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1 
visited his house. My wife visited his house. I 
2 
never would have permitted anybody to visit a home 
3 
that had those kinds of pictures displayed. 
4 
BY MR. EDWARDS: 
5 
Q. 
Was 
lying when she said 
6 
that Epstein sent girls to some of his friends? 
7 
MR. INDYKE: Same objection, same 
8 
instruction. 
9 
BY MR. EDWARDS: 
10 
Q. 
To any of his friends? 
11 
MR. SCOTT: Only on nonprivileged. 
12 
A. 
To the extent that she said that I was one 
13 
of those friends, which I know is a categorical 
14 
absolute lie, I would not believe anything she said 
15 
about having been sent to others of his friends. 
16 
But I don't have personal knowledge of that. All I 
17 
have is personal knowledge that lied when she said 
18 
she was sent to me. 
19 
MR. INDYKE: Same objection. 
20 
BY MR. EDWARDS: 
21 
Q. 
Have you at any time obtained personal 
22 
knowledge of Jeffrey Epstein having sent any girls 
23 
to any of his friends? 
24 
A. 
No. 
25 
MR. INDYKE: Same objection, same 
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1 
instruction. Please wait for the objection. 
2 
MR. SCOTT: Please listen. 
3 
THE WITNESS: I'm sorry. 
4 
BY MR. EDWARDS: 
5 
Q. 
When and under what circumstances did you 
6 
first hear 
' name? 
7 
A. 
My recollection --
8 
MR. INDYKE: Same objection, same 
9 
instruction. 
10 
A. 
My answer will show it's not privileged. 
11 
My current recollection is the first time I heard 
12 
the name was when I was called and told that she was 
13 
accusing me. The name was not familiar to me at the 
14 
time. 
15 
BY MR. EDWARDS: 
16 
Q. 
Were you ever familiar with the list of 
17 
victims that were listed as a part of the criminal 
18 
investigation -- the federal criminal investigation? 
19 
MR. SCOTT: Asked and answered in the last 
20 
depo and earlier today. 
21 
MR. INDYKE: Same objection, same 
22 
instruction. 
23 
BY MR. EDWARDS: 
24 
Q. 
Was 
lying when she said that 
25 
Jeffrey Epstein's code word for sexual encounters 
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1 
with minors was "massage"? 
2 
A. 
I have no idea. 
3 
MR. INDYKE: Same objection, same 
4 
instruction. 
5 
BY MR. EDWARDS: 
6 
Q. 
Have you reviewed the message pads that 
7 
were taken as a result of trash pulls conducted by 
8 
the Palm Beach Police Department on Jeffrey 
9 
Epstein's home? 
10 
A. 
Not to my knowledge. 
11 
MR. INDYKE: Same objection, same 
12 
instruction. 
13 
BY MR. EDWARDS: 
14 
Q. 
Have you reviewed the document that has 
15 
been at times referred to as the "Holy Grail," which 
16 
is a phone journal from Jeffrey Epstein's computer? 
17 
MR. INDYKE: Same objection, same 
18 
instruction to the extent it's privileged and 
19 
you got it other than from any kind of 
20 
disclosure by Mr. Edwards. 
21 
MR. SCOTT: Unless it's nonprivileged. 
22 
SPECIAL MASTER POZZUOLI: All these 
23 
questions -- with respect to nonprivileged, if 
24 
you can answer them, answer them. 
25 
A. 
I'm happy to answer them all. So the 
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question is am I familiar with this -- is this the 
2 
one that has the circles? 
3 
BY MR. EDWARDS: 
4 
Q. 
Yes. 
5 
A. 
That has Donald Trump circled and Bill 
6 
Clinton circled and me circled? 
7 
Q. 
I didn't know that it had Bill Clinton 
8 
circled. 
9 
A. 
Maybe not. 
10 
Q. 
So, just so that the record is clear, the 
11 
journal -- was the journal 
12 
MR. SCOTT: Was this marked in the last 
13 
depo? I don't recall. I don't think so. 
14 
MR. SCAROLA: I don't think that it was. 
