EFTA01111154

24 
1 
relieved any symptoms of atrial fibrillation or 
2 
atrial flutter, until they recurred -- until it 
3 
recurred about a month or maybe it's a month and a 
4 
half now. 1 can give you the exact dates. Because, 
5 
as I say, I have it on my -- on my machine. 
6 
Q. 
When did the atrial flutter occur? 
09:54:16 
7 
A. 
I told you that I don't have the exact 
09:54:20 
8 
date, but it occurred about a month, month and a 
9 
half ago, I think sometime in August of this year. 
10 
But I can give you the exact date. As I said, I 
11 
have it on my machine. 
12 
Q. 
So, what you have described as a 
09:54:33 
13 
recurrence of atrial fibrillation you are now 
14 
describing as an atrial flutter? 
15 
A. 
You're confused, sir. Please listen to my 
09:54:42 
16 
answers. What I've said was that I had atrial 
17 
flutter. Atrial flutter occurred after my initial 
18 
atrial fib. I then had an ablation. The flutter 
19 
and the fib both disappeared after the ablation. 
20 
And my atrial fib has returned. 
21 
Q. 
Given your superb memory, would you please 
09:55:13 
22 
name for us each of the lawyers who has represented 
23 
you in this case? 
24 
MR. SCOTT: Objection, form. 
09:55:22 
25 
Argumentative. 
EFTA01111174

25 
1 
if you need a document or anything to 
09:55:29 
2 
refresh your memory, please let us know. 
3 
A. 
Well, I'll start with the names of my 
09:55:34 
4 
lawyers. I've been represented by Judge Scott and 
5 
his law firm, including several associates and 
6 
paralegals. I don't know their status, whether 
7 
they're partners, associates or paralegals, but I've 
B 
had contact with them. 
9 
I have been represented by Mr. Simpson's 
09:55:54 
10 
law firm, including several partners, associates, 
11 
and paralegals. I've been represented by Kenneth 
12 
Sweder and presumably some of his partners and 
13 
associates. 
14 
I've been represented by Kendall Coffey 
09:56:15 
15 
and several of his associates and partners. I would 
16 
say those are my main lawyers. But I've also had 
17 
others. 
18 
I have sought the legal advice of Mark 
09:56:34 
19 
Fabiani, who was my former research assistant at 
20 
Harvard. I've sought the advice of Mitchell Webber, 
21 
who was my former research assistant at Harvard. 
22 
I was offered legal advice by Carlos 
09:56:52 
23 
Sires, who was -- who is a partner in the Boise firm 
24 
who -- who volunteered to represent me along with 
25 
one of his partners, but then withdraw from the 
EFTA01111175

26 
1 
representation when he discovered that I had a 
2 
conflict of Interest. 
3 
I've had consultations with a variety of 
09:57:18 
4 
other lawyers over particular issues in the case, 
5 
Floyd Abrams, who is probably the leading lawyer in 
6 
the world on First Amendment, has advised me on my 
7 
First Amendment rights to have said what I said 
8 
truthfully and expressed my opinion about your 
9 
clients. 
10 
I mean, that's the very beginning. But 
09:57:52 
11 
when the events first occurred, I got calls from 
12 
dozens of lawyers outraged by the unethical conduct 
13 
of your clients and offering to represent me 
14 
pro bono, offering to do anything they could to see 
15 
that these lawyers were appropriately punished and 
16 
disciplined. 
17 
David Markus, for example, of the Miami 
09:58:17 
18 
Bar called and keeps calling asking if there's 
19 
anything he can do to help me. 
20 
There's a lawyer in Broward named Diner, 
09:58:28 
21 
who has offered to represent me. It goes on and on 
22 
and on. The offers are still coming in. People are 
23 
just absolutely outraged by the unprofessional and 
24 
unethical conduct of your clients and are offering 
25 
to help me right a wrong and undo an injustice. 
EFTA01111176

