562 1 Q. Hypothetically, if you had made those 2 statements, those statements would be false, 3 correct? 4 MR. SCOTT: Objection. Hypothetical -- 5 we're not even talking -- we have no knowledge 6 of who this woman is. 7 SPECIAL MASTER POZZUOLI: I'm going to 8 grant the objection. Move on. Rephrase the 9 question. 10 BY MR. EDWARDS: 11 12 13 14 15 16 17 18 19 Q. This is not my deposition. 20 A. I understand that, but you're giving a 21 hypothetical and I'm giving a hypothetical answer. 22 One would have to know whether or not the lawyers 23 who should have called me knew about the statement. 24 Q. In this hypothetical, suppose that we were 25 aware of every one of your public statements that www.phi sre orting.com EFTA00615683

563 1 you have ever made on this case of this subject 2 matter as well as related subject matter whatsoever 3 at the time. 4 A. You would find that I was a truth-telling 5 person who never has ever deliberately stated an 6 untruth in my professional life. 7 Q. We're going to get through this -- 8 SPECIAL MASTER POZZUOLI: Go ahead and ask 9 the question now based on that hypothetical you 10 just laid out. 11 BY MR. EDWARDS: 12 Q. If we hypothetically assumed that you had 13 made these statements, would these statements, given 14 your knowledge of the facts of this case, be false? 15 A. Let me see the statements again, please. 16 MR. INDYKE: Objection. To the extent the 17 knowledge of the facts of this case derive from 18 Mr. Dershowitz's representation of Mr. Epstein, 19 I don't think he can answer that question 20 without violating the privilege. 21 SPECIAL MASTER POZZUOLI: Hang on one 22 second. Did we hop over the hypothetical to 23 reality? 24 MR. INDYKE: I think we may have. 25 SPECIAL MASTER POZZUOLI: That's my www.phi sre orting.com EFTA00615684

564 1 question to you. 2 MR. EDWARDS: We're still operating in 3 hypothetical. 4 SPECIAL MASTER POZZUOLI: So now go back 5 and describe your hypothetical specifically so 6 he understand the question that you are asking. 7 A. Is this hypothetical still? 8 BY MR. EDWARDS: 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. I can understand it. What I would have 23 done as a responsible lawyer, what you should have 24 done, is you should have called me and asked me 25 about these statements, and I might have told you I www.phi sre orting.com EFTA00615685

565 1 said them, I might have told you I didn't say them, 2 I would have to have checked. 3 4 5 6 7 8 9 MR. INDYKE: Objection if you're talking 10 about actual facts. 11 SPECIAL MASTER POZZUOLI: He's answering a 12 hypothetical, so it's within -- move forward on 13 the hypothetical basis only. 14 15 16 17 It says that I said that he had passed a 18 lie detector test. I don't recall that. I don't 19 recall that he took a lie detector test. But if he 20 had taken a lie detector test and I was told he 21 passed it, that statement would be true. 22 If I had been told hypothetically that he 23 had paid for massages and had not engaged in 24 massages with underage minors, at that point in time 25 in 1907 [sic], that statement would be true. But as www.phi sre orting.com EFTA00615686

566 1 a lawyer, I wouldn't necessarily, A, take the word 2 of the Daily Mail without calling or, B, assume that 3 the statements quoted in the Daily Mail were false. 4 BY MR. EDWARDS: 5 Q. Would you agree it is a fair assumption or 6 a fair presumption that when you are making public 7 statements on behalf of the client, that you have at 8 least reviewed the available evidence that may exist 9 against that client? 10 A. That's too broad a question. It really 11 depends. I mean, I get called on day one of a case, 12 I don't know the evidence, and I'm called by the 13 press. I talk about my client being presumed 14 innocent, my client being innocent. That's part of 15 the role of a criminal defense lawyer. Justice 16 Blackmun has said that the criminal defense lawyer's 17 role does not end in a courtroom, it continues to 18 the courthouse steps. 19 And so when my client is being accused of 20 something, I have the right to -- 21 MR. SCAROLA: Excuse me one moment. Rick, 22 could you step outside with me. 23 A. to express my clients' views on the 24 matter. I'm speaking in a representative capacity. 25 www.phi sre orting.com EFTA00615687

1 BY MR. EDWARDS: 2 Q. Can we now remove ourselves from that 3 hypothetical and go to the allegations in this 4 Complaint, which include the various allegations 5 made in the statements at the beginning of this 6 deposition? 7 A. Which Complaint are we talking about? 8 9 10 11 BY MR. EDWARDS: 12 13 14 15 16 17 18 19 20 21 22 23 24 THE WITNESS: I don't think so, based on a 25 combination of factors, including material that www.phi sre orting.com EFTA00615688

568 1 I got in a lawyer-client and work product 2 fashion. 3 BY MR. EDWARDS: 4 Q. Okay. Let's take it a different III. One 5 of the things you said we should have done is just 6 called you. 7 A. That's right. 8 Q. If we had called you, isn't it more 9 likely, based on what we've seen today, that what we 10 would have had is just a bunch of objections and you 11 not being able to tell us anything? 12 A. Absolutely not. 13 MR. SCOTT: Objection -- 14 A. This requires a long answer because you've 15 asked me what you would have found out had you 16 called me. So let me tell you what you would have 17 found out. 18 MR. SCOTT: Do you want a long answer? 19 BY MR. EDWARDS: 20 Q. I don't want a long answer. I'm asking 21 wouldn't Jeffrey Epstein have had a say in what you 22 tell us, the same way that he has a say apparently 23 today in what you're telling us? 24 A. No. When it comes to me defending myself, 25 I will make the ultimate decision as to -- I'm an www.phi sre orting.com EFTA00615689

569 1 expert on lawyer-client privilege. I'm an expert on 2 work product. I'm an expert on the exceptions. I 3 can tell you exactly what I would have told you. 4 What I would have told you was that I have 5 documentation that could prove categorically that I 6 could not have been on Jeffrey Epstein's island 7 during the three-year period that is relevant. 8 I can prove categorically that I could not 9 have had sex or any contact with her at the ranch. 10 I can prove categorically that I couldn't have had 11 sexual contact with her on the airplane. I can 12 prove categorically that I couldn't have had sexual 13 contact with her in Palm Beach. And that I could 14 not prove categorically that at least I wasn't in 15 the same city with her in New York because I was in 16 New York for a long period of time. 17 I would have told you what that 18 documentation was. I would have asked you for an 19 opportunity to produce the documentation. I would 20 have provided you with other information. 21 No, I would not have raised any privilege. 22 I would have told you exactly what the evidence is, 23 and you would have believed me and you would have 24 not made these allegations if you're a responsible 25 lawyer. www.phi sre orting.com EFTA00615690

570 1 Q. Is this the documentation that you have 2 now produced in this litigation, the documentation 3 you're talking about? 4 A. Yes. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615691

571 1 anything is missing, I regret it much more than you 2 do because I am positive that they would provide 3 exculpatory information. 4 Q. The same way 5 A. I'm hoping that you can find it. Please 6 go ahead with my blessing. Please go find it. 7 MR. INDYKE: Objection. In connection 8 with Mr. Dershowitz's response, Mr. Epstein 9 waives no such objections that he's raised. 10 He's not waiving privilege. He's not waiving 11 work product. He's not waiving 12 attorney-client, common interest, joint 13 defense. 14 SPECIAL MASTER POZZUOLI: I've got it. 15 M•v f rw r 16 17 18 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615692