15 
MR. INDYKE: To the extent that those 
16 
items are from -- I think the exhibits are a 
17 
statement of undisputed facts, obviously my 
18 
objection would apply to those items. To the 
19 
extent that they came out of Mr. Dershowitz's 
20 
representation of Mr. Epstein, I would object 
21 
if the answer is based as to information in 
22 
them. 
23 
SPECIAL MASTER POZZUOLI: We haven't seen 
24 
the exhibit yet. I know you are on the other 
25 
end of the phone. 
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THE WITNESS: Can I take a one-minute, 
2 
two-minute break? 
3 
VIDEOGRAPHER: Going off the record, 
4 
2:43 p.m. 
5 
(Recess was held from 2:43 p.m. until 2:45 p.m.) 
6 
VIDEOGRAPHER: Going back on the record. 
7 
The time is approximately 2:45 p.m. 
8 
BY MR. EDWARDS: 
9 
Q. 
Have you ever read the case documents 
10 
related to the arrest of Alfredo Rodriguez for the 
11 
Federal obstruction of justice charges? 
12 
A. 
No. 
13 
MR. INDYKE: Same objection, same 
14 
instruction. 
15 
MR. SIMPSON: Just pause for a second 
16 
before answering to let Mr. Indyke jump in if 
17 
he needs to. 
18 
BY MR. EDWARDS: 
19 
Q. 
The journal that we're talking about is 
20 
the one that has been disclosed in discovery in this 
21 
case and in prior cases where, as you mentioned 
22 
before, certain people's names are circled. Are you 
23 
familiar with that document? 
24 
A. 
I have perused the part of it that circled 
25 
me and some other prominent names. I have not read 
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1 
2 
3 
4 
5 
6 
the whole document. 
Q. 
I'm going to show you the page from this 
journal that is for Bill Clinton just based off of 
your last comment, and then I'll ask you some 
questions about that. 
A. 
This doesn't say Bill Clinton, it says 
7 
Doug Band. That's what you're talking about. 
8 
(Thereupon, marked as Plaintiff 
9 
Exhibit 20.) 
10 
A. 
This doesn't have an entry for Bill 
11 
Clinton 
It has an entry for Douglas Band, who I 
12 
know. 
13 
BY MR. EDWARDS: 
14 
Q. 
You know Doug Band? 
15 
A. 
Sure. 
16 
Q. 
Is Doug Band affiliated with Bill Clinton? 
17 
A. 
Oh, yeah, he was. Not any longer. 
18 
Q. 
19 
A. 
20 
Q. 
21 
A. 
22 
23 
24 
25 
A. 
How do you know Doug Band? 
Through Bill Clinton. 
How do you know Bill Clinton? 
I've known him for --
MR. INDYKE: Objection. Same objection, 
same instruction. 
MR. SIMPSON: Nonprivileged information. 
Well outside of my relationship with 
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Jeffrey Epstein. I was -- supported him. I've been 
2 
to the White House at his invitation. I've had 
3 
dinner with him on numerous occasions. 
4 
BY MR. EDWARDS: 
5 
Q. 
Have you called Bill Clinton with respect 
6 
to the allegations that have been made in this 
7 
lawsuit? 
8 
A. 
I've tried to. 
9 
Q. 
Has Bill Clinton given you any comment 
10 
whatsoever on any of the allegations? 
11 
A. 
Not personally, but Doug Band has. And 
12 
13 
14 
15 
16 
17 
18 
with Doug Band? 
19 
A. 
Very shortly after the accusation, as soon 
20 
as I could reach him. 
21 
Q. 
January 2015? 
22 
A. 
Probably January. 
23 
Q. 
Is Doug Band somebody who traveled with 
24 
Jeffrey Epstein as well? 
25 
A. 
That's true -- no, he traveled --
Q. 
When was that conversation that you had 
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1 
MR. INDYKE: Same objection, same 
2 
instruction. 
3 
A. 
He traveled with Bill Clinton always. I 
4 
mean, he was his body man. He was the guy who 
5 
traveled with him wherever he went. 
6 
BY MR. EDWARDS: 
7 
Q. 
My question is, did Doug Band ever travel 
8 
with Bill Clinton -- I mean with Jeffrey Epstein? 
9 
A. 
