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233 
limitations. yes. 
Q. You refused to waive the statute of 
limitations with regard to sexual crimes, correct? 
A. I didn't refuse anything. I didn't feel I 
had any obligation to respond to you. And I did 
not. 
Q. So, you were asked to waive the statute of 
limitations with regard to your sexual crimes and 
you refused to respond? 
A. I was asked by you, utterly 
inappropriately, and what I had said -- and if you 
check what I said, I said if any reasonable 
prosecutor were to investigate the case and find 
that there was any basis, I would then waive the 
statute of limitations. I didn't waive the statute 
of limitations because you, a lawyer, for two 
unprofessional, unethical lawyers asked me to do so, 
what obligation do I have to respond to you? 
Q. Well, you have no obligation to respond to 
me at all, Mr. Dershowitz, except now while sou are 
under oath and I am asking you questions and I would 
greatly appreciate you responding to the questions 
that I ask. 
MR. SCOTT: I think lies trying. 
235 
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Q. And by dropping the dint on the media when 
2 
they Bled it, you Intended to convey the message 
3 
that Paul Cassel: and Bradley Edwards intentionally 
4 
generated the focus of press attention on that 
filing; is that correct? 
6 
A. Absolutely. Absolutely without any doubt. 
7 
Why else would they have brought Prince Andrew into 
this filing? Prince Andrew had no connection to the 
9 
NPA. no relevance at all. But they knew that by 
10 
including Prince Andrew. this would ding my name 
11 
into every single newspaper and media outlet in the 
12 
world. 
13 
It Was outrageous for them to do this. 
14 
Particularly because they did so little, if any, 
15 
investigation, which will, of course, be determined 
16 
when they're deposed. And -- and --
17 
Q. Well, you've already made that 
18 
determination, right? 
19 
MR. SCOTT: Wait. 
20 
A. I'm convinced that -- that they did little 
21 
or no investigation. They never even bothered to 
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call me. That would have been --
23 
BY MR. SCAROLA: 
24 
Q. We'll get to that in just a moment. 
25 
A. -- a simple basic thing. 
234 
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BY MR. SCAROLA: 
2 
Q. You made the further statement in that 
3 
sane Interview, "They dropped the dime on the media 
4 
when they filed it," referring to the CVRA 
5 
pleading --
6 
A. Right. 
7 
Q. —in which were you named? 
8 
A. Right. 
9 
Q. What is the basis for that statement? 
10 
A. The basis for that statement was that the 
n 
filing was done virtually on the eve of New Year's 
12 
on a day that the press was completelydead. And 
13 
nonetheless. immediately upon the filing, I got a 
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bamge of phone calls that led me to conclude and 
15 
led many, many, many other lawyers who called me to 
16 
conclude that obviously somebody tipped somebody off 
17 
that they didn't just happen to file -- to find in 
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the middle of an obscure pleading which didn't even 
19 
have a heading that indicated that I was involved or 
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anybody else was involved. 
21 
So, I'm certain that a dime was dropped to 
22 
somebody saying, by the way, you want an interesting 
23 
story. there's 
Prince Andrew of Great Britain and 
24 
Alan Dershowitz have been accused of sexual 
25 
misconduct. I still believe that 
236 
Q. But right now — right now could you 
2 
please tell us was there anything other thau your 
3 
inferring that they must have contacted the media to 
4 
support your conclusion that either Paul Cassell or 
5 
Brad Edwards did, in fact, alert the media at the 
6 
time of the filing of this pleading? 
7 
A. Yes. 
8 
Q. What else besides your inference? 
9 
A. When the BBC cant to see me, the BBC 
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reporter showed me an e-mail from Paul Cassell, 
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which urged him, the BBC reporter. to ask me a 
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series of questions. So I knew that Paul Cassell 
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was in touch with the British media and was trying 
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to stimulate and initiate anbarrassing questions to 
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be asked of me. 
16 
And when I spoke to a number of reporters, 
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they certainly -- obviously reporters have 
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privilege, but they said things that certainly led 
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me to infer that they had beat in close touch with 
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your clients or representatives on their behalf. 
21 
Q. What was the date of the e-mail —
22 
A. 'don't know. 
23 
Q. — that you referenced in that response? 
24 
Q
A. Imrdoeinli.1 know. 
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239 
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A. It was whenever -- I'm not sure I ever saw 
1 
MR. SCOTT: I think he's answered that 
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the date. He just quidcly showed me the e-mail and 
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twice. 
3
I quickly looked at it. 
3 
A. It came after. It came after. 
4 
Q. The c-mall that you are referencing, in 
4 
BY MR. SCAROLA: 
5
fact, occurred after you had begun all of your media 
5
Q. Thank you, sir. On January 5, you made 
6
appearances with respect to this filing — 
6
another CNN Live appearance in an intervkw with 
7 
A. Let niche very clear about — 
7
11212 Gorani. Do you recall that? 
8 
Q. — didn't it, sir? 
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A. I do not =all the name of the person — 
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A. Lel me be very clear about my media 
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Q. Take a look at the transcript, if you 
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appearances so that I— 
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would, please, page IS. 
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Q. How about just answering the questions? 
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MR. SCOTT: Take a moment to review the 
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A. I'm trying to answer the question. All of 
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transcripL please, Mr. Dasbowitz. 
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my media appearances -- 
13 
THE WITNESS: Page IS. 
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Q. The question is: Did it occur before or 
14 
MR. SCOTT: Take your time to review that. 
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after your media — your media appearances? That 
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A. Yeah, that name is not familiar to me but. 
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doesn't call for a speech — 
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of count, I remember doing an interview, yes. 
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A. It came — 
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BY MR. SCAROLA: 
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Q. — it calls for before or alter. 
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Q. All right, sir. And during the course of 
19 
A. It came before some and alter somc. Ii 
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that interview, you said: "There are flight 
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came, for example, before my appearance on the BBC 
20 
manifests. They will prove I was never on any 
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because they showed me the e-mail before they 
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private airplane with any young woman." Correct? 
22 
interviewed me for the BBC. So sonic occurred —it 
22 
A. Yes. 
23
occurred before some and it occurred after sonic. 
23 
Q. Go to page 17, if you would. 
24 
Q. All right. So It Is your assertion that 
24 
A. Uh-huh. 
25 
this single egnall that you have made reference to 
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Q. At line 4 of transcript of that same 
238 
240 
1
where Paul Cassell says "asks Dershowitz these 
1
Interview, you said: "She made the whole thing up 
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questions" occurred before your —your media 
2
out of whole cloth. I can prove it by flight 
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appearances and after your media appearances; Is 
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records. I can prove it by my travel records." 
4 
that correct? 
4 
Did you make those statements? 
5 
MR. SCOTT: Objection. form. argumentative 
5 
A. Yes• and the/re absolutely tone. 
6 
and repetitious. 
6 
Q. Okay. I am going to hand you every flight 
7 
A. It occurred before some of the media 
7
record that has been produced in connection with 
8
appearances, and it occurred after some of media 
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this litigation. 
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appearances. yes. 
9 
A. Uh-huh. 
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BY MR. SCAROLA: 
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MR. SCAROLA: Could we mark that as the 
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Q. Did It occur before your first media 
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next composite exhibit, please? 
12 
appearances? 
12 
(Thereupon. marked as Plaintiff 
13 
A. My first media appearances came as the 
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Exhibit 6.) 
14 
result of phate calls I received from -- 
14 
MR. SCAROLA: And mark this as the next 
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Q. That's nonresponsive to my question, sir. 
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composite exhibit, which will be7. 
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A. -- newspapers -- 
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MR. SCOTT: These are all the flight 
17 
Q. I didn't ask you anything about what your 
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inanuals? 
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lint media appearances occurred — 
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MR. SCAROLA: As far as I know. 
19 
A. Yes, you did' . 
19 
MR. SCOTT: Clicay. 
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Q. — as a rank of. I asked you — 
20 
MR. SCAROLA: They're the only ones that 
21 
MR. SCOTT: Let him ask his question. 
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have been produced in discovery. If there arc 
22 
BY MR. SCAROLA: 
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more, I'm going to be interested to hear about 
23 
Q. -- whether the e-mail that you claimed to 
23 
it. 
24 
have seen was sent before or after your first media 
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(Thereupon. marked as Plaintiff 
25 
appearance? 
25 
Exhibit 7.) 
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(Discussion off the record.) 
2 
THE WITNESS: What's Number 6 then? Tin 
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confused. there were two. 
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BY MR. SCAROLA: 
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Q. Have you ever seen Exhibit Number 6 
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before? 
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A. Exhibit Number 6. I don't believe so. It 
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doesn't look familiar to me. 
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Q. No? 
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A. It does not look familiar to me. 
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Q. Did you bother at any time to review 
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discovery that was produced by Bradley Edwards and 
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Paul Cassell responding to requests for information 
14 
that supported the allegations 
15 
A I'm not clear what you're as mg. 
16 
Q. I want to know —
17 
A. In which case? In which case am we 
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talking? 
19 
Q. This case. This case. 
20 
A. Right. 
21 
Q. Did you ever bother to review the 
22 
discovery produced in this case responding to 
23 
requests for all of the information that supported 
24 
their belief in the truthfulness of Virginia 
25 
Roberts' allegations against you? 
243 
1 
exonerated by any flight logs that were innocent —
2 
that were complete and accurate, of course. 
3 
Q. So you made the public statements 
4 
repeatedly that the flight logs would exonerate you 
5 
without having examined the flight logs to see 
6 
whether they were accurate or not; is that correct? 
7 
A. Well, I knew — I knew that —
8 
Q. Did you say those things without having 
9 
examined the flight logs? 
10 
A. I said those things having looked at some 
11 
of the flight logs al some point in time. But I 
12 
knew for sure that the flight logs would exonerate 
13 
me because 
new was 
v r on Jeffrey Epstein's 
14 
plane wit 
any other young 
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underage sir s. 
. 
-new 
at to an absolute 
16 
certainty. And I was prepared to say it. fm 
17 
prepared to say it again under oath here. 
18 
And if your clients had simply cal led me 
19 
and told me they were planning to do this, we 
20 
wouldn't be here today because I could have shown 
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them in one clay that it was impossible for me to 
22 
have had sex with their client on the island, in the 
23 
ranch, on the airplanes, in Palm Beach. And they 
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would have, if they were decent and ethical lawyers. 
25 
not filed that. 
242 
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A. I don't know if I reviewed everything. 
2 
But I certainly, in preparation for this deposition. 
3 
reviewed some of the documents that were produced in 
4 
discovery. But I can't say I reviewed them all. 