572 1 2 3 4 5 6 7 8 A. First of all, I did not rely on -- MR. INDYKE: To the extent that your response requires you to invade privilege, I would instruct you not to respond. 9 10 11 12 13 14 15 16 17 Q. Is this related to answering my question? 18 A. Yes, it is very directly. 19 SPECIAL MASTER POZZUOLI: What you're 20 looking at there is related? 21 A. Yes. Her statement -- here's what I would 22 look at. 23 MR. EDWARDS: Can we attach this to the 24 deposition that he's reviewing this? 25 SPECIAL MASTER POZZUOLI: Yeah, yeah. www.phi sre orting.com EFTA00615693

573 1 A. I am simply quoting from her affidavit. 2 SPECIAL MASTER POZZUOLI: Who "her"? 3 A. That's what I looked 4 at, her affidavit, which says that 5 SPECIAL MASTER POZZUOLI: Hang on one 6 second. Tom, before he quotes, let's 7 understand, I do think we need a copy of that 8 now. 9 THE WITNESS: It's in the affidavit. 10 SPECIAL MASTER POZZUOLI: But I do think 11 in fairness to these guys, I think that what 12 you're reading from, they need to have it. 13 A. I won't read from it. In her affidavit, 14 she states that she had sex with Presidents, plural, 15 of countries, a well-known prime minister of a 16 country, prominent American politicians, prominent 17 American businessmen, academics, and more. 18 And when I read that and read other 19 information about what she was reported to have 20 said, that's not from newspapers, that's from her 21 own affidavit. 22 BY MR. EDWARDS: 23 24 25 www.phi sre orting.com EFTA00615694

574 1 2 3 4 5 6 7 8 MR. SCOTT: You've been quoting from 9 newspapers all along, and now you have a 10 problem with a newspaper? 11 MR. EDWARDS: I don't have a problem with 12 a newspaper. 13 SPECIAL MASTER POZZUOLI: Wait a second. 14 Move on. You don't need to respond. 15 BY MR. EDWARDS: 16 17 18 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615695

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Q. But by throwing that last piece in there 18 that it's also on the basis of conversations you've 19 had with your client, it implies that those 20 conversations somehow justified those statements. 21 And if that's what you're sticking to, I want to 22 understand what it is that you learned from him that 23 could possibly justify those public statements in 24 2007. 25 MR. INDYKE: Same objection, same www.phi sre orting.com EFTA00615696

576 1 instruction. 2 A. What I'm saying is that lawyers, 3 particularly criminal defense lawyers, whether in 4 court or out of court -- I don't know whether these 5 statements were made in court of out of court -- are 6 entitled to assert the innocence of their clients. 7 That's what lawyers do all the time. I'm 8 sure you've done it. I'm sure Professor Cassell has 9 done it. I'm sure Mr. Scarola has done it. And 10 none of us ever want to be judged on our credibility 11 by pleading a client nonguilty or asserting a 12 client's innocence, and then it turns out perhaps 13 later that the client -- I'm not suggesting that 14 that happened here, but that the evidence 15 contradicts it. 16 First of all, we don't know what the 17 evidence is we're talking about here because we're 18 dealing with a timeframe that's very, very different 19 from the timeframe that ultimately was available 20 later on in the case. 21 BY MR. EDWARDS: 22 Q. Let me ask it to you this way, then: 23 First let me ask, is a Massachusetts rule of 24 professional conduct on truthfulness in statements, 25 are you familiar with that rule? www.phi sre orting.com EFTA00615697

577 1 A. Yes. 2 Q. And doesn't it indicate that in the course 3 of representing a client, a lawyer shall not 4 knowingly make a false statement of material fact or 5 law to a third person? 6 A. And I've never done anything that even 7 comes close to violating that rule. 8 Q. Okay. So let's take the statement, the 9 public statement that we are discussing from the 10 Daily Mail April 2007 article. 11 A. Right. 12 Q. The statement that the financier had paid 13 for massages, but had not engaged in sex or erotic 14 massages with any minors, do you, as you sit here 15 today, believe that statement to have been true at 16 the time that you made it? 17 A. Absolutely. 18 MR. INDYKE: Same objection, same 19 instruction. 20 BY MR. EDWARDS: 21 Q. The 87-page police report that has already 22 been marked to this deposition was generated in 2005 23 and 2006 prior to that statement that you made; is 24 that right? 25 A. I have no idea. Let me qualify my answer. www.phi sre orting.com EFTA00615698

578 1 I don't recall having used those words. I don't 2 recall an interview with the Daily Mail. My current 3 recollection is I did not have an interview with the 4 Daily Mail. 5 Had I had an interview with the Daily 6 Mail, it would have had to have been authorized by 7 my client. I don't think he would have authorized 8 such an interview, so I am now not acknowledging -- 9 I just don't know, but I am not acknowledging that I 10 actually said those words to the Daily Mail. You 11 are going to have to demonstrate that. I don't 12 remember speaking to Ms. Churchhill or whatever her 13 name is. It's possible, but I don't remember it. 14 Q. So if somebody is attributing those 15 statements to you, are you saying that they are 16 lying? 17 A. I don't remember having made those 18 statements. 19 MR. SCOTT: I would like to object to the 20 entire relevancy of this entire line because 21 this doesn't even establish which lady he's 22 talking about. That article doesn't even 23 establish anything about your client. 24 MR. EDWARDS: I hear your objection. But 25 the article actually says that Jeffrey Epstein www.phi sre orting.com EFTA00615699

579 1 was innocent of all allegations. So it's 2 apparently talking to at least -- 3 BY MR. EDWARDS: 4 Q. Wouldn't you agree it's reasonable to 5 presume that it's talking about all of the 6 allegations -- 7 A. Allegations against him that I recall at 8 the time that I was representing him involve two 9 women, two young women, is my recollection of the 10 allegations. And we were taking the position, and 11 we took the position with the State Attorney that he 12 was not guilty of those allegations. 13 There were many defenses that were being 14 raised, some dealing with credibility, some dealing 15 with -- 16 MR. INDYKE: Objection, objection. 17 A. -- whether or not some of the women showed 18 him IDs. 19 MR. INDYKE: You're getting into 20 attorney-client. 21 SPECIAL MASTER POZZUOLI: Go ahead ad make 22 your point. 23 MR. INDYKE: My point is that it sounds to 24 me that Alan is now discussing attorney-client 25 matters and internal decisions and strategies www.phi sre orting.com EFTA00615700

580 1 2 3 4 5 6 7 and statements that may not have been a matter of public record. SPECIAL MASTER POZZUOLI: I think you responded to the question. MR. INDYKE: And therefore they're subject to privilege, and we object and instruct him not -- 8 MR. SCOTT: Again, I'm going to object to 9 relevancy. It's been going on for hours. It 10 doesn't even involve his client. 11 SPECIAL MASTER POZZUOLI: I'm not going to 12 rule on the relevancy objection. This is 13 something that you can take up later at a 14 deposition. So move forward. He gets to take 15 his own deposition. 16 BY MR. EDWARDS: 17 Q. Do you remember that one of the alleged 18 victims that you were -- do you remember trying to 19 discredit one of the alleged victims named -- hold 20 on, this is difficult here. What I'm having trouble 21 with is what we are going to do with the identity of 22 underage sex abuse victims. I'm a little nervous to 23 say it on the record on a video. So can we just 24 take a two-minute break, five-minute break so that I 25 can figure out how we're going to work this out? www.phi sre orting.com EFTA00615701