27 
1 
MR. SCOTT: Just hold it. Somebody's 
2 
making noise on the phone and it's causing a 
3 
little disruption here. So, you know, I'm not 
09:59t00 
4 
sure who it is, one of you-all on the phone. 
5 
Thanks. 
6 
BY MR. SCAROLA: 
09:59:16 
7 
Q. 
Mr. Scott is obviously still representing 
09:59:21 
8 
you now; is that correct? 
9 
A. 
That's correct. 
09:59:24 
10 
Q. 
Richard Simpson is still representing you 
09:59:25 
11 
now; is that correct? 
12 
A. 
That's correct. 
09:59:27 
13 
Q. 
Ken Sweder is representing you now; is 
09:59:28 
14 
that correct? 
15 
A. 
That's correct, yes. 
09:59:30 
16 
Q. 
Is Kendall Coffey representing you now? 
09:59:30 
17 
A. 
Yes. 
09:59:33 
18 
Q. 
Is Mark Fabiani representing you now? 
09:59:35 
19 
A. 
Yes. 
09:59:37 
20 
Q. 
And when I ask "are they representing you 
09:59:38 
21 
now," they're representing you now in this 
22 
litigation; is that correct? 
23 
MR. SCOTT: I don't think that -- 
09:59:45 
24 
objection, form. I don't think that was 
25 
specified. 
EFTA01111177

28 
1 
MR. SCAROLA: Well, that's why I'm asking. 
09:59:48 
2 
MR. SCOTT: As opposed to general advice. 
09:59:50 
3 
A. 
Yes. Yes. 
09:59:52 
4 
BY MR. SCAROLA: 
09:59:53 
5 
Q. 
And Mark Fabiant is representing you with 
09:59:53 
6 
regard to this litigation; is that correct? 
7 
A. 
Yes, yes. 
09:59:57 
8 
Q. 
Floyd Abrams is representing you now with 
09:59:58 
9 
regard to this litigation; is that correct? 
10 
A. 
Yes. 
10:00:01 
11 
Q. 
Mitch Webber is representing you now with 
10:00:02 
12 
regard to this litigation; is that correct? 
13 
A. 
That's correct, yes. 
10:00:C6 
14 
Q. 
Is Steven Safra representing you with 
10:00:11 
15 
regard to this litigation? 
16 
A. 
Yes. 
10:00:15 
17 
Q. 
Is Mary Borja representing you now with 
10:00:15 
18 
regard to this litigation? 
19 
A. 
Yes. 
10:00:19 
20 
Q. 
Is Ashley Eller representing you now with 
10:00:20 
21 
regard to this litigation? 
22 
A. 
That's not a name that immediately comes 
10:00:24 
23 
to my head, but I believe it's an associate in one 
24 
of the law firms. I don't know the names of all the 
25 
lawyers who are doing the background work on the 
EFTA01111178

29 
1 
case for the law firms. 
2 
Q. 
Is Nicole Richardson representing you now 
10:00:37 
3 
with regard to this litigation? 
4 
A. 
Again, yes, yes. 
10:00:41 
5 
Q. 
Is Gabe Groisman representing you now with 
10:00:46 
6 
regard to this litigation? 
7 
A. 
Yes. 
10:00:49 
8 
Q. 
Is Ben Brodsky representing you now with 
10:00:51 
9 
regard to this litigation? 
10 
A. 
Ben Brodsky? I would have to check on 
10:00:59 
11 
that. 
12 
Q. 
Is Sarah Neely representing you now with 
10:01:06 
13 
regard to this litigation? 
14 
A. 
Sarah Neely has been my assistant and 
10:01:09 
15 
paralegal for the last some years and I have used 
16 
her to perform paralegal work for me in this 
17 
litigation. 
18 
Q. 
Is Nicholas Maisel representing you now 
10:01:27 
19 
with regard to this litigation? 
20 
A. 
Nicholas Maisel is my research assistant 
10:01:31 
21 
and paralegal on this litigation, yes. 
22 
Q. 
Is your wife representing you with regard 
10:01:39 
23 
to this litigation? 
24 
A. 
My wife has been instrumental in helping 
10:01:42 
25 
me gather all the records and information. She 
EFTA01111179