I don't know the answer to that. 
10 
Q. 
Well, did Bill Clinton ever travel with 
11 
Jeffrey Epstein? 
12 
MR. SIMPSON: Asked and answered. 
13 
MR. INDYKE: Same objection, same 
14 
instruction. 
15 
A. 
According to public information, yes. 
16 
BY MR. EDWARDS: 
17 
Q. 
And Doug Band, you are saying, was always 
18 
with Bill Clinton? 
19 
A. 
Not always, but he was the guy who 
20 
traveled with him. Nobody can be with anybody 24/7. 
21 
Q. 
The flight logs will speak for themselves 
22 
whether the two were traveling together, correct? 
23 
A. 
I have no idea. 
24 
Q. 
That entry -- I believe the comment that 
25 
you made was that was Alfredo Rodriguez had circled 
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Bill Clinton's name. 
2 
A. 
I thought he had. He circled a lot of 
3 
prominent people's names, Hollywood actors. 
4 
MR. INDYKE: Objection. Do you know that 
5 
outside of your relationship with Mr. Epstein? 
6 
THE WITNESS: Yes, I saw the --
7 
MR. INDYKE: I'm asking Mr. Dershowitz if 
8 
he's answering that question outside of his 
9 
relationship with -- his attorney-client 
10 
relationship or work product relationship or 
11 
common interest relationship with Mr. Epstein. 
12 
THE WITNESS: Yes. 
13 
MR. SIMPSON: The document was produced in 
14 
discovery. 
15 
MR. INDYKE: The question is as for the 
16 
circles in the document. 
17 
A. 
The document I saw had circles in it, and 
18 
I saw that in discovery in this case. I hadn't seen 
19 
it previously. 
20 
MR. INDYKE: Okay. 
21 
BY MR. EDWARDS: 
22 
Q. 
So you have seen the notations that 
23 
Alfredo Rodriguez made to the document during the 
24 
time he was turning the document over to the FBI? 
25 
A. 
The only notations that I saw that I 
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1 
recall are circles. 
2 
Q. 
Okay. And is it your understanding that 
3 
Alfredo Rodriguez was indicating to the FBI who was 
4 
involved in the illegal activity with minors along 
5 
with Jeffrey Epstein? 
6 
A. 
Absolutely not. Categorically absolutely 
7 
not. 
8 
MR. INDYKE: Same objection, same 
9 
instruction. 
10 
BY MR. EDWARDS: 
11 
Q. 
That's not your understanding? 
12 
A. 
Not only is it not my understanding, it is 
13 
a totally false statement because if it were true, 
14 
Donald Trump would be standing accused of having 
15 
improper sexual conduct and many other Hollywood 
16 
actors, actresses and other people who have never 
17 
been accused by your lying client would also stand 
18 
accused. 
19 
SPECIAL MASTER POZZUOLI: Let's move --
20 
MR. EDWARDS: That was not my question. 
21 
SPECIAL MASTER POZZUOLI: Let me stop 
22 
before we get too far down this. The document 
23 
that -- the portion of the document that you're 
24 
asking questions upon, let's understand the 
25 
context of the questions, and Mr. Dershowitz's 
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1 
answer so far has been that because it's been 
2 
produced in this case. So let's stay focused 
3 
on that. 
4 
A. 
Can I see that document, please. 
5 
MR. INDYKE: Just for clarification, I 
6 
don't want to interrupt, but for clarification, 
7 
I wasn't objecting to the document. I was 
8 
objecting to the foundation upon which 
9 
Mr. Dershowitz may or may not know why they 
10 
were circled, how that information came 
11 
through. 
12 
A. 
I know that independently. 
13 
BY MR. EDWARDS: 
14 
Q. 
You know why the various circles were made 
15 
independently? 
16 
A. 
No, but I know what the allegation is. 
17 
Q. 
The allegation -- you know what the 
18 
allegation is why the circles were made? 
19 
A. 
I know that it was not that the people 
20 
whose name were circled were involved in any illegal 
21 
activity. Can you please show me the document. 
22 
MR. SCOTT: Can he see the exhibit? 