581 1 SPECIAL MASTER POZZUOLI: We're on break. 2 VIDEOGRAPHER: Going off the record. The 3 time is approximately 3:23 p.m. 4 (Recess was held from 3:23 p.m. until 3:38 p.m.) 5 VIDEOGRAPHER: Going back on the record. 6 The time is approximately 3:38 p.m. 7 BY MR. EDWARDS: 8 Q. I'm going to give you the police report 9 that has been moved in as Exhibit 18, and I have 10 included a sticky note that we'll throw away. I'm 11 going to refer to her by the normal'. but I've 12 marked her real name so that you will know it, and 13 I'll ask if you remember her and things of that 14 nature. But here you go. 15 A. While I'm doing that, may I amend the 16 previous answer? 17 MR. INDYKE: If you're asking if he knows 18 her name, then I would object to -- on the same 19 basis I objected previously. 20 MR. SIMPSON: Why don't we discuss that on 21 the next break before you amend an answer. 22 SPECIAL MASTER POZZUOLI: Go ahead again. 23 I lost it. 24 MR. INDYKE: If you're asking whether or 25 not he knows this person I'll, if that's the www.phi sre orting.com EFTA00615702

582 1 question, I would object on the basis of work 2 product, attorney-client, common interests, and 3 instruct you not to answer to the extent it 4 invades any of those privileges. 5 A. What am I looking at here? 6 BY MR. EDWARDS: 7 Q. This is the Palm Beach Police Department 8 police report. 9 A. What do you want me to look at? 10 Q. Sure. It's page 40. 11 A. I have it, yes. 12 Q. We're going to go to the paragraph -- 13 second paragraph, "Detective and I met with 14 on October 11, 2005." 15 A. "Detective and I met with . and 16 her friend." 17 Q. I'm going to tell you that the person 18 under that redaction is 19 A. Okay. That doesn't mean anything to me. 20 Q. Is that somebody that -- whose name that 21 you -- 22 A. Oh, that person. 23 SPECIAL MASTER POZZUOLI: Go ahead and 24 make your objection. 25 MR. INDYKE: Same objection, same www.phi sre orting.com EFTA00615703

583 1 instruction. 2 SPECIAL MASTER POZZUOLI: Do you know this 3 person? 4 A. Only through my work with Jeffrey Epstein. 5 BY MR. EDWARDS: 0 7 8 9 10 11 12 13 14 15 16 Q. That you produced to the State Attorney's 17 Office? 18 A. I don't know how to use a computer, so I 19 couldn't pull down anything. But I was presented 20 with these within the lawyer-client representation. 21 And I don't know how much further to go. 22 Q. And didn't you take that information -- 23 MR. INDYKE: Instruct you not to answer. 24 BY MR. EDWARDS: 25 Q. Didn't you take that information, whatever www.phi sre orting.com EFTA00615704

584 1 information that you pulled from .'s MySpace page 2 to the State Attorney's Office to convince the State 3 Attorney's Office that this witness was not 4 credible? 5 SPECIAL MASTER POZZUOLI: Do you have an 6 objection, or no? 7 MR. INDYKE: No. 8 A. For 50 years, I've taught my students in 9 criminal law that their job is to present evidence 10 that would raise questions about the credibility of 11 a witness against their criminal defendant. And, of 12 course, every criminal lawyer does that. And I, 13 along with my co-defendants [sic), did the very same 14 thing in this case. 15 MR. SIMPSON: I believe you misspoke. You 16 said "co-defendants." Co-counsel? 17 MR. SCAROLA: Freudian slip. 18 BY MR. EDWARDS: 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615705

585 1 2 3 4 5 6 7 8 9 10 11 12 Q. After you made the statement that 13 Mr. Cassell and I had fabricated the allegations 14 against you and believed in the story of a 15 incredible, serial liar, and had failed to call you, 16 did you read our responsive pleading which I believe 17 was more than 150 pages long outlining some of our 18 investigation of the surrounding allegations? Just 19 did you read that response? I believe it was filed 20 January 21, 2015, in Judge Marra's courtroom. 21 A. I don't recall reading a 150-page 22 document. My lawyer Kendall Coffey would have read 23 it. It's possible I read it. But -- can you show 24 it to me? 25 Q. I don't have it here, but I assumed that www.phi sre orting.com EFTA00615706

586 1 you had read it. 2 A. I would be happy to look at it and see if 3 it's something I read. I know I'm familiar with 4 what -- some of the things you said you did, and 5 they didn't make me change my opinion at all. 6 Q. Did you read Detective 's 7 deposition that was taken in the civil cases against 8 Mr. Epstein? 9 MR. INDYKE: Objection. 10 SPECIAL MASTER POZZUOLI: There's no 11 grounds for an objection as to whether he read 12 a deposition. 13 MR. INDYKE: Well, there is when they 14 didn't place it within a timeframe. 15 SPECIAL MASTER POZZUOLI: Okay. 16 MR. INDYKE: Same objection, same 17 instruction. 18 BY MR. EDWARDS: 19 Q. In production we had produced many 20 depositions not only in this case, but have been 21 filed in other cases, which is why I asked you about 22 that January 21st pleading. 23 Is one of the documents that you have read 24 regarding our investigation of the allegations 25 Detective deposition? www.phi sre orting.com EFTA00615707

587 1 A. When -- when was Detective Recarey's 2 deposition? 3 Q. It was taken sometime in 2010. I don't 4 have the entire document. 5 A. I doubt that I read it. I wouldn't have 6 had any reason to read it back in 2010. 7 Q. If -- 8 MR. INDYKE: If are you talking about what 9 he did in 2010 rather than in response to 10 pleadings in this case, then I would object. 11 Same objection, same instruction. 12 BY MR. EDWARDS: 13 Q. I don't need to ask you if you've read the 14 deposition. If Detective has testified that 15 the State Attorney, very early on in the 16 investigation, was gung-ho up until the meeting with 17 Alan Dershowitz, would that be a true statement? 18 MR. SCOTT: Objection, form, totally 19 irrelevant to anything. 20 MR. INDYKE: Same objection, same 21 instruction. 22 A. I sure hope so. I mean, if I did a good 23 job in persuading a very distinguished State 24 Attorney about being less gung-ho about going after 25 my client, that's my job, that's what I get paid for www.phi sre orting.com EFTA00615708

588 1 as a criminal defense lawyer. So I'm proud to 2 have -- if it's true, have had him be less than 3 gung-ho. 4 I have tell you my negotiations with him 5 were very tough, very arm's length and very 6 difficult to the point where I was replaced at one 7 point for not getting a good enough deal. 8 BY MR. EDWARDS: 9 Q. If -- 10 MR. INDYKE: Objection. Alan, please do 11 not go into the substance of any kind of 12 interactions between you and any of on 13 Mr. Epstein's counsel in connection with your 14 representation. 15 BY MR. EDWARDS: 16 Q. At some point in time, were your services 17 terminated by Mr. Epstein? 18 A. I was replaced. 19 MR. INDYKE: Same objection, same 20 instruction. 21 BY MR. EDWARDS: 22 Q. At what point in time were you terminated? 23 MR. SCOTT: He didn't say that. 24 MR. INDYKE: Same objection, same 25 instruction. www.phi sre orting.com EFTA00615709

589 1 A. I wasn't terminated. A lawyer was added 2 to the team. And I think the record will show when 3 that happened, and negotiations continued with a new 4 lawyer who was seeking to get a better deal. 5 BY MR. EDWARDS: 6 Q. If Detective Detective l testified that the 7 point of your meeting with the State Attorney's 8 Office was to show that the character of the girls 9 was not to be believed, would that be a fair and 10 accurate description of that? 11 A. Well, the purpose of the meeting was 12 multiple. The purpose of the meeting, I remember we 13 brought forth every single -- 14 MR. INDYKE: Same objection, same 15 instruction, please. And, Professor Cassell, 16 I'm having some difficulty hearing you. 17 MR. SCOTT: He's having a hard time 18 hearing you. 19 MR. INDYKE: Yes. 20 A. The plain purpose of my meeting and the 21 work that did I together with my research assistant 22 was to gather all the cases in Palm Beach County and 23 maybe some other surrounding counties involving the 24 allegations, allegations similar to those against my 25 client, and to show that in none of the cases had www.phi sre orting.com EFTA00615710