30 
1 
knows more about records and where my records are 
2 
kept and I've asked her to perform paralegal service 
3 
in addition to her loving service as my wife. 
4 
Q. 
Is Harvey Silverglate representing you now 
10:02:04 
5 
with regard to this litigation? 
6 
A. 
Yes. 
10:02:08 
7 
Q. 
Is Mark rabiani representing you now with 
10:02:09 
8 
regard to this litigation? 
9 
A. 
You've asked me that question and the 
10:02:12 
10 
answer is --
11 
Q. 
No, I asked you, sir, if he was your 
10:02:14 
12 
lawyer; but I haven't asked you whether he's 
13 
representing you now with regard to this litigation. 
14 
A. 
The answer is yes. 
10:02:20 
15 
Q. 
Is Floyd Abrams representing you now with 
10:02:22 
16 
regard to this litigation? 
17 
A. 
Yes. 
10:02:25 
18 
Q. 
Is Jamin Dershowitz representing you now 
10:02:26 
19 
with regard to this litigation? 
20 
A. 
Yes. 
10:02:30 
21 
Q. 
Is Nancy Gertner representing you now with 
10:02:32 
22 
regard to this litigation? 
23 
A. 
That requires a lengthier answer, if you 
10:02:36 
24 
will permit me. 
25 
Q. 
I haven't stopped you yet. 
10:02:41 
EFTA01111180

31 
1 
A. 
You've tried. 
10:02:43 
2 
Q. 
Much as I may have liked to. 
10:02:44 
3 
A. 
You've tried. 
10:02:45 
4 
MR. SCOTT: 
Scarola, that's probably 
10:02:47 
5 
one of the few times you and I agree on 
6 
something. 
7 
MR. SCAROLA: No, we've agreed on a lot, 
10:02:52 
8 
Tom. 
9 
MR. SCOTT: Yeah, we -- I'm kidding you. 
10:02:55 
10 
I'm kidding you. 
11 
MR. SCAROLA: I know you are. 
10:02:57 
12 
A. 
Nancy Gertner is one of the attorneys who 
10:02:58 
13 
called me immediately and expressed outrage at what 
14 
was happening to me and offered to help me. 
15 
Initially she wanted to help me by calling your 
16 
client, Professor Cassell, and explaining to him 
17 
that what I've been accused of could not possibly 
18 
have happened and there must have been a mistake or 
19 
something. And clearly she had confused me with 
20 
someone else. 
21 
And as I understand it, Nancy Gertner made 
10:03:29 
22 
that phone call to your client, Professor Cassell, 
23 
and Professor Cassell reiterated his false 
24 
accusation against me. 
25 
Thereafter, Nancy Gertner volunteered to 
10:03:42 
EFTA01111181

32 
1 
2 
become part of my legal team and to examine some of 
the witnesses in this case. 
3 
BY MR. SCAROLA: 
10:03:55 
4 
Q. 
Did you ever accept that offer from Nancy 
10:03:56 
5 
Gertner 
6 
A. 
Yes. 
10:03:59 
7 
Q. 
-- so as to establish$n attorney-client 
10:03:59 
8 
relationship with --
9 
A. 
Yes. 
10:04:04 
10 
Q. 
So she is one of your lawyers -- 
10:04:04 
11 
A. 
She is currently -- I regard her currently 
10:04:05 
12 
as one of my lawyers, yes. 
13 
Q. 
And is Mitch Webber one of your lawyers in 
10:04:08 
14 
this case? 
15 
A. 
Yes. 
10:04:11 
16 
Q. 
But if I just give you a name without 
10:04:12 
17 
18 
repeating the second part, "is that one of the 
lawyers in your case," will you understand --
19 
A. 
I understand. 
10:04:21 
20 
Q. 
-- that I'm asking you with regard to 
10:04:22 
21 
22 
these -- 
a lawyer 
each of these individuals whether they are 
representing you in this case? 
23 
A. 
Yes. 
10:04:30 
24 
Q. 
Okay. Anthony Julius? 
10:04:30 
25 
A. 
Anthony Julius is a British barrister and 
10:04:35 
EFTA01111182

