Epstein Secrets

ollows: 20 DIRECT EXAMINATION 09:32:47 21 BY MR. SCAROLA: 09:32:54 22 Q. Would you please state your full name, 09:32:55 23 sir? 24 A. Alan Morton Dershowitz. 09:32:57 25 Q. And where did you live? 09:32:59 EFTA00601159 7 1 A. Well, I live in three places. We have a 09:33:00 2 home in Miami B

EOGRAPHER: This is the 15th day of 09:31:40 4 October, 2015. The time is approximately 9:31 5 a.m. This is the videotaped deposition of Alan 6 M. Dershowitz in the matter of Bradley J. 7 Edwards and Paul Cassell versus Alan M. 8 Dershowitz. This deposition is being held at 9 110 Southeast 6th Street

t privilege. 20 We've conferred on a number of occasions about the 21 ethical misconduct of your clients. 22 BY MR. SCAROLA: 10:10:43 23 Q. Rana Dershowitz? 10:10:43 24 A. Rana Dershowitz is my niece and Harvard 10:10:45 25 law school graduate, former chief counsel for the EFTA00601190 38 1 U

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 re

ho 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

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 to

priate. 9 A. Would you like to establish the foundation 11:25:46 10 for why it's not protected? 11 MR. SWEDER: Alan 11:25:50 12 MR. SCOTT: Alan, just let it alone. Let 11:25:51 13 it alone. 14 THE WITNESS: Okay. 11:25:53 15 BY MR. SCAROLA: 11:25:55 16 Q. This second conversation y

:12 EFTA00601158 6 1 behalf of the Defendant Professor Dershowitz. 2 MR. SIMPSON: Richard Simpson on behalf of 0

us from the Utah Attorney 09:31:58 21 General's office is Joni Jones. 22 MS. McCAWLEY: Sigrid McCawley. I'm with 09:32:06 23 the law firm of Boies Schiller & Flexner on 24 behalf of 25 MR. SCOTT: Good morning. Tom Scott on 09:32:12 EFTA00601158 6 1 behalf of the Defendant Professor Dershowitz. 2 MR. SIM

t for the record. I may want to mark two things. A. Okay. Q. Exhibit 1 is documented Plaintiff's Response to Motion for Limited Intervention by Alan M. Dershowitz, and I'm going to ask the reporter to mark another exhibit at the same time. This will be Exhibit 2, and this is a document entitled Jane Doe Numb

DRAFT ONLY EFTA00607220 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Sweeder & Ross for Professor Dershowitz. Thereupon, PAUL G. CASSELL, having been first duly sworn, was examined and testified as follows: THE WITNESS: I do. DIRECT EXAMINATION BY MR.

8 19 20 21 22 23 24 25 Sweeder & Ross for Professor Dershowitz. Thereupon, PAUL G. CASSELL, having been first

NAME: BRADLEY J. EDWARDS and PAUL G. CASSELL vs. ALAN M. DERSHOWITZ WITNESS NAME: PAUL G. CASSELL DAT

ds and Professor Paul Cassell . With me is Joni J. Jones from the Utah Attorney General's Office. MS. McCAWLEY: Sigrid McCawley on behalf of from Boies Schiller & Flexner. MR. SIMPSON: Richard Simpson on behalf of Defendant and Counter-Claim Plaintiff Alan Dershowitz. And with me is my colleague Nicole Richardson a

PAUL G. CASSELL, Plaintiffs/Counterclaim Defendants, vs. ALAN M. DERSHOWITZ, Defendant/Counterclaim Plaintiff. DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN M. DERSHOWITZ'S MOTION FOR LEAVE TO AMEND COUNTERCLAIM AND FOR LEAVE TO ASSERT CLAIM FOR PUNITIVE DAMAGES AGAINST PLAINTIFFS/COUNTERCLAIM DEFENDANTS EDWARDS AND C

LAIM FOR PUNITIVE DAMAGES AGAINST PLAINTIFFS/COUNTERCLAIM DEFENDANTS EDWARDS AND CASSELL Defendant and Counterclaim Plaintiff, Alan M. Dershowitz ("Dershowitz"), pursuant to Florida Rules of Civil Procedure 1.170(a), 1.170(e), 1.190(a) and 1.190(f) and Florida Statute § 768.72, hereby respectfully moves t

cooperate and give me those names. But I very much believe that there were going to be other girls who would come forward and swear under oath that Alan Ders ' bused them in exactly the same ■ as he had sexually abuse See Cassell Tr. Vol. I, at 36:20-37:1 and 60:5-10 (emphasis added). • When questio