23 
MR. SCAROLA: I --
24 
MR. EDWARDS: I don't have it. I mean, I 
25 
only have the piece of the page that he just 
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1 
talked about, which is Bill Clinton. I mean, I 
2 
have it and I'll copy it for you and I'll give 
3 
it to you tomorrow and we can talk about the 
4 
whole document. 
5 
A. 
It is a categorical lie --
6 
MR. SCOTT: Let's put it over until 
7 
tomorrow, then, when we have the exhibit. 
8 
BY MR. EDWARDS: 
9 
Q. 
Well, that before you -- you just 
10 
indicated that one of the people who was circled was 
11 
Bill Clinton. 
12 
A. 
I said I thought. 
13 
MR. SCOTT: He also indicated he would 
14 
like to see the whole exhibit. 
15 
BY MR. EDWARDS: 
16 
Q. 
On that page that's before you that's 
17 
listed Doug Band, is Bill Clinton's name listed 
18 
under that? 
19 
A. 
It says Office of William J. Clinton. 
20 
Q. 
Are there numbers for Bill Clinton listed 
21 
under that entry? 
22 
A. 
I assume they're numbers of Bill Clinton. 
23 
I assume so. 
24 
Q. 
When you talked to Doug Band, can you tell 
25 
us what that conversation was that you had with Doug 
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1 
Band? 
2 
A. 
Yes. 
12 
Q. 
Go on. What did Doug Band tell you? 
13 
A. 
That it wasn't true. 
14 
Q. 
Did Doug Band tell you whether Bill 
15 
Clinton had ever been to Jeffrey Epstein's island? 
16 
A. 
He told me that to his knowledge, 
17 
President Clinton had never been to Jeffrey 
18 
Epstein's island. 
19 
Q. 
Did he tell you whether Bill Clinton and 
20 
Jeffrey Epstein had ever shared a meal together? 
21 
A. 
I didn't ask him that question. I only 
22 
asked him about the island. I think I only asked 
23 
him -- I'm not positive whether I asked him during 
24 
the relevant period or ever. I think I asked him 
25 
ever. 
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1 
Q. 
Had -- has Bill Clinton ever flown on an 
2 
airplane -- or sorry, on a helicopter with Ghislaine 
3 
Maxwell? 
4 
A. 
Not to my knowledge. 
5 
MR. INDYKE: Objection. Same objection, 
6 
same instructions. 
7 
A. 
I cannot imagine the former President or a 
8 
President of the United States being allowed by the 
9 
Secret Service to fly on a helicopter with a pilot 
10 
who had just barely been licensed. 
11 
BY MR. EDWARDS: 
12 
Q. 
I'm just asking what you know. Do you 
13 
know whether or not 
14 
A. 
I know -- I know that Bill Clinton never 
15 
flew 
never was flown by Ghislaine Maxwell to the 
16 
island. I know it based on my common sense 
17 
experience. 
18 
Q. 
Not my question. My question is, do you 
19 
know whether Bill Clinton ever flew on a helicopter 
20 
with Ghislaine Maxwell? 
21 
MR. SCOTT: On the phone, there's 
22 
background. Thank you. 
23 
A. 
I don't know for sure, but I would 
24 
seriously doubt it. 
25 
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1 
BY MR. EDWARDS: 
2 
Q. 
Okay. 
3 
A. 
We're going to get tomorrow the circled 
4 
document that we can look at? 
5 
Q. 
I can find it now and I can get it and we 
6 
can look at it today. 
7 
MR. SCOTT: Take a minute. 
8 
A. 
I want to make sure we see all the circled 
9 
names. 
10 
MR. EDWARDS: Here's a copy right here 
11 
that we can copy at the next break. 
12 
MR. SCOTT: Sure. 
13 
BY MR. EDWARDS: 
14 
Q. 
Was 
lying when she says 
15 
that Ghislaine Maxwell served as Jeffrey Epstein's 
16 
madam? 
17 
MR. INDYKE: Same objection, same 
18 
instruction. 
19 
A. 
I would have no knowledge that would 
20 
establish that. Certainly I wouldn't believe it 
21 
just because she said it. 
22 
BY MR. EDWARDS: 
23 
Q. 
Have you asked Ghislaine Maxwell about 
24 
that? 