5 
Q. Well, having placed such substantial 
6 
emphasis during the course of your public 
7 
appearances on the flight logs exonerating you, it 
would certainly seem logical that one of the things 
9 
that you would want to review would be all of the 
10 
available — all of the available flight logs, 
11 
right? 
12 
A. No. 
13 
MR. SCOTT: Objection. argumentative. 
14 
A. No. 
15 
BY MR. SCAROLA: 
16 
Q. No? 
17 
A. No. Look, l knew I was never on a plane 
18 
with any underage females under any circumstances. 
19 
I knew that. I knew that as certainly as I'M 
20 
sitting here today. So, I knew absolutely that if 
21 
the manifests and the flight logs were actuate. 
22 
they would. of course, exonerate me because I am 
23 
totally, completely, unequivocally innocent of any 
24 
of these charges. 
25 
So of course l knew that l would be 
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244 
And there arc cases, legal ethics cases 
that say that lawyers arc obliged to make that phone 
call. lawyers are obliged to cheek if it's easy to 
check. lawyers are obliged to. particularly when 
the/re making extremely heinous charges against a 
fellow lawyer, do rely, very, detailed 
investigations. And they didn't do that in this 
case. 
Q. 1 will represent to you that I have handed 
you all of the available flight logs produced in the 
discovery of this case. Could you show me, please, 
which of these flight logs exonerates you? 
A. The absence of evidence is evidence of 
absence. None of the Ili t 
have me on an 
airplane wit 
None of the flight 
logs haven 
n the relevant 
period of time when 
iris that she 
had sex with me in the presence of another woman. 
So. the flight logs clearly exonerate me. 
There's absolutely no doubt about that. 
Q. Well, the flight logs, in fact, confirm 
that you were in the same places at the same time as 
~on•t 
they? 
A. No, they do not 
Q. Do you — do you deny that they confirm 
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245 
that you were in the same place at the same time — 
A. Firs 
Q. — a 
MR. 
• question. 
THE 
MR. SCOTT: Then you answer the question. 
And Mr. Search will by to. you know, keep the 
emotion down, rm sure, so we can get through 
this with less acrimony between everybody here 
A. Your client has adamantly refused, as well 
as the lawyer --
BY MR SCAROLA: 
Q. No, sir, that's nonresponsive to my 
question. 
MR. SCOTT: Wait a minute. 
BY MR. SCAROLA: 
Q. My question is: Do you deny that the 
flight logs corroborate 
place at the same time 
1111/Ill
A. So the question i 
and, therefore, I must answer in this way. Your 
client --
Q. How to build a watch? 
MR. SCOTT: Wait a minute, you're cutting 
him off. He's been trying to answer the 
247 
1 
ious to sec any tinrframes when 
2 
claims she was with me on the 
3 
is 
,cams 
was with mc on -- at the ranch, 
4 
claims she was with me on the airplanes, claims she 
5 
was with me in Palm Beach. And they will all 
6 
conclusively --
7 
Q. You forgot -
8 
A. 
9 
10 
also? 
11 
A. No, I did not mean New York --
12 
Q. Oh. okay. 
13 
A. -- because New York is ray different I 
14 
was, in fact, in New York for large periods of time. 
15 
I was not in fact. on the island during the 
16 
relevant timcframc. I was not in the airplane in 
17 
the relevant timeliame. I was not in Jeffrey 
18 
Epstein's Palm Beach home in the relevant timeframe. 
19 
And I was once in the ranch but under circumstances 
20 
where it would have been absolutely impossible for 
21 
me to have had any contact with her. 
22 
So if you will give me the timeframe, I 
23 
will be happy to answer your question. But without 
24 
timcframcs, that question is an absolutely 
25 
inappropriate question. And the answer to it is no. 
— New York. Didn't you mean New York 
246 
1 
question. 
2 
A. Yotr client has adamantly refused, an:liter 
3 
lawyers and your clients have refused to give me any 
4 
timcframes, any timcfratnes when your client claims 
5 
that she had improper -- falsely claims, 
6 
panniously claims that she had improper sexual 
7 
encounters with me. 
8 
So how can you possibly ask mc a question 
9 
that includes the w rd "tenet-Tames" when your client 
10 
has refused 
whe 
s refused to 
11 
give any time fram 
ossiblc that 
12 
the flight logs show me being in the same tint and 
13 
were place with her when she has refused to describe 
14 
any of the time
 that she claims to have been in 
15 
those places? 
16 
So the answer to the question is 
17 
categorically no, sir. 
18 
BY MR. SCAROLA: 
19 
Q. What Is the question that you are 
20 
answering no to? 
21 
A. Whether or not the tuneframe shows that I 
22 
could have been in the same place at the same lime 
23 
as your client. Absolutely not. Because we don't 
24 
know what times your client 
now, if you know 
25 
that, you should have produced them in discovery and 
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248 
Q. Well, Mr. Dershowltz, it might be 
inappropriate if you had not repeatedly made the 
public statements that the flight logs exonerate 
you. 
A. They do. 
Q. So what I am attempting to find out is the 
basis upon which you can contend that the flight 
logs exonerate you if you are now telling us you 
don't even know when it is that you are alleged to 
me place at the same time as 
Q. So how — how can you make both those 
statements? 
ausc I know the timeframe 
the 
, knew Jeffrey Epstein. And 
during that tinyframe. I can conclusively prove that 
I was never on Jeffrey Epstein's island where she 
claimed to have sex with nt. That the only time I 
was at the ranch was with my wife, with the Ask 
family, with my daughter, the house was under 
construction, we just simply stayed outside the 
house and looked around. That the manifests show I 
was never on Jeffrey Epstein's plane during that 
period of tin*. And the manifests show that I never 
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1 
flew down to Palm Beach during that relevant period 
1 
Q. Which of the manifests are you referring 
2
of time. 
2
to when you claim what you have claimed about the 
3 
So I have a timeframe not that was 
3
manifests, Exhibit Number 6 or Exhibit Number 7? 
4 
provided by your client but that was provided by the 
4 
A. I can only tell you that I have reviewed 
5
externalities of the case. And that timeframe 
5
the manifests and they show, to me, that I was never 
6 
coupled with the manifests clearly exonerate me 
6
on Jeffrey Epstein's airplane during the relevant 
7 
without any doubt 
7
period of lime. That's Al can tell you now. 
8 
Q. I want to make sure that I understood what 
8 
Pm not in a position where I look at all 
9 
you just said. "I never flew down to Palm Beach 
9
these documents now. If you point me to any 
10 
during the relevant timeframe"? 
10 
particular trip that shows that I was on Jeffrey 
11 
A. I never flew down and stayed at Jeffrey's 
11
Epricin's plane. I would be happy to respond to 
12 
house in Palm Beach during that relevant period of 
12 
that. 
13 
time. 
13 
Q. There are two separate collections of 
14 
Q. Okay. So you want to withdraw the 
14 
documents purporting to be flight manifests for 
15 
statement that you never flew down to Palm Beach — 
15 
Jeffrey Epstein's plane. When you made the public 
16 
MR. SCOTT: Objection. 
16
statements that you mode regarding the flight logs 
17 
BY MR. SCAROLA: 
17
or manifests exonerating you, were you referring to 
18 
Q. — during that relevant period of time — 
18
Exhibit Number 6 or Exhibit Number 7? 
19 
A. Lei me be -- 
19 
A. I have no recollection as to which 
20 
MR. SCOTT: Objection. 
20 
particular exhibits, which are formed for purposes 
21 
BY MR. SCAROLA: 
21 
of the legal case. I had reviewed. I know I had 
22 
Q. — and what you want to say is, "I never 
22 
reviewed the manifests. Not only had I reviewed the 
23 
flew down to Palm Beach and stayed at Jeffrey 
23
manifests, but others reviewed the manifests and 
24 
Epstein's house during that timeframe period," 
24 
have conclusively told me that their review of the 
25
correct? 
25 
manifests shows that I was right. 
250 
252 
1 
MR. SCOTT: Objection, argumentative-- 
1 
Q. Who else — 
2 
A. Let me be •• 
2 
MR. SCOTT: Avoid any attorney-client 
3 
MR. SCOTT: -- miseharacterization. 
3 
communications either with Ms. -- you know, 
4 
A. Let me be clear. A, I never flew down on 
4 
with your current lawyers, please. 
5 
Jeffrey Epstein's plane during the relevant period 
5 
THE WITNESS: Okay. 
6
of time. 
6 
BY MR. SCAROLA: 
7 
BY MR. SCAROLA: 
7 
Q. Who told you that they had reviewed the 
8 
Q. Flew down to where? 
8
manifests and they confirmed your position? 
9 
A. To Palm Beach or anywhere else. I was 
9 
MR. SCOTT: Objection, work product. 
10
never on Jeffrey Epstein's plane, according to the 
10 
MR. SCAROLA: Well, you know. Mr. Scott 
11 
flight manifests and according to my own records, 
11 
he can't have it both ways. He can't insert 
12 
during the relevant period of time. 
12 
into the record the gratuitous statemenu that 
13 
I have independent records of my travel 
13 
he inserts into the record regarding others 
14 
which demonstrate that I was not in Jeffrey 
14 
having corroborated his inaccurate testimony, 
15
Epstein's house during the relevant period of time. 
15 
and then refuse to tell us who those others 
16 
And -- but the — talking about the manifests, the 
16 
arc. It constitutes a waiver of whatever 
17
manifests conclusively prove that I was never on the 
17 
privilege might exist. 
18 
airplane during the relevant period of time. 
18 
MR. SCOTT: He can -- he can tell who they 
19 
So I don't know how 
19 
arc. I'm just saying he can't go into 
20
manifests show that I was wit 
20 
communications with them. 
21 
during the relevant period of t 
21 
MR. SCAROLA: Well, hes already said what 
22 
that. And if you would testify under oath to that, 
22 
the communication was. The communication was 
23 
I think you could be subject to pretty -• pretty 
23 
these manifests prove your position. 
24 
scathing cross examination. So your statement is 
24 
MR. SCOTT: And he's answered that because 
25
categorically false. sir. 
25 
based on his review of them, Mr. Searola. 
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1 
BY MR. SCAROLA: 
1 
MIL INDYKE: Objection. This is Darren. 
2 
Q. Who told you that the manifests confirm 
2 
Anything that relates to your conversations 
3
the accuracy of your public statements? 
3 
with Jeffrey — 
4 
MR. SCOTT: If it involves lawyer-client 
4 
THE REPORTER: He's going to have to speak 
5 
privilege, don1 answer it. 
5 
up. 
6 
THE WITNESS: Okay. 
