Jeffrey Epstein's 
23 
plane in the company of your wife, correct? 
24 
A. 
No. That's not true. I flew in the 
16:02:50 
25 
company of my wife and my daughter from Charleston, 
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1 
South Carolina to Guadalupe --
2 
Q. 
I'm asking about what the manifests show, 
16:03:00 
3 
sir --
4 
A. 
I'm telling you what 
16:03:02 
5 
Q. 
-- the ones that you say exonerate you. 
16:03:03 
6 
A. 
Well, I said that -- 
16:03:05 
7 
Q. 
Is there a manifest that shows that you 
16:03:06 
8 
and your wife were on Jeffrey Epstein's plane at the 
9 
same time together? 
10 
MR. SCOTT: Let me object to the -- 
16:03:11 
11 
A. 
I don't know that. 
16:03:13 
12 
MR. SCOTT: -- argumentative nature and 
16:03:13 
13 
compound nature. He's trying to answer your 
14 
questions. 
15 
A. 
Let me go through each of the times 
16:03:18 
16 
MR. SCOTT: There's nothing -- 
16:03:19 
17 
THE WITNESS: Okay. Okay. 
16:03:19 
18 
MR. SCOTT: There's nothing pending. Go 
16:03:20 
19 
ahead. 
20 
BY MR. SCAROLA: 
16:03:21 
21 
Q. 
Is there a manifest that shows that your 
16:03:21 
22 
wife ever accompanied you on a flight on Jeffrey 
23 
Epstein's private airplane? 
24 
MR. SCOTT: Let me object again. There's 
16:03:30 
25 
no reference to the timeframe or the relevant 
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166 
1 
timeframe --
2 
MR. SCAROLA: Any time ever. 
16:03:34 
3 
A. 
My wife accompanied me on two occasions, 
16:03:35 
4 
my nephew --
5 
BY MR. SCAROLA: 
16:03:39 
6 
Q. 
Is there a manifest -- 
16:03:39 
7 
MR. SCOTT: You're cutting him off, 
16:03:40 
8 
Counsel. 
9 
A. 
Let me finish. 
16:03:41 
10 
MR. SCAROLA: He's not answering my 
16:03:41 
11 
question. 
12 
MR. SCOTT: Yes, he is answering your 
16:03:43 
13 
question. 
14 
A. 
My nephew accompanied me on one occasion. 
16:03:45 
15 
My research assistant, Mitch Webber, accompanied me 
16 
on one occasion. My son or grandson, I'm not sure 
17 
which, accompanied me on one occasion. 
18 
And the occasions that I flew on Jeffrey 
16:04:04 
19 
Epstein's plane were almost always business 
20 
occasions during a time when my daughter, Ella, was 
21 
in elementary school, if we're talking about the 
22 
relevant period of time. And during that period of 
23 
time, on occasion my wife did not fly with me. 
24 
BY MR. SCAROLA: 
16:04:24 
25 
Q. 
Is there -- 
16:04:24 
EFTA00601319

167 
1 
A. 
But let me emphasize -- let me emphasize 
16:04:25 
2 
that the manifests that do exculp me, do not show me 
3 
flying with 
, they do not show me 
4 
flying with any young women. 
5 
They know that on every trip I took, there 
16:04:35 
6 
was a business reason for it, there were other 
7 
people on the plane, and it is inconceivable that 
8 
during any of those periods of time, the lies that 
9 
told about me could have been true. 
10 
Q. 
So it's your contention that no manifests 
16:04:49 
11 
show you traveling outside the company of your wife; 
12 
is that correct? 
13 
A. 
Said that again, no manifest -- 
16:04:58 
14 
Q. 
No manifest shows you traveling outside 
16:04:59 
15 
the company of your wife? 
16 
A. 
I'm confused. That's a double, triple 
16:05:02 
17 
negative. 
18 
MR. SCOTT: Do you understand the 
16:05:07 
19 
question? 
20 
THE WITNESS: I don't, no. 
16:05:07 
21 
MR. SCOTT: Rephrase it. 
16:05:09 
22 
BY MR. SCAROLA: 
16:05:09 
23 
Q. 
There is not a single manifest of the ten 
16:05:10 
24 
that shows you as a passenger on Jeffrey Epstein's 
25 
plane that shows your wife there at the same time, 
EFTA00601320