590 1 prison time been given for the kinds of activities 2 that were alleged against my client. So, I 3 presented him with hundreds of -- 4 MR. INDYKE: I have to interrupt you. If 5 you are talking about what you did for 6 Mr. Epstein, which it sounds like you are, then 7 you are invading the attorney-client privilege 8 and work product. 9 A. I gave it to the prosecutor. 10 MR. INDYKE: I object, and I instruct you 11 not to answer. 12 BY MR. EDWARDS: 13 Q. My question is very narrow. 14 Do you remember attending a meeting with 15 Detective yourself and the State Attorney 16 wherein you made presentations using the website of 17 some of the victims, including 18 A. The three people that you mentioned were 19 not the only people at that meeting. 20 Q. I'm not insinuating that they are. Do you 21 remember those people being at the meeting? 22 A. I remember others as well, including 23 Mitchell Webber, who had done some of the research 24 for me on the case. 25 Q. I'm just asking do you remember this www.phi sre orting.com EFTA00615711

591 1 meeting? 2 A. I do, yes. 3 Q. If Detective says that the point 4 of your presentation was to attack the credibility 5 of the witnesses, is that accurate? 6 A. No. The point of my meeting 7 Q. I'm only asking for yes or no. 8 A. I have to do more than yes or no. 9 SPECIAL MASTER POZZUOLI: The initial 10 answer was? 11 A. No. And now explain. The point was to 12 get a reduction in sentence and to get the best 13 possible deal I could get for my client. That 14 included giving comparative sentencing data about 15 other cases and included raising questions about the 16 17 18 19 20 21 against my client, which is -- I've done that many, 22 many times, and so has every other criminal lawyer I 23 know. 24 BY MR. EDWARDS: 25 Q. And if Detective says it was Alan credibility of the witnesses and included showing documentation that some of the witnesses had provided false documentation about their age. It was a general presentation to a prosecutor to try to mitigate the allegations www.phi sre orting.com EFTA00615712

592 1 Dershowitz that was making the presentation on 2 Mr. Epstein's behalf to discredit the victims, that 3 would be a true statement in part? 4 A. Alan Dershowitz made a presentation in 5 general that included truthful statements about the 6 witnesses, the truth of which tended to discredit 7 some of their testimony, yes. 8 Q. If Detective IIIIIII was asked, in fact, 9 "Was he, Alan, trying to convey to the State 10 Attorney's Office that you should not believe these 11 girls that they were at his house at all because 12 they have credibility problems," and he answered, 13 "That was the impression I received, yes" 14 A. Totally false impression. 15 Q. This is something that Detective 16 if he said that, he's lying? 17 A. No, I didn't say he's lying. You're 18 putting words in my mouth. I said it's a false 19 impression. He didn't say it definitely happened. 20 He said that's the impression he had. 21 I didn't ever say that these people were 22 not at Jeffrey Epstein's house. That was not part 23 of my defense. I never said that to anybody about 24 any of the people involved in this case. The 25 defense was very different. And Mitch Webber, who www.phi sre orting.com EFTA00615713

593 1 was there, and probably the State Attorney will 2 confirm that. 3 Q. Okay. Going to the police report of 4 on page 40 it begins, is she one of the victims that 5 you tried to discredit during this meeting we're 6 discussing? 7 A. My recollection is that was one of 8 the accusers, and we had -- 9 MR. INDYKE: Objection. I'm sorry, I'm 10 trying to give you some leeway, but I object on 11 the same basis that I objected previously. And 12 I believe this was also treading settlement 13 negotiations on behalf of Mr. Epstein with the 14 police department. Again, this is -- so I 15 instruct you not to answer to the extent it 16 invades privilege. 17 THE WITNESS: So I just understand, are 18 you alleging a negotiation privilege, too? 19 MR. INDYKE: Yes. I don't want you 20 talking about -- 21 THE WITNESS: Clearly, it's covered by 22 negotiation, and it would take incredible -- 23 well, I'm not going to say it. This was 24 clearly a negotiation. Are they asserting a 25 negotiation privilege? I would like to hear www.phi sre orting.com EFTA00615714

594 1 that. 2 MR. INDYKE: Yes. 3 MR. SCAROLA: It's being asserted by 4 Mr. Epstein's counsel. 5 THE WITNESS: Are you challenging the 6 negotiation privilege? 7 MR. SCAROLA: We're asking the question. 8 MR. EDWARDS: Are we challenging it? 9 Absolutely. 10 THE WITNESS: Good. 11 MR. SIMPSON: Just wait for a question. 12 MR. EDWARDS: It's not getting us 13 anywhere. 14 MR. INDYKE: I would instruct you not to 15 answer that question to the extent it invades 16 that privilege. 17 THE WITNESS: I think we need a ruling on 18 negotiation privilege. 19 MR. SCAROLA: I don't think we get that 20 ruling in the context of this deposition. 21 THE WITNESS: Well, you're asking me a 22 question -- 23 MR. SCOTT: There's no question pending. 24 BY MR. EDWARDS: 25 Q. Do you remember . as being one of the www.phi sre orting.com EFTA00615715

595 1 victims that explained that she was also made to 2 have sexual relations with 3 A. No, I have no recollection. 4 MR. INDYKE: Same objection, same 5 instruction. 6 BY MR. EDWARDS: 7 Q. Do you remember ■ being one of the 8 victims sa in that Epstein bragged that he bought 9 from her family in to be 10 his sex slave? 11 MR. INDYKE: Same objection, same 12 instruction. 13 BY MR. EDWARDS: 14 Q. Do you remember -- do you know how it was 15 that obtained a visa in this 16 country? 17 A. No, absolutely not. 18 MR. INDYKE: Same objection, same 19 instruction. 20 BY MR. EDWARDS: 21 Q. Were you a part of the negotiation with 22 the U.S. Attorney's Office to protect against immigration charges? 24 A. I was not aware that there was any 25 negotiation relating to her. www.phi sre orting.com EFTA00615716

596 1 MR. INDYKE: Same objection, same 2 instruction. 3 BY MR. EDWARDS: 4 Q. Are you aware that told the police 5 that she had massagers, vibrators and strap-on 6 rubber penises used on her? 7 MR. INDYKE: Same objection, same 8 instruction. 9 MR. SCOTT: If that is privileged, then 10 don't answer it. 11 BY MR. EDWARDS: 12 Q. You're refusing to answer? 13 A. I'm not refusing to answer anything. I 14 have not refused to answer a single question today. 15 I'm instructed, I await the judge's ruling, and 16 whatever the judge says, I do. 17 SPECIAL MASTER POZZUOLI: There are now, I 18 count, four privilege issues that have been 19 raised separately. One deals with the 20 privilege issue directly and under the 21 representation of Mr. Epstein, the work product 22 issue that deals with the scope of the 23 representation of Mr. Epstein, the joint 24 defense agreement and common interest 25 privilege, and now as well as a negotiation www.phi sre orting.com EFTA00615717

597 1 privilege. 2 And for my purposes, in fairness to all 3 the parties, I do think that is something that 4 has to be subject to a set of facts on some of 5 them and fuller briefing of law, and that 6 requires -- I'm happy to hear it, but I think 7 it would be even in the purview of a separate 8 hearing from today, whether it's in front of me 9 or in front of directly Judge Lynch. 10 BY MR. EDWARDS: 11 Q. Do you remember III. saying that Epstein 12 turned her on her stomach on the massage bed and 13 began to pump his penis in her vagina? 14 MR. INDYKE: Same objection, same 15 instruction. 16 BY MR. EDWARDS: 17 Q. I'm going to read this into the record and 18 then we'll get the objection and then we'll -- 19 MR. INDYKE: I apologize. I'm not there, 20 so I'm not clear when you're finished. I just 21 want to make sure I make the objection before 22 Mr. Dershowitz responds. 23 BY MR. EDWARDS: 24 Q. then became upset over this. She 25 said her head was being held against the bed www.phi sre orting.com EFTA00615718