6 
MR. SCOTT: You're going to have to speak 
7 
BY MR. SCAROLA: 
7 
up a little bit more. Counsel. 
8 
Q. You're refusing to answer? 
0 
MR. INDYKE: Objection. This is Darren 
9 
A. No, I would like— 
9 
Indyke. Anything that Alan might have to say 
10 
MR. SCOTT: Instruct you not to answer. 
10 
to that, to the extent they are covered under 
11 
A. -- to answer. But rye been instmcted 
11 
conversations with Jeffrey Epstein, privileged 
12
not to answer. I would like to answer. 
12 
under attomey.client privileges as well as 
13 
You've made a statement -- 
13 
common interest privileges. 
14 
MR. SCOTT: There's no question pending. 
14 
MR. SCOTT: Do you understand? 
15 
THE WITNESS: But he node a statement -- 
15 
THE WITNESS: I do. 
16 
MR. SCOTT: But there's no question 
16 
BY MR. SCAROLA: 
17 
pending, sir. 
17 
Q. To which your response was: "Sure, sure, 
18 
BY MR. SCAROLA: 
18 
certainly I have been his lawyer and I did speak to 
19 
Q. What does it mean to make something up out 
19 
him about It- I wanted to make sure that his memory 
20
of whole cloth? 
20 
and mine coordinated about when I was at his island. 
21 
A. It means that nr 
21 
He was able to check I was able to check. I 
22 
clients -- 
22 
checked with my friends who went with me." 
23 
' 
• 
I asked you anything 
23 
Did you make that answer to that question? 
24 
a 
I haven't asked you 
24 
A. Yes. 
25 
anything about my clients. 
25 
Q. Disclosing the contents of your 
254 
256 
1 
I want to know what the words "making 
1 
communication with Jeffrey Epstein, correct? 
2 
something up out of whole cloth" mean. 
2 
A. I disclosed that I had spoken to him to 
3 
A. I said those words in the context of 
3 
find out whether he had any records of when I was on 
4 
4 
his island. And, yes. 
56
Illat's 
-- that's finc. Go 
5
E: 
MR. 
INDYK 
Again, this is Darren Indyke. 
6 
Jeffrey does not waive any attorney-client 
7 
BY MR. SCAROLA: 
7 
privileges here. 
8 
Q. What do the words mean? 
8 
BY MR. SCAROLA: 
9 
s absolutely no basis for 
9 
Q. Well, the reason why you were able to 
10 
im that she had any sexual 
10 
answer that question and discuss with the mess what 
11
con 
wan cit. 
at the story was entirely false. 
11 
Jeffrey Epstein was telling you was because you 
12 
I don't know where the metaphor derives about whole 
12 
weren't his lawyer at that time, right? 
13 
cloth, but certainly that's the common 
13 
A. No. I was his lawyer at that time. I'm 
14 
understanding. And I repeat under oath that 
14 
still his lawyer. 
15 
de up the entire story about 
15 
Q. Oh, what were you representing him on 
16
having sex 
contact with Inc out of whole cloth. 
16 
then -
17 
Q. During the course of the same interview 
17 
A. The ongoing.-
18 
that we have been referencing with Hata Gorani — 
18 
Q. — that is, on January — 
19 
for the record, that's FI-A-L-A, G-O-R-A-N-I. 
19 
MR. SCOTT: Whoa. 
20 
A. What page? 
20 
BY MR. SCAROLA: 
21 
Q. Page 19. 
21 
Q. — on January 5,2015? 
22 
You were asked: "I'm wondering, have you 
22 
A. The ongoing--
23 
spoken to Jeffrey Epstein about this since these 
23 
MR. INDYKE My objection stands. 
24 
allegations came out in this suit in the United 
24 
MR. SCOTT: You can answer what you were 
25 
States? Have conversations happened there?" 
25 
representing him on. I think. 
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257 
259 
1 
A. The ongoing issues -- 
1 
Q. — the last 10 years? 
2 
MR. SCOTT: But nothing about 
2 
A. I would say 15 --
3 
ccovnunkrations. 
3 
Q. Last IS — 
a 
A. Right. The crigoing issues relating to the 
4 
A. -- years. 
5 
NPA, which continue to this day. And I regard 
5 
Q. — how about the last 20 years? 
6 
myself as his lawyer basically on all those — all 
6 
A. thaw -- I don't think so. 
7
those issues. 
7 
Q. Okay. 
8 
BY MR. SCAROI.A: 
8 
A. As I stand here today. I have no 
9 
Q. So, when the pleadings were filed in the 
9
recollection of ever being in New Mexico except to 
10 
Crime Vitt' 
• 
rding your conduct in 
10 
visit the Ashes in January of 2000.
11 
relationship t 
and Jeffrey 
11 
I'm 77 years old. I've lived a long life. 
12 
Epstein, you were an still are his lawyer in the 
12 
It is certainly possible that at some earlier point 
13 
Crime Victim's Rights Act case; is that correct? 
13 
in my life — I mean, I've been in most of the 
14 
A. I certainly am bound by lawyer-client 
14 
states. But I have no recollection of ever being in 
15 
privilege and communications, yes. 
15
New Mexico. 
16 
Q. Okay. You go on to say in that same 
16 
And I can tell you unequivocally the only 
1 7 
interview: "Only once in my life have I been in 
17
time I was ever at Jeffrey Epstein's ranch was that 
18 
that area," referring to New Mexico. 
18 
one time with my wife with the Ashes, with my 
19 
A. Yes. 
19
daughter. And we only stayed there for an hour and 
20 
Q. "Only once in my life did my travel 
20
the house was not completed. It was under 
21 
records show I was In New Mexico.' 
21 
construction. And I certainly did not have any 
22 
A. Uh•hula 
22 
sexual encounter or any encounter with Virginia 
23 
Q. Is that an accurate statement? 
23
Roberts during that visit. 
24 
A. To the best of my knowledge. I have no 
24 
MR. SCAROLA: Move to strike the 
25 
recollectionof being in New Mexico other than 
25
unresponsive portions of the answer. 
258 
260 
1
during that visit to the Ashes, which was not during 
1 
MR. SCOTT: We don't agree on that point, 
2
the •- the narrower timcframe. 
2 
so let's go ahead. 
3 
The narrower litnefraine, remember, is 
3 
MR. SCAROLA: It's of any help. I can 
4 
ts Jeffrey Epstein in the late 
4 
agree that you don't agree to any of my 
5 
summer. the summer just before she's turning 16, of 
5 
objections. 
6
1999. She says she didn't commence having sexual 
6 
MR. SCOTT: No. that's not true. I mean, 
7
activities with any of Epstein's friends until nine 
7 
I'm trying to work with you, sir. 
8
months later. That world put it in March or April 
8 
I have to tell you, this -- this is 
9
of 2000. This visit occurred in January of 2000. 
9 
obviously one of thc most acrimonious 
10
Ifs the only time I recall having been in 
10 
depositions I've sat through in my 40 plus 
11
New Mexico. 
11 
years because of the personalities involved 
12 
Q. Okay. I want to be sure now. You're not 
12 
here and because of the personal issues. And 
13 
Just saying that you were only at Jeffrey Epstein's 
13 
it's quite difficult for everybody in this 
14 
ranch In New Mexico once; you are confirming your 
14 
room. 
15 
statement on national television that you have only 
15 
MR. SCAROLA: I agree. 
16 
been in New Mexico one time? 
16 
MR. SCOTT: And all I'm saying, and my 
17 
A. My recollection right new is that I was 
17 
client is -- who's 77, is trying to defend his 
18
only there once. I have no — no other recollection 
18 
life. And I understand you're trying to 
19
of -- it's conceivable when I was a very young man, 
19 
vigorously •• and you're a great lawyer --
20 
I could have been there. But I have no recollection 
20 
represent your clients. And it's — this is 
21 
of having been there. It certainly —certainly I 
21 
not the typical deposition. And we're trying 
22 
haven't been there recently. And during the 
22 
our very best, both of us. 
23
relevant time period, I know I haven't been there 
23 
MR. SCAROLA: Thank you. And you're 
24 
Q. "Recently" means — 
24 
right, you and I do agree on something. 
25 
A. Fifteen •• 
25 
MR. SCOTT: As you said yesterday, more 
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1 
often than we usually say. 
2 
MR. SCAROLA: Yes. sir. 
3 
BY MR. SCAROLA: 
4 
Q. In interviews on January 4 and January 5, 
5 
you claim to have completed the necessary work to 
6 
Identify documents exonerating you within an hour 
7 
after learning of the accusations that were made, 
8 
correct? 
9 
A. I don't remember having said that. But 
10 
within a minute, I had clear knowledge that every 
11 
document in the world would exonerate Inc because I 
12 
knew fort absolute certainty that every aspect of her 
13 
allegation was totally false. That's why I 
14 
challenged the other side to produce videos, to 
15 
produce photographs. I knew that there could be no 
16 
evidence inculpating me because I knew I was 
17 
innocent. So I knew that all of my records would 
18 
prove that. 
19 
Facts arc facts. And I just wasn't in an 
20 
contact or any sexual contact wit 
21 
and I knew with absolute certainty that the facts 
22 
would completely exonerate me. And if your clients 
23 
had just called me, at the courtesy of simply 
24 
calling me, I would have been able to point them to 
25 
Professor Michael Potter of the Harvard Business 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
39 
20 
21 
22 
23 
24 
25 
263 
A. Where? Where? Can you point to that? 
BY MR. SCAROLA: 
Q. Well, I'm asking you, sir, based wain your 
superb memory whether you remember having said —
MR. SCOTT: No, were going to do —
BY MR. SCAROLA: 
Q. — on Jan — 
MR. SCOTT': lie's going to take a moment to 
review the transcript and 
and that's any 
witness is entitled to do that. So why don't 
we take a break, hen review transcript and 
well come back? We've been going an hour --
MR. SCAROLA: Because I haven't asked him 
a question about the transcript. 
MR. SCOTT: You've asked --
MR. SCAROLA: I'm asking him a question 
about his recollection. 
MR. SCOTT: Based upon what he said in the 
transcript 
MR. SCAROLA: No. fm asking him whether 
he has a recollection of having madc public 
statements that within an hour, he had gathered 
the documents that proved his innocence, 
exonerated him. 
262 
1 
School. I would have been able to to alert them 
2 
to the Ashes. I would have been able to tell them 
3 
that I keep little black books which have all of my 
4 
travel information. Although they were in the 
5 
basement of Martha's Vineyard, I would have been 
6 
happy to go up and get them. 