168 
1 
correct? 
2 
A. 
I am not aware that there are ten 
16:05:18 
3 
manifests 
I would be happy to look at the 
4 
manifests 
I have explained 
5 
Q. 
Unfortunately -- 
16:05:24 
6 
A. 
-- each of the times -- 
16:05:24 
7 
Q. 
-- we won't have time to do that this 
16:05:25 
8 
afternoon --
9 
A. 
-- I've been -- 
16:05:27 
10 
Q. 
-- but we will have time to do that 
16:05:27 
11 
eventually. 
12 
A. 
We will -- I welcome that time, because I 
16:05:29 
13 
can give complete context to every single trip I 
14 
took. And if you're trying to convey the impression 
15 
that there was any occasion on which I had any 
16 
improper conduct while I was on that airplane, that 
17 
is a categorical lie. 
18 
Q. 
What I am trying to do, sir, is to test 
16:05:45 
19 
the veracity of your public assertions that you have 
20 
never traveled outside the presence of your wife. 
21 
A. 
That is a lie. 
16:05:57 
22 
Q. 
That is what I'm trying to do. 
16:05:57 
23 
A. 
That is a lie, sir, a categorical lie. I 
16:05:57 
24 
challenge you to find any statement where I said I 
25 
have never traveled outside the presence of my wife. 
EFTA00601321

169 
1 
Q. 
Well, how about this -- 
16:06:08 
2 
A. 
Sir, find me that statement. 
16:06:09 
3 
Q. 
-- do you -- do you remember having -- 
16:06:10 
4 
having stated publicly on multiple occasions that 
5 
you never received a massage --
6 
A. 
No. 
16:06:17 
7 
Q. 
-- from Jeffrey Epstein? 
16:06:18 
8 
MR. SCOTT: Unless you can show them and 
16:06:20 
9 
characterize them by date and time, you just 
10 
can't say here -- it's improper impeachment --
11 
that you've done this ten times. It's just 
12 
improper completely. 
13 
BY MR. SCAROLA: 
16:06:28 
14 
Q. 
Can you answer the question -- 
16:06:29 
15 
MR. SCOTT: And it's overly broad. 
16:06:29 
16 
BY MR. SCAROLA: 
16:06:30 
17 
Q. 
-- do you have any recollection of saying 
16:06:30 
18 
that you never received a massage? 
19 
A. 
I did receive a massage. 
16:06:32 
20 
Q. 
Do you have any recollection 
16:06:34 
21 
A. 
I have no recollection -- 
16:06:35 
22 
Q. 
-- of making that public statement that 
16:06:36 
23 
you never received a massage? 
24 
A. 
I can't imagine me saying that. If I said 
16:06:39 
25 
it, I was mistaken. I had one massage, to my 
EFTA00601322

170 
1 
recollection. 
2 
Q. 
Okay. Tell us about where that occurred. 
16:06:43 
3 
A. 
That occurred in my bedroom of Jeffrey 
16:06:45 
4 
Epstein's home in Palm Beach. I was asked whether 
5 
I -- Palm Beach. I was asked whether I wanted a 
6 
massage. I had been asked repeatedly whether I 
7 
wanted a massage and I had said no. Then I was told 
8 
that they had a masseuse coming from Miami who was a 
9 
specialist of some kind, she was very good, she was 
10 
Russian, and she worked, I think, in the Russian 
11 
baths or something like that, and I agreed to have a 
12 
massage. 
13 
I regretted it. She massaged me in a very 
16:07:25 
14 
tough and rough way. And she wanted to put her 
15 
knees on my shoulder and I said no. I immediately 
16 
called my wife when the massage was over and I told 
17 
her about the bad experience I had. And I said to 
18 
her, see, I really don't like massages. But my wife 
19 
likes massages. And she has had -- she has massages 
20 
frequently. 
21 
Q. 
This massage occurred in your bedroom in 
16:07:55 
22 
Jeffrey Epstein's house; is that correct? 
23 
A. 
Not in my bedroom, in the bedroom that I 
16:07:59 
24 
had been assigned, which was a guest bedroom. The 
25 
door was open. The -- a massage table was brought 
EFTA00601323