598 1 forcibly as he continued to pump inside her. She 2 screamed no, and Epstein stopped. She told him that 3 she did not want to have him inside of her. Epstein 4 apologized and subsequently paid her a thousand 5 dollars." 6 Does that refresh your recollection as to 7 8 MR. INDYKE: Same objection, same 9 instruction. 10 BY MR. EDWARDS: 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615719

599 1 BY MR. EDWARDS: 2 Q. Do you believe, then, that it was a 3 different victim that Jeffrey Epstein forcibly raped 4 and that had a long history of lying, theft and 5 blaming others for her crimes other than 6 MR. SCOTT: Object to the form. 7 MR. INDYKE: Same objection, same 8 instruction. 9 MR. SCOTT: Argumentative and relevancy. 10 This whole line. 11 A. I guess I have to answer? 12 SPECIAL MASTER POZZUOLI: No. 13 A. I just want to make one point in response, 14 though, and that is the quotes from the Mail, of the 15 three paragraphs, the first two are not in quotation 16 marks, they are not quoting me directly, they're not 17 in quotation marks, and I do not remember saying 18 those. 19 Only the third one is in quotation marks, 20 and only had a long record of lying, theft and 21 blaming others for her crimes, and I think that 22 comes from a court document. And I think if you 23 check, you would see that quotation comes from a 24 court document. So I have not been quoted by the 25 Daily Mail, and I do not think I ever spoke to www.phi sre orting.com EFTA00615720

600 1 Ms. Churchill. 2 BY MR. EDWARDS: 3 Q. You don't deny, though, that in reading 4 the Daily Mail article in your hand that the Daily 5 Mail has attributed each of those statements to you, 6 whether quoted or not? 7 MR. SCOTT: Objection, form, totally 8 improper examination. 9 BY MR. EDWARDS: 10 Q. You can answer. 11 SPECIAL MASTER POZZUOLI: You can answer. 12 A. Oh, sure. I have no memory of having had 13 an interview with the Daily Mail. They do attribute 14 statements to me, but not in quotes, and that's 15 always a red flag. When you see statements 16 attributed to somebody in the newspaper and there 17 are no quotes, any reasonable lawyer or reader would 18 question whether there, in fact, had been such a 19 conversation because if there had been such a 20 conversation, any good journalist would put it in 21 quotes. And many of the things article are in 22 quotes, but my statements are not in quotes other 23 than the last statement, which I think comes from a 24 legal document. 25 And at the time I made any statement about www.phi sre orting.com EFTA00615721

601 1 this -- about a woman with a long record of lying, I 2 don't think I was making it about somebody who 3 claimed to have been raped. I have no recollection 4 as I sit here now that anybody ever claimed to have 5 been raped by Jeffrey Epstein. I mean forcibly 6 raped in the way that you described it in that 7 document. That was not part of my negotiation with 8 the D.A. The D.A. never accused -- 9 MR. INDYKE: Objection. 10 BY MR. EDWARDS: 11 Q. But that document that I was reading from 12 is the public police report that is available to 13 everybody. You recognize that, right? 14 A. But the D.A. obviously didn't put much 15 credit in that because he never charged him with 16 that. So that was not one of the things that I was 17 dealing with. 18 What I was dealing with was two charges -- 19 MR. INDYKE: Objection. 20 A. -- of massages with underage sex. That 21 was what I was dealing with. That's what any 22 comments I may have made dealt with. There was 23 never an allegation of forcible rape made by any 24 responsible prosecutor in this case. 25 www.phi sre orting.com EFTA00615722

602 1 BY MR. EDWARDS: 2 Q. Isn't the comment, that's attributed to 3 you, doesn't it specifically say he, talking about 4 Alan Dershowitz, said that the girl who accused 5 Epstein of forcible sex had a long record of lying, 6 theft and blaming others for her crimes? That's -- 7 A. I categorically deny having said that in a 8 context of a statement about forcible sex. What the 9 Mail probably did is they juxtaposed their view 10 based on these articles that it was forcible sex and 11 assumed somehow that what I was saying related to 12 her. That's not what I said. That I remember quite 13 unequivocally. 14 Q. is particularly one of the victims -- 15 A. is not mentioned in this article. 16 Q. No, no, is one of the victims whose 17 MySpace page you used to give a presentation to the 18 State Attorney's Office about her credibility, isn't 19 it? 20 MR. SCOTT: Let me object. Argumentative. 21 We've been through this five times. 22 MR. INDYKE: Objection, same instruction. 23 SPECIAL MASTER POZZUOLI: How much further 24 do you have on this line of questions because I 25 will be -- www.phi sre orting.com EFTA00615723

603 1 MR. EDWARDS: I just want to get an 2 answer, that's it. I want to get answers. 3 SPECIAL MASTER POZZUOLI: But the point is 4 well made that the way this article is 5 constructed, it's meant to -- really the only 6 thing that's quoted here based upon this 7 article is "had a long record of lying, theft 8 and blaming others for her crimes." 9 The rest of it is not. And so you don't 10 know the source. Based upon what you've 11 already elicited from the witness, he doesn't 12 remember even talking to the Mail. And so I 13 don't want impact your line of questioning. 14 I've let you go on this. But how much further 15 do you have? 16 MR. EDWARDS: Okay, but I think I need to 17 put this in context, then, so that we kind of 18 understand what the point of this is. 19 This is a defamation action where we've 20 been accused of not performing any 21 investigation. So part of what we had to do is 22 what has she told us and what can we prove, and 23 what has he said in light of the evidence. 24 When we're weighing credibility, this is 25 one of the public statements that we have to www.phi sre orting.com EFTA00615724

604 1 weigh against the evidence. 2 SPECIAL MASTER POZZUOLI: And I've read 3 the pleadings, I've read the various arguments, 4 I've read the summary judgment that was filed, 5 and so I agree, that's why I've kind of let 6 this continue. But how much further? Because 7 I'm not so sure how much more information you 8 can get from him that you haven't gotten 9 already. 10 BY MR. EDWARDS: 11 Q. Are the three statements that are 12 attributed to you in the Daily Mail true or false? 13 MR. SCOTT: Asked and answered three 14 times. 15 MR. INDYKE: Same objection, same 16 instruction. 17 A. I have no knowledge, as I said today, as 18 to whether or not Jeffrey Epstein passed a lie 19 detector test. If I said it, and I don't recall 20 saying it, I assume it's true. I can check that. 21 So I assume statement one is true. Statement two, 22 "'The financier had paid for massages, but did not 23 engage in sex or erotic massages with any minors,' 24 the lawyer insisted," I have no recollection of 25 saying that. www.phi sre orting.com EFTA00615725

605 1 BY MR. EDWARDS: 2 Q. Can we start over and go back to the first 3 statement and finish that whole statement, and then 4 you tell me whether it's true or false? 5 A. Right. 6 Q. So the first statement is told the Mail -- 7 MR. INDYKE: If you are speaking about the 8 truth or falsity about these statements in any 9 manner to which I have I inserted my 10 objections, I would ask you not to answer the 11 question. 12 SPECIAL MASTER POZZUOLI: So in the 13 context of privilege that Mr. Epstein is 14 asserting, can you answer the question any 15 further than you have already? 16 THE WITNESS: Yes. I can. 17 SPECIAL MASTER POZZUOLI: Go ahead. 18 A. Our position was that he was innocent of 19 the allegations against him. They did not include 20 any allegations relating to forcible sex, they did 21 not include any of the things that you just read. 22 And our position was, and we stated it to 23 the State Attorney, that he was innocent of those 24 allegations, innocent of those statements. 25 I don't want to ever be held to statements www.phi sre orting.com EFTA00615726