7 
If they had just simply called me, I would 
8 
have been able to persuade them without any doubt 
9 
that these allegations were false. If they needed 
10 
any persuading because I believe. as I sit here 
11 
today, that they knew they were false at the time --
12 
certainly should have known, but I believe knew they 
13 
were false at the time that they leveled them. 
14 
Q. My question related to your gathering 
15 
documents that you claim exonerated you --
16 
A. That's right. 
17 
Q. — and your public statements were that 
18 
within an hour, you —
19 
A. Can you 
20 
Q. — had gathered the documents —
21 
MR. SCOTT: Listen to the question. 
22 
BY MR. SCAROLA: 
23 
Q. --you had gathered the documents that 
24 
exonerated you, correct? 
25 
MR. SCOTT: You can refer. 
264 
1 
BY MR. SCAROLA: 
2 
Q. Do you remember having made those 
3 
statements? 
4 
A. I do not, but it's true. I was able to 
5 
gather documents literally within an hour. I was 
6 
able to call Tom Ask. lie was able to access his 
7 
daughter's journal notes that I had taught his 
8 
daughter's class. I was able to find out where my 
9 
other documents were. 
10 
My wife made some phone calls immediately. 
11 
We called the Canyon Ranch. We called and 
12 
determined the dates of when I was in Florida. We 
13 
called the Porters. We very. My, very quickly 
14 
were able to gather information that conclusively 
15 
would prove that she was lying about me having had 
16 
SG( with me on the island, in the ranch, 
17 
particularly those two I was able to prove 
18 
conclusively. 
19 
And when a woman lies deliberatelyand 
20 
willfully about two instances where she in great 
21 
detail claims she had had sex, I think you can be 
22 
clear that you should discount any other 
any 
23 
other false allegations. 
24 
MR. SCOTT: We've been going for an hour. 
25 
Let's take a break for a few minutes. Then we 
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265 
1 
have another hour. 
2 
MR. SCAROLA: I'm almost ready to take a 
3 
break. 
4 
MR. SCOTT: Okay. 
5 
MR. SCAROLA: Could you read back the last 
6 
question, please? 
First of all. I move to strike the 
8 
unresponsive speech. 
9 
And now read back the last question. if 
10 
you would. 
11 
(Requested portion read back as follows:) 
12 
THE REPORTER: "Do you remember having 
13 
made those statements?" 
14 
Do you want me to read prior to that? 
15 
MR. SCAROLA: No, that's fine. That's the 
16 
question that I asked. 
17 
BY MR. SCAROLA: 
18 
Q. Is I he answer yes? 
19 
A. I don't lung:tibia specifically. !do 
20 
generally remember having said that your clients 
21 
' 
" 
conclusive proof that 
22 
rag about Inc and that I 
23 
f come, it was false--
24 
MR. SCAROLA: Tom — 
25 
A. -- been able to uncover such proof. 
267 
1 
and then explained it but now you have it 
2 
directly answered. So were 
were at a 
3 
break point. 
4 
MR. SCAROLA: Thank you. 
5 
VIDEOGRAPHER: Going off the record. The 
6 
time is approximately 11:01 a.m. 
7 
(Recess was held from 11:01 a.m. until 11:23 a.m.) 
8 
VIDEOGRAPHER: Going back on the record 
9 
The time is approximately 11:23 a.m. 
10 
BY MR. SCAROLA: 
11 
Q. When did you last travel from outside the 
12 
State of Florida to arrive In Florida? 
13 
A. The day before yesterday. I think. 
14 
Q. And where did you travel from? 
15 
A. New York. 
16 
Q. When were you last in Boston, in the 
17 
Boston area? 
18 
A. About two weeks ago. 
19 
Q. So, if anyone had represented that you 
20 
were going to be traveling from Boston to Florida 
21 
this past weekend, that would have been a 
22 
misrepresentation; is that correct? 
23 
A. I have no idea what you're talking about. 
24 
Q. Well. I'm talking about your personal 
25 
travels. If anyone had represented that you were 
266 
1 
MR. SCAROLA: That has nothing to do with 
2 
the question I asked — 
3 
MR. SCOTT: Let's take — let's take a 
4 
break like I suggested and well come back and 
then you can ask your question and — okay? 
6 
MR SCAROLA: Well, while the question is 
7 
pending, I would like an answer to the question 
8 
before we break. 
9 
MR. SCOTT: Did you answer the question? 
10 
THE WITNESS: I thought I did 
11 
A. But what -- could you repeat the question? 
12 
try to answer it in a yes or no if l can. 
13 
BY MR. SCAROLA: 
14 
Q. Did you make the statement that within an 
15 
hour of learning of these allegations, you had 
16 
gathered documents that completely exonerated you? 
17 
A. I don't recall those specific words —
18 
Q. Thank you, sir. 
19 
A. -- but the bitch --
20 
MR. SCOTT: That's it, and I think he 
21 
indicated that before. 
22 
MR SCAROLA: That would be very helpful 
23 
if we said that and then WC stoppedand wc an 
24 
take a break. 
25 
MR. SCOTT: He previously had said that 
1 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
268 
going to travel from Boston to Florida and canceled 
travel arrangements from Boston to Florida this past 
weekend, that would have been a misrepresentation. 
correct? 
A. lhavc no idea what you're talking about. 
I'm retry. 
Q. Well, what Is it that you don't understand 
about that question? Either you were in —
A. The basis --
Q. — Boston and were planning on traveling 
from Boston to Florida this past weekend or the last 
time you were In Boston was two weeks ago, so you 
couldn't have been planning —
Q. — on traveling from Boston to Florida. 
A. I was actually in Boston -- now that 
checked my calendar, I was actually in Boston --
here. I have 
aha. It says — and my calendar 
says I was in Boston. Then it says leave for 
Florida, but that got changed. Yes, that got 
changed, right. 
Q. May I sec that, please? 
A. No, this is my personal calendar. 
Q. Yes, I'm sorry, but If you refer to 
anything to refresh your recollection — 
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A. I have — 
269 
1 
2 
Q. — dining thecoarse of the deposition, I 
2 
3 
am permitted to examine It. 
3 
4 
A. I have lawyer-client privileged 
4 
5 
information in hem. so I can't give it to you. I 
S 
6 
can give it to you in a redacted form. I have a 
7 
quote from David Bois in here, which I'm sure —
7 
a 
MR. SCOTT: Don't -
8 
9 
A. — nobody is going to want to sec —
9 
10 
MR. SCOTT: Well make a copy and give it 
10 
11 
to you. 
11 
12 
MR. SCAROLA Thank you. Would you hand 
12 
13 
it to your counsel, please? 
13 
19 
MR SCOTT: On that note. hold onto that. 
14 
15 
TIIE WITNESS: But I need that back. 
15 
16 
MR. SCOTT: Of course. Don't worry. 
16 
17 
MR. SIMPSON: Hold on to it. 
17 
18 
MR. SCOTT: That's why I saw it to him 
18 
19 
because I'd lose it. 
19 
20 
BY MR. SCAROLA: 
20 
21 
Q. Before January 21.2015, what Information 
21 
22 
dld you have regarding what Bradley Edwards and Paul 
22 
23 
Cassell had p 
Investigating 
23 
29 
the accuracy o 
lions 
24 
25 
against you? 
25 
270 
1 
A. Well. first, I knew that anything they 
1 
2 
gathered -• 
2 
3 
MR. IN DYKE: Objection to the extent that 
3 
4 
requires —
4 
5
MR. SCOTT: Whoa. 
5 
6 
MS. MCCAWLEY: 
you to disclose anything 
6
7 
you gave --
7 
8
THE COURT REPORTER: I can't hem. 
9 
I'm sorry, Mr. Indyke, can you repeat your 
9 
10 
objection? 
10 
11 
MR. SCOTT: Can you say that a little 
11 
12 
louder? 
12 
13 
MR. INDYKE: Darren Indyke. I would 
13
14 
object to the extent Mal your answer would 
14 
15 
disclose anything you -- you obtained or 
15 
16 
learned or any knowledge you gained in 
16 
17 
connection with your representation of Jeffrey 
17 
18 
Epstein. 
18 
19 
MR. SCOTT: Do you understand that 
19 
20 
inSIniction? 
20 
21 
THE WITNESS: I do, yes. 
21 
22 
Could you repeat the question? 
22 
23 
BY MR. SCAROL A: 
23
24 
Q. Yes, sir. I want to know what information 
24 
25 
you had regarding what Bradley Edwards and Paul 
25 
271 
Cassell had done in the course of their 
invest' 
' 
' 
y of the accusations 
made 
;dust you? 
A. Well, list and oremost, the most 
important piece of information I had was my Finn and 
complete knowledge and memory that I had never had 
any sexual contact with 
odor 
any circumstances or a 
. So I 
knew --
Q. The question I'm asking, sir — 
A. 
this infatuation — 
Q. — focuses on what knowledge you had 
regarding what Bradky Edwards and Paul Cassell did 
In the course of their investigation of the 
credibility of the accusations against you made by 
A. That was the first and most important bil 
of information namely, that I couldn't have done it 
and didn't do it. So I knew for sure that they 
could not have conducted any kind of valid 
investigation. 
Second. I knew from — that they also Ind 
a later from Mr. Scuola that said that multipk 
witnesses lad placed me in the preserec of Jeffrey 
Epstein and underage girls and I knew (hat 
272 
Mr. Scarola's letter was a patent lie. And they had 
access to that letter and that information. 
I also knew they were relying on 
depositions of two house people of Jeffrey Epstein. 
And I've read these two depositions. And I'm sure I 
knew of other -- other information as well. 
I knew that they had stated -- I knew that 
they had slated publicly, or you had stated publicly 
on their bchalf as a witness, that you had stated 
publicly that you had tried to depose me on these --
on this subject. I knew that that was a blatant lie 
and unethical conduct because nobody ever tried to 
depose me on this subject. 
I had never been accused, nor did I have 
any knowledge that anybody had ever falselyaccused 
me of having any sexual encounters. And I had a 
great deal of information about the paucity or 
absence of any legitimate investigation. And I also 
knew that they hadn't called nc. they hadn't tried 
to call me, there was no record of an attempt to 
call me or c-nuil Inc. My e-mail is available on my 
website. My phone number is available on my 
website. 
The most basic thing they could have done, 
as courts have said. what you're accusing somebody 
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1 
of outrageous, honible, inexcusable misconduct. at 
2 
least call the person and ask thcm if they can 
3 
dispose it before you file a -- a statement. Not 
4 
even asking for a hearing on it, not even basically 
5 
seeking to prove it. just --just putting it in a 
6 
pleading as if scrolling on a bathroom stall. 