SSELL, Plaintiffs/Counterclaim Defendants, vs. ALAN M. DERSHOWITZ, Defendant/Counterclaim Plaintiff.

sel for Plaintiff Cassell to: o: Joni J. S to: Bradley J. Edwards, Esq, Farmer, Jaffe et al, Paul G. Cassell, Esq.,; Sigrid S. McCawley, Esq., Boies Schiller & Flexner, LLP, this day of February, 2016. By: sffhomas E. Scott THOMAS E. SCOTT FBN: 149100 17 to: 0: EFTA00613407 EXHIBIT A EFTA00613408 IN T

edacted, with the 21 exception of Does 1 and 2, Professor Dershowitz, and in 22 deposition testimony already unseale

1 and 2 should 8 be unsealed. 9 Additionally, Alan Dershowitz's name and information 10 identifyin

eir names in this case's documents. Accordingly, 7 the names and identifying information for Does 1 and 2 should 8 be unsealed. 9 Additionally, Alan Dershowitz's name and information 10 identifying him may be unsealed. By his letter at docket entry 11 1138, he has requested that redactions of his name in t

specific comment, personal identifying 20 information for all nonparty Does should be redacted, with the 21 exception of Does 1 and 2, Professor Dershowitz, and in 22 deposition testimony already unsealed by the Court of Appeals. 23 The other names of Does and identifying information 2.1 will remai

ou are required to be present, but who is on for Ms. a please? MS. McCAWLEY: Good morning, your Honor. It is Sigrid McCawley from the law firm of Boies Schiller & Flexner on behalf of THE COURT: Good morning. Who is on for Ms. Maxwell, please? MS. MENNINGER: Good morning, your Honor, Laura Menninger on behalf of M

F |S ao FBP WN F- 970 DO DN ODO OT BR W NY — ROUGH DRAFT TITLE ***ROUGH DRAFT TRANSCRIPT *** CASE NAME: BRADLEY J. EDWARDS and PAUL G. CASSELL vs. ALAN M. DERSHOWITZ WITNESS NAME: PAUL G. CASSELL DATE OF DEPOSITION: 10/16/15 This is an unedited, unproofread, | uncertified transcript for attorneys' information o

Oo O DN OO FF WwW NY =| NO RO PO PNP NM NO | S| S| HS SF S| S| S| S| S| non BP WO NO -|- ODO OO WDN OO OT BP WO NYO — Sweeder & Ross for Professor Dershowitz. Thereupon, PAUL G. CASSELL, having been first duly sworn, was examined and testified as follows: THE WITNESS: I do. DIRECT EXAMINATION BY MR. SI

ODO OO WDN OO OT BP WO NYO — Sweeder & Ross for Professor Dershowitz. Thereupon, PAUL G. CASSELL, having been first

NAME: BRADLEY J. EDWARDS and PAUL G. CASSELL vs. ALAN M. DERSHOWITZ WITNESS NAME: PAUL G. CASSELL DAT

sor Paul Cassell. With me is Joni J. Jones from the Utah Attorney General's Office. MS. McCAWLEY: Sigrid McCawley on behalf of Virginia Roberts from Boies Schiller & Flexner. MR. SIMPSON: Richard Simpson on behalf of Defendant and Counter-Claim Plaintiff Alan Dershowitz. And with me is my colleague Nicole Richardson and

, 4:01 p.m. (Thereupon, a recess was taken.) THE VIDEOGRAPHER: We are back on the video record, 4:04 p.m. (Thereupon, Kenneth A. Sweder, Esquire, Alan M. Dershowitz and Carolyn Cohen left the proceedings.) ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 420 MR, SCAROLA: The record should reflect that Mr. and Mrs.

fy sealing these presumptively-public documents. L DERSHOWITZ HAS NOT JUSTIFIED SEALING ALLEGED DEFAMATORY RECO

e to speak up. MR. SCOTT: You're going to have to speak up a little bit more, Counsel. MR. INDYKE: Objection. This is Darren Indyke. Anything that Alan might have to say to that, to the extent they are covered under conversations with Jeffrey Epstein, privileged under attorney-client privileges as