606 1 that are not quoted, because particularly the Daily 2 Mail and other newspapers take tremendous liberties 3 with what you say. And therefore -- 4 BY MR. EDWARDS: 5 Q. I'm asking are they true or false? 6 A. Say it again. 7 Q. Are the statements true or false? 8 A. Statement one is passed the lie detector 9 test. 10 MR. INDYKE: Objection again. 11 A. I don't know the answer to that, but I 12 assume if I said it, it was true at the time. 13 Statement two, he was innocent of all the 14 allegations, that was the position that we took as 15 to the two women who had allegation against them. 16 the State Attorney obviously did not credit 17 .'s testimony because he never -- it would be 18 irresponsible for a State Attorney not to bring rape 19 charges against somebody who had done what you 20 allege from that police report had been done. 21 Obviously the State Attorney came to the conclusion 22 that there were real questions about her 23 credibility. 24 BY MR. EDWARDS: 25 Q. Is it true or false? www.phi sre orting.com EFTA00615727

607 1 A. The statements are true. 2 Q. All of them are true? 3 A. All of these statements, to the extent 4 that I made them, are true. 5 MR. INDYKE: Objection. 6 A. To the extent that I made these 7 statements, they are true, yes. And you should have 8 been on your guard when you saw that there were no 9 quotes, and you should have checked to see that the 10 one statement that was quoted probably appeared in a 11 legal document. And you should have checked with 12 Churchill to see if I ever spoke with her, because I 13 have absolutely no recollection of speaking with her 14 and I'm fairly confident I did not. 15 MR. EDWARDS: I move to strike the 16 unresponsive aspects of that answer beyond 17 whether they were true or false, which I 18 believe the witness has said the statements are 19 true. 20 A. That's not -- 21 MR. INDYKE: To the extent that the 22 witness was making that statement from 23 privileged information, I move to strike the 24 remainder of it. 25 SPECIAL MASTER POZZUOLI: To the extent www.phi sre orting.com EFTA00615728

608 1 that -- your motion on the privilege piece is 2 granted to the extent that that's what it's 3 based upon. 4 However, I would say to you that the 5 balance of the statement is in response to your 6 continued questions on it, so I'm going to 7 leave it be. You can be put in context in 8 argument with the Court. 9 MR. INDYKE: Okay. Thank you. 10 BY MR. EDWARDS: 11 Q. Did you write a letter or communicate to 12 the U.S. Attorney's Office that Mr. Epstein never 13 targeted minors? 14 A. I have no 15 MR. INDYKE: Same objection as to 16 settlement negotiations. 17 BY MR. EDWARDS: 18 Q. Is that a true statement that Mr. Epstein 19 never targeted minors? 20 SPECIAL MASTER POZZUOLI: Let me ask a 21 question about that. 22 Is there a copy of the letter? 23 MR. EDWARDS: Yes. 24 SPECIAL MASTER POZZUOLI: Is it in the 25 context of the negotiation between -- under the www.phi sre orting.com EFTA00615729

609 1 context of either Mr. Dershowitz or his team 2 representing Mr. Epstein with the State 3 Attorney's Office? 4 MR. EDWARDS: It is. And I will put on 5 the record something that everyone in this room 6 knows, which is that we have litigated in the 7 context of that case whether or not a privilege 8 extended between the defense attorneys for 9 Mr. Epstein and the government. 10 We had to battle both the government and 11 his defense attorneys on that all the way to 12 the 11th Circuit, and we have an 11th Circuit 13 opinion indicating that there is no such 14 privilege. 15 So to the extent it is being claimed, it 16 was already ruled there is no such privilege by 17 the 11th Circuit. 18 A. But -- 19 SPECIAL MASTER POZZUOLI: Hang on one 20 second. I'm at a disadvantage because you've 21 lived the case and this is my second day in the 22 case. So what who was party to the 11th 23 Circuit? Darren, were you involved with that, 24 or were you, Tom? 25 MR. SCOTT: No. www.phi sre orting.com EFTA00615730

610 1 MR. INDYKE: No, not directly. 2 MR. EDWARDS: Martin Weinberg and Roy 3 Black represented Jeffrey Epstein there. The 4 government, I believe, was represented by 5 in the argument. And we were the 6 other party. And we prevailed by written 7 opinion. I think that it -- 8 THE WITNESS: I'm personally delighted if 9 there is no negotiation privilege because the 10 negotiation privilege only has been invoked 11 against me -- 12 MR. SCAROLA: There's no question pending. 13 THE WITNESS: Sorry. Sorry. 14 MR. SCAROLA: We move to strike. 15 SPECIAL MASTER POZZUOLI: I would agree 16 with. Strike that last portion from the 17 witness. 18 If you can share the 11th Circuit opinion, 19 that would be appreciated. 20 MR. EDWARDS: Okay. 21 THE WITNESS: With us, too. 22 MR. SCOTT: I've never seen it. 23 MR. SIMPSON: I'm aware there is one. 24 MR. EDWARDS: Okay. Thank you, Rick. 25 MR. SCOTT: I've never seen or read the www.phi sre orting.com EFTA00615731

611 1 opinion, that's all I'm telling you. 2 BY MR. EDWARDS: 3 Q. Do you know Gerald Lefcourt? 4 A. I do. 5 Q. One of the cases -- when you were 6 outlining the five pieces of litigation, one of the 7 cases was the Crime Victim Rights Act that you 8 outlined? 9 A. I don't think I included that. That 10 brings it up to seven. Unless you're talking about 11 the case in front of Judge Marra. 12 Q. I'm going to show you what we'll mark as 13 the next consecutive exhibit, and I don't have a 14 clean copy, but it's okay. We can mark mine. 15 MR. SCOTT: Well, while we're doing that, 16 can we get the exhibits actually marked and 17 make sure we know which is which for the 18 record? 19 (Discussion off the record.) 20 (Thereupon, marked as Plaintiff 21 Exhibit 22.) 22 BY MR. EDWARDS: 23 Q. Can we go to page 13? Can we go to the 24 last page? And is that your signature? 25 A. No, it's not. www.phi sre orting.com EFTA00615732

612 1 Q. On the last page. 2 A. It is not. 3 Q. That's not your signature? 4 A. No. 5 Q. Who signed your name to this document? 6 A. I don't know, but I didn't sign it. It's 7 not my signature. It's not even close. 8 Q. Somebody forged your signature to this 9 document? 10 A. No, no, I don't know. It's not my 11 signature. You asked me the question is it my 12 signature. It is not my signature. You can check 13 it against hundreds of signatures. 14 Q. Did you have anything do with the 15 authoring of this letter? 16 A. My recollection -- I'd have to read the 17 letter -- is that I did some of the legal research. 18 My job was primarily to be the legal research 19 person. 20 MR. INDYKE: Objection. 21 BY MR. EDWARDS: 22 Q. I'm really just asking about this letter 23 and the authenticity of it. 24 A. I did not sign this letter. 25 Q. Did you authorize someone to sign your www.phi sre orting.com EFTA00615733