7 
So, yes, I had -- I had a great basis for 
making that kind of statement and I repeat it here 
9 
today. And we will find out in depositions what 
10 
basis they actually had. And nn anxiously awaiting 
11 
Mr. Cassell's deposition this afternoon. 
12 
MR. SCAROLA: Move to strike the 
13 
non-responsive portion of that answer. 
14 
Could I have a standing objection to 
15 
unresponsive --
16 
MR. SCOTT: Sure. 
17 
MR. SCAROLA: — answers? That would be 
18 
helpful. Thank you. I appreciate that. That 
19 
will save us — 
20 
MR. SCOTT: Absolutely. No, anytime. 
21 
MR. SCAROLA: -- save us some time. 
22 
MR. SCOTT: Thank you, sir. 
23 
BY MR. SCAROLA: 
24 
Q. The one portion of what you just said that 
25 
directly responded to my question was you knew in 
275 
1 
your assertion that the testimony of these two 
2 
Individuals completely exculpates you. 
3 
A. Uh-huh. 
4 
Q. The following question was asked of — 
MR. SCOTT: What you arc reading from? 
6 
MR. SCAROLA: I'm reading from the 
7 
deposition transcript. 
BY MR. SCAROLA: 
9 
Q. The following question was asked of — 
10 
MR. SCOTT: The deposition transcript --
11 
BY MR. SCAROLA: 
12 
Q. —of Mr. Juan — Mr. Juan Akssl and — 
13 
MR. SCOTT: fat me object to the —first 
14 
of all, let inc object to this fonmi because he 
15 
has not been provided a part of the deposition. 
16 
You're reading portions from the deposition --
17 
MR. SCAROLA: Yes, I am. 
18 
MR. SCOTT: -- which can be taken out of 
19 
context. He has not had the ability to review 
20 
the deposition. This is inproper. 
21 
MR. SCAROLA: Okay. 
22 
MR. SCOTT: Cross-examination. 
23 
BY MR. SCAROLA: 
24 
Q. Do you recall the following questions 
25 
having been asked of Mr. Alessi and the following 
274 
1 
early January of 2015 that Bradley Edwards and Paul 
2 
Cassell had the sworn testimony of two - did you 
3 
refer to them as house-
4 
A. House people. 
5 
Q. House staff? 
6 
A. House staff 
7 
Q. House start of Jeffrey Epstein's --
8 
A. That's right. 
9 
Q. — correct? 
10 
And those two Individuals are Juan Alessi 
11 
and Alfredo Rodriguez, correct? 
12 
A. That's right. 
13 
Q. And you, in fact, were aware of the 
14 
existence of that testimony from shortly after the 
15 
time that the testimony was given, weren't you? 
16 
A. Well, I was certainly aware of it at the 
17 
time I made these statements. 
18 
Q. Yes, sir. But you also knew as far back 
19 
as 2009, when this sworn testimony was given, that 
20 
you were specifically Identified by name in the 
21 
sworn testimony of Jeffrey Epstein's house staff 
22 
members, right? 
23 
A. I was identified byname in a manner that 
24 
completely exculpated me, yes. 
25 
Q. Okay. Well, let's - let's takes look at 
276 
1 
answers have been given during the course of this 
2 
deposition Ns filch you contend completely exonerates 
3 
you? 
4 
"Question: Do 
• 
tion 
5 
of VR, referring t 
caning to 
6 
the house when Prince Andrew was there? 
7 
"Answer: It could have been, but I'm not 
B 
sure. 
9 
"Question: When Mr. Dershowitz was 
10 
ebbing — 
11 
"Answer: Uh-huh. 
12 
"Question: — how often did he come? 
13 
"Answer: lie came pretty 
pretty often. 
14 
I would say at least four or five times a year. 
15 
"Question: And how long would he stay 
16 
rypkally? 
17 
"Answer. Two to three days. 
18 
"Question: Did he have manages sometimes 
19 
when he was there? 
20 
"Answer: Yes. A massage was like a treat 
21 
for everybody. If they wanted, we call the 
22 
massage, and they get-- excuse me — and they 
23 
have a massage. 
24 
"Question: You said that you set up the 
25 
massage tables, and would you also set up the 
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277 
279 
1 
oils and towels? 
1
is a third-year student at Harvard, were anthem 
2 
"Answer: Yes, ma'am- 
2
with me. Thal was the only time that I stayed over 
3 
"Question: And did you ever have occasion 
3
more than one night. And I never stayed even one 
4 
to go upstairs and clean up after the massages? 
4 
night during the relevant timeframe. 
5 
"Answer: Yeah, uh-huh. 
5 
But most importantly, he gives no 
6 
"Question: Did you ever find any 
6
timcframc. And clearly his reference to the sex 
7 
vibrators In that area? 
7
toys is a reference to the part of the house that I 
8 
"Answer: Yes. I told him yes. 
8
was never permitted in and never entered. 
9 
"Question: Would you describe for me what 
9 
Q. What Is the question that you think you 
10 
Idnds of vibrators you found? 
10
were answering? 
11 
"Answer. I'm not too familiar with the 
11 
A. Whether --
12 
names, but they were like big dildos, what they 
12 
MR. SCOTT: He was explaining to you 
13 
call the big rubber things like that 
13 
exactly why he felt that that was 
14 
(indicating). And I used to go and put my 
14 
inappropriate, which is exactly what you asked 
15 
gloves on and pick them up, put them in the 
15 
him. 
16 
sink, rinse it off and put it in Ms. Maxwell — 
16 
MR. SCAROLA: No. it is not 
17 
Ms. :Maxwell had in her closet, she had like a 
17 
MR. SCOTT: Well, it is my recollection, 
16 
laundry basket. And you put laundry in. She 
18 
so I don't know --
19 
have full of those toys." 
19 
MR. SCAROLA: Well, then —
20 
Is that testimony that exonerates you, 
20 
MR. SCOTT: I think he was defending --
21 
Mr. Dershowite? Is that what you were referring to? 
21 
MR. SCAROLA: Let me try the same question 
22 
MR. SCOTT: Let me — objection to the 
22 
over again 
23 
form. improper cross examination by taking 
23 
MR. SCOTT: I think he was defending 
24 
excerpts out of depositions of witnesses. 
24 
his -- his position. 
25 
25 
THE WITNESS: Right. 
278 
280 
1 
BY MR. SCAROIA: 
1 
BY MR SCAROLA: 
2 
Q. Is it your contention that that testimony, 
2 
Q. The question was: Is that part of the 
3
under oath, of your friend. Mr. Epstein's staff 
3
time that you claim exonerates you? 
4 
person, exonerates yon? 
4 
A. Well, I think if you read the whole 
5 
A. First, a little background. Mr. Alessi 
5 
testimony. it clearly exonerates me and I think that 
6 
was fired for theft of material from Mr. Epstein, so 
6
pan of the testimony in no way inculpates me and no 
7
Mr. Alessi was not on a friendly basis with Jeffrey 
7
reasonable person reading that could use that as a 
8
Epstein. 
8
basis for making allegations that I had sexual 
9 
Second, the description of the dildos and 
9
encounters or misconduct with 
10 
sex toys clearly refer to the area of the house 
10
So. when -- if that's thebest test unary 
11 
that I was never in. the area of Ms. Maxwell's room. 
11
that your unprofessional clients relied on. then 
12 
rather than the area of the room that I stayed in 
12
clearly that exonerates me. 
13 
Third. he gives no timeframe for the 
13 
Again, the absence of evidence is evidence 
14 
visits. 
14 
of absence. And the very idea that this is seen as 
15 
And. fourth, he eathinly di '  
• 
15
some basis for condo 
16
way confirm that I was there toll 
16
encounters with •• wit 
why wasn't 
17
was there. His answer was simply la 
was ere 
17
he asked did he ever see me have a massage by 
18 
from time to time. I Ic's wrong about that. During 
18 
Did he ever sec me have a sexual 
19
the relevant timcframe. I was never in the house. 
19
encounter 
Did he ever go to 
20 
And even taking outside the relevant 
20 
the room I was staying in and find any sex tor? 
21 
timefratne, the only time I was in the house for more 
21 
The answers to all those questions, if 
22 
than one day was when my family, my wife, my son, my 
22 
truthful. would be no. 
23 
daughter-in-law, my then probably seven or 
23 
Q. What was Mr. Alessi's motive against you? 
24 
eight-year-old granddaughter, who just graduated 
24 
You've told us he was fired by Jeffrey Epstein. so 
25 
Harvard. and niy probably four-year-old grandson, who 
35
he may have had some motive against Mr. Epstein. 
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1 
What was his motive against you? 
2 
A. I was Jeffrey Epstcin's friend and lawyer 
3 
and, in fact -- well. 1 can't get into this. But I 
4 
can say this, l gave advice --
5 
MR. SCOTT: Be careful about anything 
6 
involving --
7 
THE WITNESS: Okay. 
8 
MR. SCOTT: -- Mr. Epstein. please. 
9 
A. He could easily have believed that I was 
10 
one of the causes of his firing. 
11 
BY MR. SCAROLA: 
12 
Q. So, he was -- he may have been angry al 
13 
you because you assisted in getting him fired? 
14 
A. It's --
15 
MR. SCOTT: Objection, 
16 
ntischaracterization. 
17 
A. It's conjecture. It's possible. But in 
18 
any event, even --
19 
BY MR. SCAROLA: 
20 
Q. It's conjecture, is that what you were 
21 
about to say? 
22 
A. I'm saying I have -- I don't know what he 
23 
was thinking, but there is a basis for him believing 
24 
that. But most -- most important, even if you take 
25 
everything he says as true, which it's not, it's 
283 
1 
A. Ycs. 
2 
Q. A man who would never undertake to advance 
3 
the cause of a client whom he believed to be 
4 
Incredible, right? 
5 
A. Yes. Andaman who told me and a man 
6 
who--
7 
MR. SCOTT: That's it. 
8 
A. Okay. And a man who believes I'm 
9 
innocent. 
10 
BY MR. SCAROLA: 
11 
Q. You know that Bob Josefsberg would never 
12 
file charges on behalf of a client alleging that she 
13 
was lent out by Jeffrey Epstein for purposes of 
14 
sexual abuse while she was a minor to academicians 
15 
unless he absolutely had confidence that those 
16 
statements were true - 
17 
MR. SCOTT, Let me object —
18 
BY MR. SCAROLA: 
19 
Q. -right? 
20 
MR. SCOTT: -- that this is completdy 
21 
irrelevant to the issues in this case. 
22 
Whatever Mr. Josefsberg thinks has nothing to 
23 
do with this lawsuit. This is all your effort 
24 
to try to put Josefsberg into this case to try 
25 
to give some justification to your position. 