171 
1 
in. I kept my undergarments on. And I was massaged 
2 
maybe for 20 minutes or 25 minutes. And then 
and 
3 
then she left and I had an unpleasant experience and 
4 
I called my wife and I told her about it. 
5 
Q. 
Was the bedroom to which you were 
16:08:28 
6 
assigned, which you previously referred to as your 
7 
bedroom --
8 
A. 
No, no. I said "my bedroom" in the sense 
16:08:34 
9 
that I was in it. 
10 
Q. 
Was the bedroom to which you were assigned 
16:08:38 
11 
in the private section of the residence? 
12 
MR. SCOTT: Do you understand the 
16:08:46 
13 
question? 
14 
A. 
Yeah, let me explain exactly. This 
16:08:47 
15 
requires a long answer. 
16 
There -- when you walk into Jeffrey 
16:08:52 
17 
Epstein's house, there are two areas. If you walk 
18 
up the left side of the stairway, there are guest 
19 
bedrooms, three or four guest bedrooms. Those were 
20 
assigned to people like Senator George Mitchell, 
21 
Ehud Barak, prominent guests who would stay in his 
22 
house. Each one had its own bathroom and its own 
23 
bed. I stayed there with my wife for a period of 
24 
time. 
25 
But then there was another area of the 
16:09:26 
EFTA00601324

172 
1 
house, which I have never been in, ever, and which 
2 
nobody was allowed basically into, which was Jeffrey 
3 
Epstein's part of the house, which contained his 
4 
bedroom and whatever other rooms. I've read about 
5 
them, but I've never seen them. So it was in the 
6 
guest area of the house over the kitchen. 
7 
BY MR. SCAROLA: 
16:09:45 
8 
Q. 
Who told you no one was allowed in that 
16:09:47 
9 
area of the house? 
10 
A. 
I was told by the people that that was 
16:09:50 
11 
off -- off limits, that that was Jeffrey's --
12 
Q. 
Which people? 
16:09:54 
13 
A. 
Ghislaine, 
, 
that that 
16:09:56 
14 
was Jeffrey's area of the house and that the guests 
15 
were limited to the public areas of the house and 
16 
the -- and I think that's common in many houses when 
17 
you go and stay at somebody's house, you don't go 
18 
into their bathrooms and their bedrooms. 
19 
Q. 
And it's common for people to tell you, 
16:10:11 
20 
you're not allowed in this area of the house? 
21 
A. 
People -- people -- guests are not 
16:10:15 
22 
supposed to go to that area of the house. 
23 
Q. 
No, sir. That's my question. Is it 
16:10:19 
24 
common for you to be told --
25 
A. 
Yes. 
16:10:22 
EFTA00601325

173 
1 
Q. 
-- when you enter somebody's house, you're 
16:10:22 
2 
not allowed to go into this portion of the house? 
3 
A. 
Oh, yes. I just recently went to a -- a 
16:10:26 
4 
breakfast at somebody's house after Yom Kippur and I 
5 
wanted to show friends of mine the art that was in 
6 
the house and I started walking down the house and 
7 
the waiter said, oh, I'm sorry, you're not allowed 
8 
in -- in that part of the house, that's the private 
9 
residence. And so I had to turn around and show my 
10 
friends the art that was in the public area, not the 
11 
private area --
12 
Q. 
Jeffrey Epstein's art consisted of 
16:10:54 
13 
photographs of young naked girls all over the house, 
14 
right? 
15 
A. 
Are you testifying? That's false. I 
16:11:01 
16 
never saw any such thing. Ever. Never saw a 
17 
picture, with one exception, of a nude. The one 
18 
exception was a sepia print of Rodin's model that 
19 
appeared on one of his desks. 
20 
But in all the times I was at Jeffrey 
16:11:23 
21 
Epstein's house in Palm Beach, the one time I was in 
22 
his house in -- on the island, certainly the one 
23 
time in -- in the ranch because there was nothing 
24 
there, it was just a construction site, I never saw 
25 
a picture -- or in his house in New York, I never 
EFTA00601326