33 
1 
solicitor who I conferred with regarding the 
2 
possibility of filing lawsuits against your clients 
3 
in Great Britain. I continue to confer with him on 
4 
matters relating to defamation. 
5 
Q. 
So you consider him to be one of your 
10:04:54 
6 
lawyers representing you with regard to matters 
7 
relating to this lawsuit? 
8 
A. 
I'll stand by -- 
10:05:00 
9 
MR. SCOTT: Objection, form. 
10:05:01 
10 
A. 
-- my answer. I'll stand by my answer. 
10:05:02 
11 
BY MR. SCAROLA: 
10:05:04 
12 
Q. 
Charles Ogletree? 
10:05:05 
13 
A. 
Charles Ogletree is a close personal 
10:05:06 
14 
friend and colleague at the Harvard Law School with 
15 
whom I have conferred about this case. I always 
16 
have regarded him as a personal attorney and 
17 
continue to confer with him about this case and the 
18 
general picture. So, I do regard him as one of my 
19 
lawyers in this litigation, yes. I certainly regard 
20 
him as having been given privileged information as 
21 
part of a lawyer-client privilege, yes. 
22 
Q. 
There -- there may be a time when I need 
10:05:47 
23 
more than just an answer to the question that I'm 
24 
asking as to whether these individuals are or are 
25 
not your lawyers in this case. That's not now. 
EFTA01111183

34 
So if you would, please, I would 
2 
appreciate it if you would tell me only whether 
these individuals are or are not your lawyers in 
10:06:01 
this case. 
A 
I'm sorry, but I cannot comply with that. 
10:06:09 
6 
I'm --
7 
Q. 
Well, you can but you refuse to. 
10:06:12 
8 
MR. SCOTT: Let's not interrupt him. 
10:06:14 
9 
A. 
Let me complete my answer, please. 
10:06:16 
10 
MR. SCOTT: It doesn't help the court 
10:06:17 
11 
reporter or the record. 
12 
A. 
I've been teaching legal ethics for close 
10:06:19 
13 
to 40 years. I understand the complexity of the 
14 
lawyer-client relationship. And it's impossible as 
15 
to some of the names you've mentioned to simply give 
16 
a yes or no answer to whether they are representing 
17 
me in this case. 
18 
What I can do is give you the facts and 
10:06:39 
19 
then you and others can draw legal conclusions from 
20 
those facts. But I -- I cannot, under my oath to 
21 
tell the truth, the whole truth and nothing but the 
22 
truth, respond to questions with yes or no answers 
23 
when those questions do not call for simplistic yes 
24 
or no answers. 
25 
EFTA01111184