1 
2 
a 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
282 
exculpatory because it has no 
' 
had any sexual encounter wit 
And if I were a lawyer 
MR. SCOTT: It's okay? 
A. — I certainly would not base this heinous 
accusation on that flimsy read. 
BY MR. SCAROLA: 
Q. You know the context in which that 
deposition was taken, don't you? 
A. I don't recall it as I'm sitting here 
today. 
Q. Do you remember that the lawsuit in which 
that deiwItion nos taken was a lawsuit in which 
being represented by Bob 
A. No. 
Q. You know Bob Josefsberg, don't you? 
A. We -- we were classmates at law school. 
Q. You know Bob Josefsberg to be an extremely 
ethical, highly professional and extraordinarily 
well-respected lawyer, right? 
A. Absolutely, yes. 
Q. Absolutely? 
A. Yeah. 
Q. A man of impeccable honesty and integrity? 
284 
1 
A. I'll answer that question. 
2 
BY MR. SCAROLA: 
3 
Q. Thank you. 
4 
A. And I also know Bob Josefsberg and know 
5 
that he would never nuintain a friendship, as he has 
6 
with me, if he believed that I was one of the. 
quote, academicians --
8 
Q. Welt, how about — 
9 
A. — with whom — 
10 
Q. — answering my question —
11 
MR. SCOTT: Wait a minute. No, no, no. 
12 
A. You're going to Id me finish. 
13 
BY MR. SCAROLA: 
14 
Q. I know I'm going to go, but I don't have 
15 
to like it — 
16 
MR. SCOTT: Yeah, but --
17 
BY MR. SCAROLA: 
18 
Q. — when you're not being responsive to the 
19 
questions that arc being asked. 
20 
MR. SCOTT: Yeah, but you're 
21 
interjecting — 
22 
BY MR. SCAROLA: 
23 
Q. And — 
24 
MR. SCOTT: You're interjecting questions 
25 
that arc irrelevant utilizing Bob Josefsberg's 
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1 
relationship with him and he has an ability to 
2 
justify and explain his position in response 
3 
MR. SCAROLA: If it's responsive to the 
4 
question. 
5 
A. It's responsive. And as far as the 
6 
filibustering is — 
7 
BY MR. SCAROLA: 
8 
Q. Do you remember what the question is? 
9 
A. -- is concerned, I was here --
10 
Q. Do you remember what the question was? 
11 
A. Yes. Yes. 
12 
Q. What is the question? 
13 
A. The question is — no, why don't you 
14 
repeat the question. 
15 
Q. Yes, sir. 
16 
A. So --
17 
Q. You know that Bob Josefsberg would not 
18 
advance allegations on behalf of a client that that 
19 
client had been lent out by Jeffrey Epstein to 
20 
satisfy the sexual desires of friends of Jeffrey 
21 
Epstein, including academicians, unless Bob 
22 
Josefsberg believed those allegations to be true, 
23 
right? 
24 
A. I believe that — I know that Bob 
25 
Josefsberg would never maintain a friendship with 
287 
the people who the FBI had put on the — the list. 
2 
I just don't know what his responsibility was. 
3 
I can say with confidence that he would 
4 
only ad ethically and would. A. not represent 
5 
not make any false statements the way your clients 
6 
made than, and that I wish your clients had the 
7 
ethics of Bob Josefsberg 
8 
Q. You then agree that if Bob Josefsbcrg 
9 
advanced the claims that I have described in a 
10 
complaint on behalf of a client, he would not have 
11 
done so unless he believed those allegations to be 
12 
true, having conducted a fair and reasonable 
13 
Investigation, correct? 
14 
MR. SCOTT: Objection, asked and answered 
15 
several limes. 
16 
A. I don't know the answer to that question 
17 
because I don't know the context in which he made 
18 
these arguments. All I do know is that he never 
19 
would maintain a friendship with me if he believed 
20 
in any way that I was cne of the people that she had 
21 
accused. 
22 
BY MR. SCAROLA: 
23 
Q. Did Alfredo Rodriguez, another one of your 
24 
friend's staff persons, have a motive to lie against 
25 
you? 
286 
1 
me, as he has, if he believed that 1 was one of 
2 
those academicians. Bob Josefsberg knows tint I was 
3 
not one of those academicians, and the inference of 
4 
your question is beneath contempt. sir. 
5 
Q. Could we try to answer the question now? 
6 
A. The answer is that Bob Josefsberg would 
7 
never maintain a friendship with me if he believed 
that there was any possibility that I was among the 
9 
academicians who she was accusing of sexual 
10 
misconduct. I do not believe that she ever accused 
11 
me of sexual misconduct to Bob Josefsberg. to the 
12 
FBI, to the U.S. attorney. or even, sir, to you and 
13 
Bradley Edwanls, as she says in 2000,1 think, 'I I. 
14 
1 think she made up this stay on the eve of the 
15 
filing in 2014. 
16 
Q. You do agree that Bob Josefsberg would not 
17 
have advanced the claims that he advanced if he did 
18 
not have confidence that they were true, correct? 
19 
A. I have no idea what he believed or knew at 
20 
the time. I would say this: I know Bob Josefsberg 
21 
is an extraordinarily ethical lawyer. I don't know 
22 
what his responsibilities were in the case. I don't 
23 
know whether his responsibilities were to make those 
24 
kinds of judgments or whether his responsibility was 
25 
simply to make sure that money was paid to each of 
288 
1 
A. Alberto Rodriguez --
2 
Q. No, sir, Alfredo Rodriguez. 
3 
A. Alfredo Rodriguez, I never knew him by 
4 
name. Ile was, of course, there out — well outside 
S 
of the limeframe of the alleged events in this case. 
6 
And so anything that he would be able to testify to 
7 
would bear no relationship whatsoever to the -- the 
8 
allegations here. 
9 
Ile was criminally prosecuted, to my 
10 
memory. for having stolen material and fumed it 
11 
over to Bradley Edwards is my recollection. And as 
12 
the result of that clearly had a motive to lie. And 
13 
the same with Mr. Alessi, clearly would have a basis 
14 
for believing that I may have played a role as 
15 
Jeffrey Epstein's lawyer in seeking to do harm to 
16 
him. 
17 
But again, there's nothing in 
18 
Mr. Rodriguez's testimony which is in any way 
19 
inculpatory of rue. I think he has me sitting and --
20 
and reading a book and drinking a glass of wine. 
21 
Q. In the presence of young women? 
22 
A. No. 
23 
Q. No? 
24 
A. I don't — 
25 
Q. Do you — 
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1 
A. 
believe that. 
2 
Q. — recall the following testimony — 
3 
A. It wouldn't be true if he said it. 
4 
Q. Yes. sir. Well, do you recall the 
following testimony having been given by Mr. Alfredo 
6 
Rodriguez In a deposition that was taken on 
7 
August 7,2009? 
"Question: Mr. Rodriguez, you staled last 
9 
lime that there were guests at the house, 
10 
frequent guests from Harvard. Do you remember 
11 
that testimony? 
12 
"Answer: Yes, ma'am. 
13 
"Question: Was there a lawyer from 
14 
Ilartiard named Alan Dershowitz? 
15 
"Answer: Yes, ma'am 
16 
"Question: And arc you familiar with the 
17 
fact that he's a famous author and famous 
18 
lawyer? 
19 
"Answer: Yes, ma'am. 
20 
"Question: How often during the six 
21 
months or so that you were there was 
22 
Mr. Dershowitz there? 
23 
"Answer: Two or three times. 
24 
"Question: And did you have any knowledge 
25 
of why he was visiting there? 
291 
1 
that testimony? 
2 
A. Yes. 
3 
MR. SCOTT: Objection. This is totally 
4 
improper cross examination of a witness by 
trying to use a deposition. The only purpose 
6 
of doing this is to interject this into the 
7 
record. which has no relevance and would not be 
admissible at trial. And in any ease, he never 
9 
actually has my client doing any of the thing, 
10 
that you've accused him of. 
11 
Go about, let's go ahead and do it. 
12 
Answer the question. Answer the question. 
13 
MR. SCAROLA: He did. 
14 
A. Yes, I iumura....r that. 
15 
MR. SCAROLA: He said yes. 
16 
A. Yes. I remember that. yes. 
17 
BY MR. SCAROLA: 
18 
Q. And do you know why it was that back in 
19 
19 - excuse me, back in 2009, August of 2009, four 
20 
and a half years before you allege that this story 
21 
about you was being made up out of whole cloth, that 
22 
lawyers representing Jeffrey Epstein's victims, 
23 
Including Katherine Ezell, E-Z-E-L-L from Bob 
24 
Josefsberg's office, who had filed the complaint 
25 
alleging that you had — excuse me, that Virginia 
290 
1 
"Answer: No, ma'am. 
2 
"Question: You don't know whether or not 
3 
he was a lawyer acting as a lawyer or whether 
4 
he was there as a friend? 
5 
"Answer: I believe as a friend. 
6 
"Question: Were there also young ladies 
7 
in the house at the time he w•as there? 
8 
"Answer: Yes, ma'am. 
9 
"Questio • 
• 
10 
for instance 
11 
"Answer: 
es, ma am. 
12 
"Question: Were there other young ladies 
13 
there when Mr. Dershowitz was there? 
14 
"Answer: Yes, ma'am. 
15 
"Question: Do you have any idea who those 
16 
young women were? 
17 
"Answer: No, ma'am. 
18 
"Question: Were there any of these — 
19 
excuse me. Were any of these young women that 
20 
you have said came to give massages? 
21 
"Answer: Yes, ma'am." 
22 
Do you recall that testimony having been 
23 
given --
24 
A. Yes. 
25 
Q. — and those answers having been given to 
292. 
1 
Roberts had been lent out for sexual purposes to 
2 
academicians, were asking specific questions about 
3 
you? Do you know why It was In 2009 they were doing 
4 
that? 
5 
A. I have no idea that it happened. And I 
6 
imagine that they had a list of every academic that 
7 
was in the house. Probably included .-
8 
MR. SCOTT: I want to object to this whole 
9 
procedure because you're taking pieces out of 
10 
the record and not reading other pieces that 
11 
totallyabsolve my client. For example, 
12 
there's testimony by him that says --
13 
MR. SCAROLA: Is this an objection? 
14 
MR. SCOTT: Yes, it's a statement into the 
15 
reeved just Eke you're putting into the 
16 
record. There's — I want to show this to my 
17 
client and refresh his memory as to some other 
18 
testimony by this witness --
19 
MR. SCAROLA: There's no question pending 
20 
as to what you can -- as to what you can 
21 
refresh your client's memory. What you arc 
22 
doing is coaching him. 