174 
1 
saw a picture of a naked woman, ever. 
2 
Q. 
The notice for deposition with which you 
16:11:45 
3 
were served both initially a few months ago and for 
4 
today's deposition is a notice of deposition duces 
5 
tecum. Could we please have the documents that 
6 
you --
7 
MR. SCOTT: We have a disk. I'll hand it 
16:12:01 
8 
to you at the end of the depo with everything 
9 
that's responsive 
10 
MR. SCAROLA: I would like it now, please. 
16:12:04 
11 
MR. SCOTT: Let the record reflect I'm 
16:12:13 
12 
handing the disk. 
13 
MR. SCAROLA: Thank you. 
16:12:16 
14 
MR. SIMPSON: Just for the record, it's a 
16:12:17 
15 
disk of all the documents that have been 
16 
produced in the case subject to the objections 
17 
and privilege assertions that have been made in 
18 
the case. 
19 
MR. SCAROLA: All right. And so that the 
16:12:25 
20 
record is clear, and hopefully you will be able 
21 
to make these arrangements by tomorrow, one of 
22 
the things that we want are the original of the 
23 
handwritten documents so that we have an 
24 
opportunity to examine those. 
25 
MR. SCOTT: I'll talk to him -- 
16:12:40 
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175 
1 
MR. SCAROLA: Calendars. 
16:12:41 
2 
MR. SCOTT: -- whether we comply or not. 
16:12:43 
3 
We'll discuss it off the record. 
4 
MR. SCAROLA: The flight logs, anything 
16:12:44 
5 
that's in handwritten form. 
6 
And we will reconvene tomorrow. What time 
16:12:50 
7 
would you like to start? 
8 
MR. SCOTT: 9:30. 
16:12:53 
9 
THE WITNESS: The earlier the better. 
16:12:54 
10 
9:00. 
11 
MR. SCAROLA: 9:00? 
16:12:55 
12 
MR. SCOTT: 9:00, good. 
16:12:56 
13 
MR. SCAROLA: 8:00, want to go to 8:00? 
16:12:57 
14 
MR. SCOTT: No, 9:00 is fine. 
16:12:59 
15 
MR. SCAROLA: Okay. Thank you. 
16:13:00 
16 
VIDEOGRAPHER: Going off the record. The 
16:13:00 
17 
time is approximately 4:13 p.m. 
18 
(The proceedings ADJOURNED at 4:13 p.m., 
19 
and will continue in Volume 2.) 
20 
21 
22 
23 
24 
25 
EFTA00601328

176 
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 15th day of 
October, 2015. 
Signed this 15th day of October, 2015. 
KIMBERLY FONTALVO, RPR, FPR, CLR 
Notary Public, State of Florida 
My Commission No. EE 161994 
Expires: 2/01/16 
EFTA00601329

177 
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 deposition of ALAN M. 
DERSHOWITZ; pages 1 through 170; 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 15th day of October, 2015. 
KIMBERLY FONTALVO, RPR, FPR, CLR 
EFTA00601330

178 
October 15, 2015 
Re: Bradley Edwards, etc. v. Alan M. Dershowitz 
Please take notice that on the 15th day of October, 
2015, 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, FPR, CLR 
Phipps Reporting, Inc. 
1615 Forum Place, Suite 500 
West Palm Beach, Florida 33401 
I do hereby waive my signature. 
ALAN M. DERSHOWITZ 
EFTA00601331

179 
ERRATA SHEET 
DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE 
In Re: BRADLEY EDWARDS, ETC. V. ALAN M. DERSHOWITZ 
ALAN M. DERSHOWITZ 
October 15, 2015 
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. DERSHOWITZ 
EFTA00601332