25 
A. 
No. 
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1 
MR. INDYKE: Same objection, same 
2 
instruction. 
3 
BY MR. EDWARDS: 
4 
Q. 
One of the things -- one of the statements 
5 
that we began the day with was that something that 
6 
Paul and I could have done was call you and ask you, 
7 
right, we could have picked up the phone and called 
8 
you? 
9 
A. 
You and Mr. Cassell, yeah. Yeah. 
10 
Q. 
When you were representing Jeffrey Epstein 
11 
back in 2007, did you ever insist that Jeffrey 
12 
Epstein had paid for massages, but had not engaged 
13 
in sex or erotic massages with any minors? 
14 
MR. INDYKE: Same objection, same 
15 
instruction to the extent that you can 
16 
specify --
17 
BY MR. EDWARDS: 
18 
Q. 
I'm asking whether you ever made that 
19 
statement. 
20 
MR. INDYKE: Same objection, same 
21 
instruction. 
22 
A. 
Can you repeat the question for me? 
23 
THE REPORTER: "When you were representing 
24 
Jeffrey Epstein back in 2007, did you ever 
25 
insist that Jeffrey Epstein had paid for 
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1 
massages, but had not engaged in sex or erotic 
2 
massages with any minors?" 
3 
SPECIAL MASTER POZZUOLI: By definition of 
4 
your question, it's within the representation 
5 
of Jeffrey Epstein, right? So in a -- without 
6 
any further clarification, I would agree with 
7 
the objection. 
8 
MR. SCAROLA: I'm sorry, this is about a 
9 
public statement. 
10 
MS. McCAWLEY: It's a public statement. 
11 
MR. EDWARDS: It's a public statement that 
12 
he makes to the New York --
13 
SPECIAL MASTER POZZUOLI: So then make 
14 
your question limited to that. Then I can rule 
15 
on that. That's why looked at the question. 
16 
MR. SCOTT: If you specify where the 
17 
statement came from, it would be helpful. 
18 
BY MR. EDWARDS: 
19 
Q. 
Did you ever make a public statement --
20 
did you ever make a statement in public that Jeffrey 
21 
Epstein had paid for massages, but had not engaged 
22 
in sex or erotic massages with any minors? 
23 
A. 
May I see the statement? 
24 
Q. 
Sure. 
25 
MR. SCAROLA: No. 
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1 
BY MR. EDWARDS: 
2 
Q. 
Well, did you make that statement? 
3 
A. 
I have no recollection of whether I made a 
4 
statement like that ten years ago. I'd like to see 
5 
the statement. 
6 
MR. SCAROLA: Now you can refresh his 
7 
recollection. 
8 
MR. INDYKE: Same objection, same 
9 
instruction. 
10 
BY MR. EDWARDS: 
11 
Q. 
Did you make a public statement that 
12 
Epstein was innocent of all allegations? 
13 
MR. SCOTT: Let me object to this in the 
14 
context that he's asking him statements from 
15 
ten years ago without specifying date, time and 
16 
place. It's just unfair. 
17 
SPECIAL MASTER POZZUOLI: If you're 
18 
reading from an article, published article, 
19 
then show him that. Let's stop for a second. 
20 
Do you recall making that statement? 
21 
THE WITNESS: I do not recall. 
22 
SPECIAL MASTER POZZUOLI: Will you show 
23 
him something that might 
24 
BY MR. EDWARDS: 
25 
Q. 
Sure. I'm going to go through each of the 
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1 
2 
3 
4 
three statements and then I'm going to show you the 
document. 
SPECIAL MASTER POZZUOLI: These all deal 
with public statements, right? 
5 
Q. 
Yes. 
6 
BY MR. EDWARDS: 
7 
8 
9 
10 
11 
12 
• 
^ou 
e p o re res your reco ec ion 
13 
if I showed you the statement? 
14 
A. 
Yes. 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
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www.phi sre orting.com 
So your --
MR. SCOTT: Are we going to mark that? 
MR. EDWARDS: Yes, we can mark that. 
5 
BY MR. EDWARDS: 
6 
9 
10 
11 
12 
BY MR. EDWARDS: 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
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