23 
MR. SCOTT: No, I'm not. 
24 
MR. SCAROLA: Improperly. 
25 
MR. SCOTT: And you are improperly reading 
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295 
1 
excerpts out of a deposition to try to imply 
1 
Do you remember that testimony having been 
2 
something when there's other parts that totally 
2 
given? 
3 
arc inconsistent with that. And if you're 
3 
A. I assume that when your clients used the 
4 
going to do that, then he has the ability under 
4
trartsdipt as a basis for their false conclusion 
5 
our rules to review the entire transcript of 
5
that I was guilty, they reed the whole transcripts. 
6 
the deposition and that's what fin permitting 
6
not just the --
7 
him to do, just like when were in court. 
7 
BY MR. SCAROLA: 
8 
MR. SCAROLA: What Ian doing. 
8 
Q. Every word. 
9 
Mr. Scott -- what I am doing, Mr. Scott -- 
9 
MR. SCOTT: Don't interrupt him. 
10 
MR. SCOTT: Have you read that now, sir? 
10 
BY MR. SCAROLA: 
11 
MR. SCAROLA: -- is reviewing the evidence 
11 
Q. You don't need to assume that. I will 
12 
that was relied upon by Bradley Edwards and by 
12
stipulate they read every word. 
13 
Paul Cassell in coming to the conclusion that 
13 
MR. SCOTT: Mr. Scarola, he's speaking. 
14 
the allegations that had been made by Virginia 
14 
You don't have a right to do this. 
15 
Roberts were, in fact, credible allegations. 
15 
A. And if you read every word, you will see 
16 
MR. SCOTT: And I'm -- 
16
that its totally exculpatory. that I have no idea 
17 
MR. SCAROLA: Because your own client has 
17
whether there were any young women in one part of 
18 
acknowledged that this is information that was 
18
the house when I was in another part of the house. 
19 
available to both him and to them back in 2009. 
19
It's completely consistent with my testimony that I 
20 
MR. SCOTT: And what I am doing is showing 
20
have never seen any underage women. Let's see. 
21 
him portions of the sank deposition that 
21 
And if you read the whole transcript. 
22 
totally take a different position from this 
22 
you'll see. I think: 
23 
witness from what you have read, so that this 
23 
"Was Dershowitz ever there when one of the 
24 
record is a complete record and not a partial 
24 
woman gave a massage? 
25 
record with your inference only. And I feel 
25 
"I don't notxria.: that. 
294 
296 
1 
that that's totally appropriate. If we were in 
1 
"Were you in — were you in any way 
2 
a counroom, a judge would permit him to do it. 
2 
attempting in your response to imply that 
3 
So you have your position and I have rt 
3 
Mr. Dershowitz had a massage by one of these 
4 
MR. SWEDF.R: Can we have the witness read 
4 
young ladies? 
5 
that? 
5 
"I don't know, sir. 
6 
BY MR. SCAROLA: 
6 
"You have no knowledge? 
7 
Q. Do you recall the following testimony 
7 
"No, sir. 
8 
having been given In that same deposition? 
8 
"And you certainly weren't implying that 
9 
"Question: All right. This is follow-up 
9 
that occurred: you just have no knowledge, 
10 
to questioning by Ms. Ezell. Ms. Ezell asked 
10 
correct? 
11 
you about Mr. Dershowitz being present in 
11 
"Answer: I don't know.' 
12 
Mr. Epstdn's home, and I think you said — I 
32
And I would hope that your clients would 
13 
think you said Mr. Epstein and he and 
13 
be reading the whole thing in context, unlike what 
14 
Mr. Dershowitz were friends? 
14 
you've tried to do to try to create a false 
15 
"Answer: Yes. 
15 
impression that this testimony in any way exculpates 
1.6 
"Question: She also, I think, asked was 
16 
inc.
17 
Mr. Dershowitz ever there when one of the young 
17
I have to say if this is what they relied 
18 
women who gave a massage was present in the 
18
on, my collimation of their unethical and 
19 
home. 
19
unprofessional conduct has been strongly 
20 
"Answer: I don't remember that. 
20 
corroborated by that and you're helping my case. 
21 
"Question: That's where I want to clear 
21 
BY MR. SCAROLA: 
22 
up. Is It your testimony that Mr. Dershowitz 
22 
Q. Would it have been reasonable for Bradley 
23 
was there when any of the women came to 
23 
Edwards and Paul Cassell to have relied upon the 
24 
Mr. Epstein's home to give a massage? 
24 
detailed reports of Palm Beach pollee department? 
25 
"Answer: Yes." 
25 
A. I don't know. I don't know what the Palm 
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1
Beach police depanment says. 
1 
this. 
2 
Q. You never read those reports? 
2 
A. Excuse me one second. 
3 
A. I don't know which reports you're 
3 
MR. SCOTT: You know, you think this is 
4
referring to. 
4 
funny and I think this man's --and I think 
5 
Q. All of the reports about Jeffrey Epstein. 
5 
this man's --
6 
MR. SCOTT: Asked and answered yesterday 
6 
MR. SCAROLA: I think it's inipmper for 
7 
co this whole lint 
7 
you to be coaching the witness in the middle of 
8 
A. I probably did not read all the reports on 
8 
examination. If you think that there's 
9
Jeffrey Epstein. rm sure I've read some of them. 
9 
something that needs to be brought out, you do 
10
I do not recall -- 
10 
that in cross examination. You don't feed hint 
11 
MR. SCOTT: Be careful about any work -- 
11 
information that you want him to be reading in 
12 
attorney-diem privilege. 
12 
the middle of my examination of this witness. 
13 
THE WITNESS: Right. 
13 
MR. SCOTT: No. But it's also true that 
14 
A. I don't remember my name coming up. I was 
14 
under our rules, when you read portions of a 
15
the lawyer during that period of time. 
15
deposition, he has the ability to read other 
16 
BY MR. SCAROLA: 
16 
portions of the deposition which clarify the 
17 
Q. To the extent that Bradley Edwards and 
17 
answers. That's done in every courtroom on 
18
Paul Cassell relied upon detailed reports fromthe 
18
every time a witness -- you have selected 
19
Palm Beach 
lice department in order to assess the 
19
portions of it that am not accurate based on
20 
credibility 
would It be 
20 
other portions and l am having him review them 
21
reasonable for them to rely upon police reports? 
21 
since you did not offer him the deposition to 
22 
A. I would hope that they would rely on all 
32
review. 
23
the police reports, including the ones that showed 
23 
MR. SCAROLA: And that's what you do -- 
24 
that she was involved in criminal actions, including 
24
MR. SCOTT: And I think that's totally 
25
the owes that would show that she took money as an 
25
Ricca --
298 
300 
1
adult to provide sexual services to people. 
1 
MR. SCAROLA: -- in cross examination. It 
2 
I would hope they would look at all the 
2 
is —
3
reports, not just selected portions of those 
3 
MR. SCOTT: --to do. No --
4 
reports. 
4 
MR. SCAROLA: -- improper. 
5 
Q. Would that include the reports of the 
5 
MR. SCOTT: No. 
6
Federal Bureau of Investigation? 
6 
MR. SCAROLA: There's no question pending 
7 
A. I would hope so. 
7 
as to which that's relevant. But Ids take a 
a 
Q. Would that include the information 
9
look at whit you're showing him. 
9
provided by the US. Attorney's Office? 
9 
MR. SCOTT: Sure. Why dolt you read it 
10 
A. I would sure hope so, and I could tell you 
10 
into the record? 
11
that the — 
11 
1TIE WITNESS: I've read it. 
12 
Q. Would that include — 
12 
MR. SCOTT: Read it into the record so 
13 
A. Let me just say that the U.S. Attorney's 
13 
that Mr. Scarola is advised. 
14 
Office has told me unequivocally that my name never 
14 
A. 'clay. When Alan Dershowith was in the. 
15 
came tip in any context of any accusation against me 
15 
house, I understand you to say that these local 
16 
during the negotiations. 
16 
Palm Beach girls would conic over to the house 
17 
Q. Is this part of your work product that 
17 
while he was there, but you're not sure if he 
18
you're waiving right now? 
18 
had a massage from any of these girls? 
19 
MR. SWEDER: No, no. 
19 
'Exactly. 
20 
A. My conversation with Jeffrey Simian is not 
20 
'And what would he do while these girls 
21 
work product. 
21 
were in the house? 
22 
MR. SCOTT: Here's a — 
22 
"Hc would read a book Mitt a glass of 
23 
BY MR. SCAROLA: 
23 
wine by the pool, stay inside. 
24 
Q. What Is the work product — 
24 
-Did he ever talk to any of the girls? 
25 
25 
1 don't know, sir. 
MR. SCUI I: Excuse me. Please review 
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301 
303 
1 
"Certainly he knew they were there? 
1 
A. Let me answer. 'Rely" connotes to me that 
2 
1 don't know, sir." 
2 
they would place a heavy emphasis on that to the 
3 
That's the best you can do? That's really 
3
exclusion of ocher things and that it would be 
4 
the best you can do? You think a professional 
4
enough. And so my answer is, yes, they certainly 
6 
lawyer would make these allegations based on "I 
5
should have read all the reports They certainly 
6
don't know. sir." 
6
should have read all the transcripts. But they also 
7 
MR. SCAROLA: Is there a question pending, 
7
should have called me, they should have made other 
8 
Mr. Scott? 
8
inquiry, and they should have made sure that they 
9 
MR. SCOTT: He's reading — you asked him 
9
read all of these depositions and reports in 
10 
what he was reading-- 
10 
context. 
11 
MR. SCAROLA: Yes, sir. 
11 
And ifyou're implying that there are FBI 
12 
MR. SCOTT: -- front and I had him publish 
12 
reports that in any way inculpate me, that's 
13 
it. 
13
I have from Former 
inconsistent with the information 
14 
MR. SCAROLA: Yeah, I brow, and then he 
14
Chief of Assistant Jeffrey Sloman, who was prepared 
15 
went on to make a speech. So I know I don't 
15
to file an affidavit saying that that wasn't the 
16 
have to do it. but I'm compelled to move to 
16 
case but was prevented front doing so by thc Justice 
17 
strike the unresponsive speeches. 
17
Department. 
18 
MR. SCOTT: And I consider these to be a 
18 
MR. SCOTT: It's about noon now. So I 
19 
response to the interrogation that you did 
19 
guess we're heading — we're wrapping this up! 
20 
taking excerpts improperly and not having the 
20 
MR. SCAROLA: Not quite yet. 