613 1 signature to this letter? 2 A. I have no recollection. But probably. I 3 can't imagine somebody sending a letter with my name 4 on it that wasn't somehow authorized. 5 Q. Is that something that you would do is 6 authorize somebody to sign your name to a letter? 7 A. I'm not responsible for who signed this 8 letter. I did not sign this letter. All I can tell 9 you is I know my signature, and nobody who knows my 10 signature would know this is not my signature. 11 Q. Okay. You do know Gerald Lefcourt? 12 A. Yeah. In fact, my name is even spelled 13 wrong, but it's okay. I know Gerald Lefcourt very 14 well, yeah. 15 Q. Was he authorized to sign your name to the 16 bottom of a letter? 17 A. I'm sure he must have been. I'm sure I 18 saw a draft of the letter at some point and said, 19 that's okay, or maybe he just assumed he can sign my 20 name because I had done the research, legal 21 research, the III you do of counsel, outside counsel 22 letters -- 23 MR. INDYKE: Objection. 24 A. but I don't have any distinct 25 recollection of this. www.phi sre orting.com EFTA00615734

614 1 BY MR. EDWARDS: 2 Q. You agree that the recipient of that 3 letter would believe that that was a letter authored 4 by you, given that it was purported to be your 5 signature at the bottom, wouldn't you agree? 6 A. A letter that I had some input to. No, 7 not necessarily. The first signature is Lefcourt. 8 I'm senior to him, older than him. Normally if I 9 wrote a letter, my name would come first. 10 Probably what should have been -- probably 11 it should have included my name as of counsel. 12 But -- but, again, I don't have any real 13 recollection of this letter. 14 Q. If we go to page 13, second paragraph -- 15 A. I don't see pages. 16 MR. SCOTT: Do you need time to review 17 this letter? 18 A. It's a long, long letter It would take 19 me over an hour to review it, probably take me an 20 hour to review it. There are no pages. Yours may 21 have pages; mine don't have pages. 22 BY MR. EDWARDS: 23 Q. In the top right, it starts "Jeffrey 24 Sloman," if you go down to that -- 25 A. Would you find it for me. www.phi sre orting.com EFTA00615735

615 1 2 3 4 5 6 7 Q. Sure. MR. SCOTT: Do you want to review the letter for few a minutes? Professor, do you want to review the letter for a few minutes? THE WITNESS: I see where it is. Let me first hear the question, and then I might want to review it. I think it's basically a legal 8 brief, if I recall correctly. Page 13. 9 BY MR. EDWARDS: 10 Q. Second paragraph. 11 A. I see it. 12 Q. Second sentence, "As we believe we 13 persuaded you at the June 26 meeting..." 14 Were you at the June 26 meeting? 15 A. I don't remember. I've been at several of 16 the meetings, but I can't give you a date. I can go 17 back in my calendars and see if I was at the June 26 18 meeting, 19 Q. 20 wouldn't 21 sentence 22 A. 23 Q. 24 A. 25 Q. but I don't have a current recollection. Given the two signatures at the bottom, a reasonable interpretation of that be "as we" Yes. -- "Alan and Gerald"? Yes. Comma, "Mr. Epstein never targeted www.phi sre orting.com EFTA00615736

616 1 minors." 2 Do you see that? 3 A. Yes. 4 Q. Is that a true statement? 5 A. That was the position -- 6 MR. INDYKE: Objection. Same objection on 7 any privilege, attorney-client, settlement 8 9 10 11 12 13 14 15 privilege. SPECIAL MASTER POZZUOLI: Can I see the document? MR. INDYKE: Object and instruct him not to answer. SPECIAL MASTER POZZUOLI: Hang on one second. THE WITNESS: Do you want to give it to me 16 overnight and we do it tomorrow? 17 MR. SCOTT: He needs to read the letter 18 MR. EDWARDS: To know whether that's a 19 truthful statement? 20 MR. SCOTT: He wants to read the letter 21 before he's examined on it. 22 MR. EDWARDS: He can read the statement 23 I'm going to ask him is that a truthful 24 statement. 25 MR. SCOTT: But he needs to read it in the www.phi sre orting.com EFTA00615737

617 1 1 context of the whole letter. That's what 2 you're entitled to do. He's entitled to read 3 the exhibits before he answers that. 4 MR. SCAROLA: We'll move on and we'll deal 5 with it tomorrow. He can read it overnight. 6 MR. SCOTT: You seem to be laughing at 7 things I say or smiling at them, and I 8 apologize if you do that, because I'm just 9 10 11 12 13 14 15 16 trying to protect my client -- MR. EDWARDS: I understand. MR. SCOTT: -- like you're trying to protect yours. And I wasn't laughing at you when we took Mr. Cassell's deposition. Seriously, I don't understand why you laughed several times. I don't get it. This is serious, and nobody is enjoying this. 17 SPECIAL MASTER POZZUOLI: Okay. 18 THE WITNESS: One laughs, one cries. 19 MR. EDWARDS: I think we're just waiting, 20 right? 21 MR. SCOTT: So he can make a copy 22 overnight and look at it. 23 SPECIAL MASTER POZZUOLI: That's fine. I 24 would suggest for purposes of tomorrow that a 25 copy of the letter be sent to counsel that's on www.phi sre orting.com EFTA00615738

618 1 the phone, too, so at least he can hear 2 argument around that letter rather than have 3 him be at a disadvantage. 4 MR. EDWARDS: It would have to be sent by 5 them. Jeffrey Epstein is not submitted to the 6 jurisdiction of the Court. 7 SPECIAL MASTER POZZUOLI: This is going to 8 be -- my guess is that it's going to be subject 9 to a full further inquiry, so let's just -- you 10 know, we'll skip to it. 11 MR. SCOTT: If I can have copies of the 12 exhibits ahead of time so we can look at them, 13 it would be helpful. We're going to be using 14 them to cross examine him. 15 MR. EDWARDS: I'm sorry, Tom. I will do 16 that. I was not prepared for the fact that 17 Mr. Dershowitz's signature's on the bottom of 18 something and he apparently didn't sign them. 19 I was blindsided, too. I thought this was a 20 letter he would be intimately familiar with 21 because I thought he had authored it. I didn't 22 realize somebody had signed his name to the 23 bottom of it. 24 And that's the cause of my laughter, 25 because I've personally never seen that before. www.phi sre orting.com EFTA00615739

619 9 10 BY 11 12 13 14 1 I've never seen that happen. 2 MR. SCOTT: I understand, but when you're 3 going to show -- I apologize, Mr. Pozzuoli, but 4 when you're going to show exhibits and ask 5 questions about them, you should anticipate 6 that the witness and his counsel would want to 7 see them. So you should have a copy of them. 8 I think that's basic good rules of a deposition. MR. EDWARDS: Q. Do you agree that in assessing your credibility on the subject matter of who was involved in the abuse of underage girls, that it would be fair and reasonable to assess the 15 statements that you made during and surrounding that 16 investigation against the available evidence? 17 MR. SCOTT: Objection -- 18 A. If that would be done, every criminal 19 defense lawyer in the country could be charged with 20 rape, with murder, with every other crime that he 21 defends his clients on the basis of. 22 I'm a criminal defense lawyer. I've been 23 teaching criminal defense law, I've been teaching 24 legal ethics in the context of criminal cases for 40 25 years. Lawyers are advocates. They assert www.phi sre orting.com EFTA00615740

620 1 positions given to them by clients. And the idea 2 that a lawyer asserts a position and, as a result of 3 that, is guilty of rape is the worst form of 4 McCarthyism imaginable. 5 Q. So your answer is you don't think it would 6 be fair to put your statements up against the 7 evidence when evaluating your credibility? 8 A. In the context that you've just stated, it 9 would be utterly unfair, in the context that you 10 have just stated, utterly unfair and unprofessional, 11 and you know better than that. If I were to judge 12 you by the same standards -- 13 SPECIAL MASTER POZZUOLI: Okay. 14 BY MR. EDWARDS: 15 Q. Because this case is about an initial 16 allegation of unprofessionalism, I want to 17 investigate that last statement. And let me make 18 sure that I got it correctly. It would be 19 unprofessional of me to assess or any lawyer to 20 assess your credibility by -- 21 MR. SCOTT: Listen to the question. 22 BY MR. EDWARDS: 23 Q. -- statements that you have made 24 surrounding this particular case against the 25 backdrop of the available evidence that would be www.phi sre orting.com EFTA00615741