:35 
1 
BY MR. SCAR0LA: 
10:07:01 
2 
Q. 
Is Philip Heymann a lawyer representing 
10:07:01 
3 
you in this case? 
4 
A. 
I have conferred with Philip Heymann on 
10:07:04 
5 
several occasions about several aspects of this case 
6 
and I regard him, for purposes of lawyer-client 
7 
privilege, as one of my lawyers on this case. 
8 
Q. 
David Oscar Markus, same question? 
10:07:18 
9 
MR. SCOTT: We covered him, didn't we? 
10:07:22 
10 
A. 
David Oscar Markus is a former student and 
10:07:23 
11 
research assistant of mine. Lives in Miami and 
12 
practices law. And he has repeatedly called and 
13 
offered me legal representation. Has offered to 
14 
help me in the legal context of this case. And I've 
15 
conferred with him on lawyer-client confidential 
16 
basis about this case on several occasion. 
17 
BY MR. SCAROLA: 
10:07:49 
18 
Q. 
Thomas Wiegand? 
10:07:49 
19 
A. 
Thomas Wiegand is a litigator in Chicago 
10:07:51 
20 
with whom I worked along with Carlos Sires and 
21 
Sigrid McCawley on the Guma Aguiar case in Florida. 
22 
And as soon as this case occurred, Thomas Wiegand 
23 
was one of those lawyers who called and offered to 
24 
represent me and do whatever he could to help undo 
25 
the injustice that had been perpetrated on me by 
EFTA01111185

36 
1 
your clients' false and mendacious allegations 
2 
regarding me and Virginia Roberts. 
3 
Q. 
Jeanne Baker? 
10:08:30 
4 
A. 
Jeanne Baker is a long-term associate, 
10:08:32 
5 
legal associate and friend who also called and 
6 
offered me legal help, legal representation, and I 
7 
continue to confer with her on a privileged basis. 
8 
Q. 
Rick Pildes? 
10:08:51 
9 
A. 
Rick Pildes is a professor at New York 
10:08:53 
10 
University law school and I sought his legal advice 
11 
on a particular issue in this case. And continue to 
12 
seek his legal advice. 
13 
Q. 
Susan Rosen? 
10:09:03 
14 
A. 
Susan Rosen is a prominent lawyer in 
10:09:04 
15 
Charleston, South Carolina and a cousin of my 
16 
wife's. And she has offered me legal advice about 
17 
this case as recently as two days ago. 
18 
Q. 
Alex MacDonald? 
10:09:24 
19 
A. 
Alex MacDonald is my personal lawyer in 
10:09:25 
20 
several instances in Massachusetts and he has 
21 
offered me advice and consultation on this case, 
22 
again volunteering in an effort to undo the horrible 
23 
injustice that was done to me by your clients' 
24 
mendacious willful and unprofessional conduct and 
25 
leveling of false charges, sexual misconduct against 
EFTA01111186

37 
1 
me at a time when they knew it wasn't true and 
2 
seeking to repeat that charge after they knew that 
3 
it was impossible that I could have engaged in any 
4 
of the 
5 
Q. 
6 
7 
school and also the wife of Steven Gillers and she, 
8 
along with Steven Gillers, have advised me and 
9 
conferred with me about the legal ethics aspects of 
10 
this case. 
11 
So you consider her to be one of your 
12 
lawyers in this case, is that 
13 
14 
15 
16 
17 
18 
19 
as having come within the lawyer-client privilege. 
20 
We've conferred on a number of occasions about the 
21 
ethical misconduct of your clients, 
22 
BY MR. SCAROLA: 
23 
Q. 
Rana Dershowitz? 
24 
A. 
Rana Dershowitz is my niece and Harvard 
25 
law school graduate, former chief counsel for the 
conduct that they have accused me of. 
Barbara Gillers? 
A. 
Barbara Gillers is at professor at NYU law 
A. 
i can --
MR. SCOTT: Object to the form. Go ahead. 
10:10:23 
Let me make an objection. I know you're just 
10:10:05 
10:10:06 
10:10:19 
10:10:22 
trying to answer, but go ahead, you can answer, 
sir. 
A. 
Sorry. I regard my conversations with her 
10:10:29 
10:10:43 
10:10:43 
10:10:45 
EFTA01111187