21 
entire record in front of him, which he's 
21 
BY MR. SCAROLA: 
22 
entitled to do to make that the record is 
22 
that the allegations that 
23 
complete. And I intend to protect him in that 
23 
ade against Prince Andrew were 
24 
way. 
24 
well-founded allegations, correct? 
25 
25 
A. I have absolutely no idea. fve met 
302 
304 
1 
BY MR. SCAROLA: 
1
Prince Andrew on a number of occasions in a public 
2 
Q. So we have agreed that it was reasonable 
2
context. He came and spoke in my class at Harvard 
3
for Bradley Edwards and Paul Cassell, in assessing 
3
law school. The dean then had a dinner in his -- or 
4 
the credibility o 
o rely upon 
4 
lunch in his honor. I was then invited to a dinner 
S 
poke reports, FBI reports, U.S. Attorney's Office 
5 
at the British Consulate. 
6 
information, and information from the Palm Beach 
6 
I've never seen him in the presence of any 
7
County State Attorney's Office, correct? 
7
underaged women, so I have absolutely no basis for 
8 
A. No. 
0 
reaching any conclusion whatsoever about 
9 
Q. No? 
9
Prince Andrew. 
10 
A. No. It would not be enough for than to do 
10 
Q. So you don't know one way or another 
11
that -- 
11 
whether those allegations arc true or false? 
12 
Q. I didn't ask you whether it was enough. 
12 
A. Neither do you. Nobody would know except 
13 
A. You said it was -- 
13 
two people. I imagine. But I daft know. Of course 
14 
Q. I asked you: Would It reasonable for them 
14 
not. 
15 
to rely upon those sources 
' 
' 
15
Q. All right. 
16 
17
assessing the credibility of 
A. No( alone, not wi 
16 
17 
A. But I presume -- 
Q. You say you have never seen him — 
18 
Q. That wasn't my question. 
18 
A. -- people innocent --
19 
A. -- other sources of information. 
19 
Q. — In the presence of any underaged women, 
20 
MR. SCOTT: Wait a minute. 
20 
but you've seen photographs of him in the presence 
21 
BY MR. SCAROLA: 
21 
of an underaged woman, correct? 
22 
Q. Well, what he's relying upon — 
22 
A. I have, yes. 
23 
MR. SCOTT: You're not the judge here. 
23 
MR. SCAROLA: May we mark this as the next 
24 
Let him -- ask a question and let him answer it 
24 
numbered exhibit, please. 
25 
and not cut him off, please. 
25 
A. And I want 10 note --
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305 
THE REPORTER: Hold on. Hold on. 
A. -- the absence of any --
MR. SCOTT: She can't take it down. 
THE WITNESS: Sony. 
(Thereupon. marked as Plaintiff 
Exhibit 8.) 
THE REPORTER: les okay. Go ahead. 
A. And I want to note the absence of any 
photograph of me wit 
BY MR. SCAROLA. 
Q. That's the photograph that you were 
referring to? 
A. rve seen this photograph in the 
newspapers. 
Q. Yes, sir. And the woman on the far tight 
of that photograph, who Is that? 
A. Ghislainc Maxwell. 
Q. The woman that you and your friend Jeffrey 
Epstein have traveled with repeatedly, correct? 
A. No. A woman who I may have traveled with 
on two or three occasions. I can't think of more 
times than that that I traveled with her, but it's 
possible But not -- I wouldn't say repeated 
occasions. I've --
Q. Well — 
3 07 
1 
THE WITNESS: Excusc me, I need to a take 
2 
a vay quick bathroom break. 
3 
MR. SCAROLA: That's fine. 
4 
THE WITNESS: Probably be two minutes or 
5 
less than two minutes. 
6 
VIDEOGRAPHER: Going off the record. The 
7 
time is approximately 12:03 p.m. 
(Sidebar held off the record.) 
9 
MR. SCAROLA: While were waiting. let me 
10 
mark the next numbered exhibits as well. That 
11 
will save us sane time. 
12 
MR. SCOTT: What is this? 
13 
MR. SCAROLA: Her calendar, his calendar. 
14 
MR. SCOTT: Who's calendar is this, 
15 
Carolyn's? 
16 
MR. SCAROLA: Okay. This is Number 10 
17 
MR. SCOTT: Carolyn's calendar. 
18 
(Thereupon, marked as Plaintiff 
19 
Exhibit 10.) 
20 
MR. SCAROLA: This is Number II. 
21 
(Thereupon, marked as Plaintiff 
22 
Exhibit I I.) 
23 
MR. SCAROLA: This is Number 12. 
24 
(Thereupon, marked as Plaintiff 
25 
Exhibit 12.) 
306 
1 
A. -- probably been in her presence fewer 
2 
than a dozen times. 
3 
Q. I'm going to hand you —
4 
A. But just to be clear, what I knew about 
5 
Ghislaine Maxwell was that she was the daughter or a 
6 
prominent British publisher --
7 
Q. I haven't asked you what you knew about 
8 
Ghislaine Maxwell. I asked you —
9 
A. Well, you asked --
10 
Q. - whether or not you recognized her in 
11 
the photograph? 
12 
A. Yes. Yes. 
13 
Q. Thank you very much, sir. 
14 
I'm going to hand you an airport codes log 
15 
that identifies the airports that arc identified by 
16 
abbreviations in the case — in case that is of some 
17 
assistance to you in answering the next series or 
18 
questions that I'm about to ask you. 
19 
A. Right. 
20 
Q. And I'm going to hand you this composite 
21 
exhibit, which we will mark as the next numbered 
22 
composite. 
23 
A. Uh-huh, right. 
24 
(Thereupon, marked as Plaintiff 
25 
Exhibit 9.) 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
30B 
1 
BY MR. SCAROLA: 
2 
Q. Mr. Dershowitz, I have handed you a 
3 
composite exhibit that is marked as Number 9. 
4 
A. Yes. 
S 
Q. The first document in that composite is a 
6 
page from —
7 
MR. SCOTT: flues Number9. 
8 
BY MR. SCAROLA: 
Q. — is a page from your wife's calendar; is 
that correct? 
A. Yes. 
MR. SCOTT: Take a moment to review the 
exhibit, please. 
A. Yes, it looks like -- I'm looking at the 
first page. It looks like my wiles -- my wife's 
handwriting, yes. 
BY MR. SCAROLA: 
Q. And the second page is another page from 
your wife's calendar; is that correct? 
A. Looks like it, yes. 
Q. And — 
MR. SCOTT: Take the time to review it 
before you answer questions, please. 
A. Right 
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3 1 1 
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BY MR. SCAROLA: 
1
December. 
2 
Q. And can you determine from the calendar 
2 
Q. One shows the subsequent two months and 
3 
entries here where your wife Is during the period of 
3
the —
4
time that's covered by these calendar entries? 
4 
A. Okay. 
5 
A. I would have to looks a panicular 
5 
Q. — other one shows --
6 
entry. If it describes where she is. yes. 
6 
A. Yes. 
7 
Q. Okay. Well, tell me where she is. 
7 
Q. — the preceding and following month, 
8 
A. What day? 
8
correct? 
9 
MR. SCOTT: Which one? What point? 
9 
A. Yes, that does look like it's December of 
10 
BY MR. SCAROLA: 
10
2000. yes. 
11 
Q. The period covered by this calendar 
11 
Q. Okay, sir. So look at the calendar and 
12 
between December 7 and December 13. 
12 
tell me where It appears your wife is during this 
13 
A. What year? 
13
period of time. 
14 
Q. You know what, I can't tell you what year 
14 
A. Thc whole period of time? 
15 
It is from these calendars. So you tell me. 
15 
MR. SCOTT: Please read the exhibit, all 
16 
1 suggest to you that this Is a calendar 
16 
the pages, thoroughly, so that you have a full 
17 
from December of 2000, since the next two months at 
17 
context. 
18
the top of the calendar are January 2001 and 
18 
A. it says. A.D. in Boston. That means I was 
19 
February 2001. So let's assume that since it is a 
19
in — in Boston. 
20 
page from a calendar that appears to be December of 
20 
It says Charleston, New York. It says 
21 
2000, that It's December of 2000. 
21 
book fair. It says book fair. It says A.D. in 
22 
That would be a reasonable conclusion, 
22 
Boston. 
23 
wouldn't It? 
23 
It then says the Halbrcichcs arrive. 
24 
A. I have no idea. 
24
They — they were probably our guests. 
25 
Q. You don't know? 
25 
310 
312 
1 
A. I don't know. I nimn,1 daft know -- you 
1 
BY MR. SCAROLA: 
2 
said you daft -- you can't tell what the year is, 
2 
Q. Your guests at home in Cambridge, 
3 
so .. 
3 
Massachusetts, ighe 
4 
Q. Well, I'm telling — 
4 
A. No, I don't know. I don't know. 
5 
A. — I cant tell what the year is. 
5 
Halbreicha arrive. 
6 
Q. — you that It appears to be December 2000 
6 
And Ican't really tell from here where 
3
because the next two months at the top of the 
7 
Carolyn S. McDonalds — lets sm. this is 2000 
8
calendar are January of 2001 and February of 2001. 
8 
and what year? 2001. 2000. Yeah, yeah. 
9 
A. I only sec -- I'm sorry. we're probably 
9 
So tell me what you're looking for. I'll 
10
looking at different things. I sec November 2000, 
10 
try to --
11 
December 2000. I don't see January or anything like 
11 
Q. I want to know where your wife was during 
12 
that. Maybe you can show than to inc. Oh. it's on 
12 
this period of time if you can tell from the 
13 
the first page. 
13 
calendar entries. 
14 
Q. First page, yes, sir. 
14 
A. Well, she may have been in -- there's 
15 
A. So it's in reverse order. 
15 
sancthing about Charleston. There's something about 
16 
Yeah, so the pages arc in reverse order. 
16 
New Yak. There's something about me being in 
17 
The lint page says on top January 2001, 
17 
Boston. I really can't ten much beyond that. 
18 
February 2001 and the second page says 
18 
Q. Okay. So you don't know one way or 
19
November 2000. December 2000. yeah. 
19 
another from these calendar entries where your wife 
20 
Q. So It appears we're looking at 
20 
was during this period of time; Is that correct? 
21 
December 2000, correct? 
21 
A. I can't tell that from this catty, no. 
22 
A. When we're looking at which page? When 
22 
Q. What we can tell from the entry in the 
23 
we-- 
23 
bottom right-hand corner — 
24 
Q. Both pages. 
24 
MR. SCOTT: Which page? 
25 
A. Well, one is Januaty/Fcbmaty and one is 
25 
A. Which page? 
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