UIRE DEPOSITION SOLUTIONS (954) 331-4400 mention Professor Dershowitz's name once. A. I said flight logs. And let's ta

tiality of Court Records Page 20 of 20 COUNSEL LIST Sigrid Stone McCawley, Esquire [email protected]; [email protected]; [email protected] Boies Schiller & Flexner, LLP 401 E Las Olas Boulevard., Suite 1200 Fort Lauderdale, FL 33301 Phone: (954)-356-0011 Attorneys for Alan M.Dershowitz, Esquire Thomas Emers

ENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, vs. ALAN M. DERSHOWITZ, Defendants. PLAINTIFFS' REOUEST FOR PRODUCTION TO DEFENDANT (PUNITIVE DAMAGES) BRADLEY J. EDWARDS and PAUL G. CASSELL, by and through their unde

r file, pencil jottings, diary entries, desk calendar entries, reported recollections and other written form of EFTA00602638 Edwards, Bradley vs. Dershowitz Plaintiffs, Edwards and Cassell, Request to Produce to Def. (Punitive Damages) Case No.: CACE 15-000072 Page 2 notation of events or intentions,

EDWARDS and PAUL G. CASSELL, Plaintiffs, vs. ALAN M. DERSHOWITZ, Defendants. PLAINTIFFS' REOUEST

) Case No.: CACE 15-000072 Page 13 COUNSEL LIST Sigrid Stone McCawley, Esquire [email protected]; [email protected]; [email protected] Boies Schiller & Flexner, LLP 401 E Las Olas Boulevard., Suite 1200 Fort Lauderdale, FL 33301 Phone: (954)-356-0011 Thomas Emerson Scott, Jr., Esquire Thomas.scott@cskle

ents related to communications with any members of Ghislaine Maxwell's family from 1970 — present. 9. All Documents related to communications with Alan Dershowitz from 1999 — present. 9 EFTA00606504 Jeffrey Epstein EXIJIBIT A 10. All Documents relating to, and all media depicting, any of the following

All Documents related to communications with Alan Dershowitz from 1999 — present. 9 EFTA00606504 Jeffrey

9. All Documents related to communications with Alan Dershowitz from 1999 — present. 9 EFTA00606504

es or other representative of Jeffrey Epstein. INSTRUCTIONS 1. Production of Documents and items requested herein shall be made at the offices of Boies Schiller & Flexner, LLP, 401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida 33301, no later than five (5) days before the date noticed for Your depositi

e, FL 33301, on Tuesday, February 2, 2016, at 9:30 or as soon thereafter as counsel may be heard, the following: DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN M. DERSHOWITZ'S MOTION IN LIMINE TO OVERRULE OBJECTIONS AS TO APPLICATION OF SETTLEMENT RULES Movant counsel certifies that A) I have made a good faith attempt to

L DIVISION CASE NO: CACE 15-000072 vs. ALAN M. DERSHOWITZ, Defendant/Counterclaim Plaintiff. NOTICE OF HE

s, CIVIL DIVISION CASE NO: CACE 15-000072 vs. ALAN M. DERSHOWITZ, Defendant/Counterclaim Plaintiff.

Esq, Farmer, Jaffe et al, 425 North Andrews Avenue, Suite 2, Ft. Lauderdale, FL 33301; to: Paul G. Cassell, Esq.,: to: Sigrid S. McCawley, Esq., Boies Schiller & Flexner, LLP, 401 E. Las Olas Blvd, Suite 1200, Ft. Lauderdale, FL 33301, this 8th day of January, 2016. By: sffhornas E. Scott Thomas E. Scott FBN: 1491

ent Right, sir. Q. Have you socialized with Alan Dershowitz? A. Yes, sir. He's my attorney, as well as a 832-

r de Roshi Mchiwn. Jerome Pierre (Gardner) M- F Alan Stopeck Landscape designer, Checks the garden Fra

like to answer that question, at least today I'm going to have to assert my Fifth, Sixth and 14th Amendment Right, sir. Q. Have you socialized with Alan Dershowitz? A. Yes, sir. He's my attorney, as well as a 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (40

XWELL, Defendant. ee re ee 7 x May 18, 2016 9:04 a.m. CONFIDENTIAL Deposition of Po pursuant 4 to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Not