36 
1 
U.S. Olympic Committee and a prominent lawyer in 
2 
Colorado. And I've conferred with her on numerous 
3 
occasions about litigation and strategy and aspects 
4 
of this case. 
5 
Q. 
Ella Dershowitz? 
10:11:05 
6 
A. 
Ella Dershowitz is my daughter and she has 
10:11:06 
7 
served as a paralegal helping me gather material. I 
8 
don't think I regard her -- I certainly don't regard 
9 
her as a lawyer in the case. But I regard her as 
10 
somebody who has been a part of our kind of legal 
11 
team. 
12 
Q. 
Ellen Dershowitz? 
10:11:29 
13 
A. 
Ellen -- 
10:11:32 
14 
Q. 
Elon? 
10:11:33 
15 
A. 
Elon Dershowitz is my oldest son, child, 
10:11:34 
16 
and he has served repeatedly in a paralegal capacity 
17 
in this case helping me to gather information and 
18 
evidence and doing some investigative work for me. 
19 
Q. 
Nathan Dershowitz? 
10:11:52 
20 
A. 
Nathan Dershowitz is my brother. He's a 
10:11:52 
21 
distinguished attorney in New York, had his own law 
22 
firm. And he and I did a lot of our legal cases 
23 
together and as soon as this case emerged, I 
24 
conferred with him and have conferred with him on 
25 
numerous occasions about this case. 
EFTA01111188

39 
1 
Q. 
You consider him to be one of your lawyers 
10:12:14 
2 
in this case? 
3 
A. 
Yes. 
10:12:16 
4 
Q. 
Ben Brafman? 
10:12:17 
5 
A. 
Ben Brafman is one of the leading criminal 
10:12:19 
6 
lawyers and general lawyers in the City of New York? 
7 
He has volunteered to help me in any way he could in 
8 
this case and we have conferred and I have sought 
9 
legal advice from him in this -- in this matter. 
10 
Q. 
Arthur Aidala? 
10:12:36 
11 
A. 
Arthur Aidala is a distinguished member of 
10:12:38 
12 
the who's president of the Brooklyn Bar Association 
13 
and a former district attorney in Brooklyn. He has 
14 
volunteered to help me. He was outraged at the 
15 
unethical behavior of your clients and has sought 
16 
the opportunity to do everything in his power to try 
17 
to undo the injustice perpetrated on me by your 
18 
clients' mendacious and false and unethical 
19 
allegations against me, and I continue to confer 
20 
with him. 
21 
Q. 
David Zornow? 
10:13:15 
22 
A. 
David Zornow is the senior litigating 
10:13:17 
23 
partner at Skadden Arps in New York. He has offered 
24 
to assist me in this matter and I've conferred with 
25 
him and sought his legal advice. 
EFTA01111189

40 
1 
Q. 
Charles Johnson? 
10:13:31 
2 
A. 
Charles Johnson is my former research 
10:13:32 
3 
assistant and paralegal. I think we've taken his 
4 
name off the list of lawyers because he now, I 
5 
think, performs more of a journalistic job than a 
6 
legal one, though he has offered to help me gather 
information on your clients. 
8 
Q. 
When did you cease considering Charles 
10:14:02 
9 
Johnson to be your lawyer with regard to matters 
10 
relating to this case? 
11 
A. 
After a conference with my attorneys in 
10:14:10 
12 
Washington, D.C. about ten days ago or so. We went 
13 
through the list and that was one that I said was 
14 
too close a question and I would regard him more as 
15 
a blogger and a journalist than as a lawyer. But 
16 
it's a close question. 
17 
Q. 
David Efron? 
10:14:32 
18 
A. 
David Efron is a prominent lawyer in 
10:14:33 
19 
Miami, Florida and Puerto Rico. He was one, who 
20 
called me immediately and offered his assistance, 
21 
the assistance of his law firm. I've conferred with 
22 
him repeatedly about this case. 
23 
Q. 
In an attorney-client capacity; is that 
10:14:54 
24 
correct? 
25 
A. 
Yes. 
10:14:57 
EFTA01111190

43 
1 
Q. 
Ashe? 
10:14:57 
2 
A. 
Thomas Ashe is not a lawyer. He was one 
10:14:58 
3 
of the first people I called on the day I was 
4 
informed of the lies being spread by your clients. 
5 
Because he could help me gather all the information 
6 
necessary to prove that the only time I was ever in 
7 
New Mexico was visiting him and his wife, who is a 
8 
prominent film person, and his daughter, who is a 
9 
sex offender prosecutor in the Brooklyn District 
10 
Attorney's Office who specializes in sex 
11 
trafficking. 
12 
I needed to call them to prove what I knew 
10:15:49 
13 
immediately, that the only time I was ever at 
14 
Jeffrey Epstein's ranch was when I went to visit the 
15 
Ashes in New Mexico. I spoke to their daughter, the 
16 
prosecutor's, class. She was then in high school, 
17 
and took a day trip to Santa Fe. 
18 
Ashe had known -- had heard that Jeffrey 
10:16:15 
19 
Epstein had bought a ranch, a very large ranch in 
20 
New Mexico and Ashe was very interested in the 
21 
outdoors and asked me if I would do him a favor and 
22 
call to see if we could just take a look at what the 
23 
ranch looked like. And I did that. 
24 
And we spent about an hour looking around 
10:16:35 
25 
the house that was under construction. And I needed 
EFTA01111191

42 
1 
Ashe to gather all the evidence for me, including 
2 
journal entries in his daughter's journal, 
3 
photographs, other evidence and proof of our visit 
4 
to the ranch, which your client encouraged Virginia 
5 
Roberts to include in an affidavit -- perjurious 
6 
affidavit, that she submitted with details, false 
7 
and mendacious details that could not have occurred 
8 
about an alleged sexual encounter between her and me 
9 
at the ranch in New Mexico. 
10 
Q. 
Which of my clients are you swearing under 
10:17:30 
11 
oath encouraged Virginia Roberts to include 
12 
allegations of an encounter with you at the 
13 
New Mexico ranch? 
14 
A. 
Both of them, both of your clients, both 
10:17:49 
15 
Judge Cassell and Mr. Edwards were both involved in 
16 
encouraging your client to file a perjurious 
17 
affidavit that they knew or should have known was 
18 
perjurious and did know was perjurious recently when 
19 
they sought to file another defamatory allegation in 
20 
the federal proceeding. 
21 
Q. 
Was the encouragement such that what you 
10:18:21 
22 
are charging Bradley Edwards and Professor Paul 
23 
Cassell with doing was suborning perjury? 
24 
A. 
Absolutely. 
10:18:34 
25 
MR. SCOTT: Objection, form. 
10:18:35 
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94 
l 
absolutely, categorically lying. So I am completely 
2 
aware that never, until the lies were put in a legal 
3 
pleading at the end of December 2014, it was never 
4 
alleged that I had any sexual contact with Virginia 
5 
Roberts. 
6 
I know that it was alleged that I was a 
11:38:46 
7 
witness to Jeffrey Epstein's alleged abuse and that 
8 
was false. I was never a witness to any of Jeffrey 
9 
Epstein's sexual abuse. And I wrote that to you, 
10 
something that you have falsely denied. And I stand 
11 
on the record. The record is clear that I have 
12 
categorically denied I was ever a witness to any 
13 
abuse, that I ever saw Jeffrey Epstein abusing 
14 
anybody. 
15 
And -- and the very idea that I would 
11:39:18 
16 
stand and talk to Jeffrey Epstein while he was 
17 
receiving oral sex fro. 
, which she 
18 
swore to under oath, is so outrageous, so 
19 
preposterous, that even David Boies said he couldn't 
20 
believe it was true. 
21 
MS. McCAWLEY: I object. I object. I'm 
11:39:40 
22 
not going to allow you to reveal any 
23 
conversations that happened in the context of a 
24 
settlement discussion. 
25 
THE WITNESS: Does she have standing? 
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