621 1 unprofessional? 2 A. Not only would it be unprofessional, it 3 would involve you also to accuse Jerry Lefcourt, to 4 accuse Roy Black, to accuse Ken Starr. All of us 5 stood behind our client's defense, and we were 6 successful. We persuaded the United States 7 Attorney's Office, persuaded the State Attorney's 8 Office of our position. 9 And you're saying that our advocacy and 10 persuasion is evidence that I committed a crime of 11 rape. That that is so unprofessional, so goes 12 against what the legal system is all about. And 13 would basically make it impossible for anybody to 14 defend alleged criminals in any criminal context. 15 Yes. 16 Q. Can you find a public statement that was 17 made by Roy Black or any of Epstein's other lawyers 18 that says that Jeffrey Epstein was innocent of all 19 charges or never engaged in an erotic massage or sex 20 with minors? 21 A. Yes, I'm sure that those positions were 22 stated universally by all the lawyers in all the 23 contexts, if they were stated -- I mean those kinds 24 of statements. I'm not saying those statements in 25 specific, because I don't know who made those www.phi sre orting.com EFTA00615742

622 1 statements. 2 But defending a client against charges, 3 trying to minimize the charges, are made by all 4 lawyers, and were made by all the lawyers in this 5 case, and have been made by you in cases. I'm sure 6 if I go back, I will find them. 7 Q. Okay. 8 MR. EDWARDS: I have a document we'll mark 9 as -- what's the next consecutive exhibit? 10 COURT REPORTER: Number 23. 11 (Thereupon, marked as Plaintiff 12 Exhibit 23.) 13 SPECIAL MASTER POZZUOLI: Will you mark 14 that as 22 so we don't forget? 15 MR. SIMPSON: Yes. 16 BY MR. EDWARDS: 17 Q. Can you look at the document that we've 18 marked as number 23? 19 A. Yes. 20 Q. My only question is going to be, did you 21 go to that speaking engagement that was scheduled? 22 MR. INDYKE: I didn't hear the question. 23 This is Darren. 24 MR. EDWARDS: I've shown him a document, 25 and it is a public document about a scheduled www.phi sre orting.com EFTA00615743

623 1 speaking engagement for Mr. Dershowitz, and I'm 2 just asking him whether or not he gave that 3 speech. 4 A. I don't recall that I did. 5 MR. INDYKE: Thank you. 6 BY MR. EDWARDS: 7 Q. Do you recall it being canceled or you not 8 going? 9 A. I don't recall me doing that speech. 10 Q. Okay. Do you remember it being scheduled? 11 A. I remember -- I don't remember 12 specifically, but I remember some general statement 13 that I had some speeches scheduled, yeah. 14 MR. EDWARDS: Do we have an extra copy of 15 the Daily Mail article? I thought we -- 16 VIDEOGRAPHER: Going off the record. The 17 time is approximately 4:26 p.m. 18 (Recess was held from 4:26 p.m. until 4:29 p.m.) 19 VIDEOGRAPHER: Going back on the record. 20 The time is approximately 4:29 p.m. 21 BY MR. EDWARDS: 22 Q. Are you aware from any nonprivileged 23 document or information that Jeffrey Epstein 24 referred to sex with underage girls as massages, 25 that that was a code word? www.phi sre orting.com EFTA00615744

624 1 A. No. 2 Q. In reviewing the message pads that were 3 taken from his home and the public police report, 4 have you been able to learn that fact? 5 A. I think it's false. I think it's a false 6 fact. When I was offered a massage at Jeffrey 7 Epstein's house, I received a legitimate massage by 8 a professional masseuse who hurt me. And I called 9 my wife and told her about it. I didn't enjoy it. 10 And I've been told by numerous people that they have 11 gotten ordinary massages, so I don't believe it was 12 a code word. I think that's false. 13 Q. Who told that you that they got ordinary 14 massages at Jeffrey Epstein's house? 15 A. People who were guests at the house. 16 Q. Exactly. 17 MR. INDYKE: I'm sorry? 18 A. My wife -- 19 MR. INDYKE: Can you repeat the question, 20 please. 21 MR. EDWARDS: Yes, I was just asked for 22 the identity of the people who have told 23 Mr. Dershowitz that they have received 24 legitimate massages at Jeffrey Epstein's home. 25 MR. INDYKE: I object to that question and www.phi sre orting.com EFTA00615745

625 1 2 3 4 5 6 7 the response to the extent it would invade privileges that we've already discussed, and instruct Alan not to answer. SPECIAL MASTER POZZUOLI: I think you can answer it outside the privilege. A. Virtually everybody that -- when I was at Jeffrey Epstein's house in Palm Beach, not in 8 New York -- I never heard the word "massage" used in 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 New York, but in Palm Beach, he would offer -- you would get an offer of massage, and people would accept it or not. But I never heard massage being anything other than an ordinary therapeutic massage. And I think it's insulting to professional massage therapists to assume that every massage -- I mean, it was like -- BY MR. EDWARDS: Q. Maybe I communicated my question poorly. I was actually asking for the names of the people who told you -- A. I told you my wife, my daughter, myself. I'll try to think of other names, but I remember people telling me Jeffrey Epstein's Q. Anybody that they had received massages at house. outside of your immediate family? A. Yes, but I'm having trouble remembering www.phi sre orting.com EFTA00615746

626 1 specifically who they were. 2 Q. Okay. 3 MR. INDYKE: Outside of subject to not 4 privilege, you're saying? 5 A. Right, yeah. 6 BY MR. EDWARDS: 7 Q. Do you remember speaking with the Daily 8 Mail on or around January 21, 2015, and saying -- 9 Dershowitz said the statements are all lies and "I 10 never got a massage from anybody, it's made up out 11 of whole cloth"? 12 A. No, I never said. 13 Q. If I showed you the statement, would it 14 help refresh your recollection? 15 A. No, because it's false. I never said that 16 I never got a massage because I said immediately 17 from day one that I got one massage. I said that 18 immediately. I described the massage. I might have 19 been asked did I get a massage from . The answer would be no. Did I get massage 21 during the relevant period of time? The answer 22 would be no. 23 But I never stated, and I would challenge 24 you to come up with -- no, with a tape recording of 25 me saying that in full context because that's not www.phi sre orting.com EFTA00615747

627 1 what I said. I've always said that I received one 2 massage. 3 4 5 6 7 Q. What does the quote say? 8 A. And, in fact, I said specifically that I 9 kept my underpants on. I was very specific about 10 the massage that it was -- I think it was a woman 11 from a Russian background. I was very clear. So to 12 say that I said that I never got a massage is just 13 false. From day one, I said I got a massage. 14 SPECIAL MASTER POZZUOLI: You had another 15 question in the middle that. Go ahead. 16 BY MR. EDWARDS: 17 Q. Right. What does the quote attributed to 18 you in that article say? 19 MR. SIMPSON: The document hasn't even 20 been marked yet. 21 MR. EDWARDS: What are we up to, 24? 22 (Thereupon, marked as Plaintiff 23 Exhibit 24.) 24 A. It doesn't show what the question was. It 25 doesn't show the context. And like -- all lies. I said that, I think, on day one. And, again, you're dealing with the Daily Mail. The context would have to be did you get a massage from any underage girl or anything like that. I never said that. www.phi sre orting.com EFTA00615748

628 1 All lies. Obviously I was referring to what 2 said and what said 3 about me, so that was the "all lies." 4 BY MR. EDWARDS: 5 Q. I'm asking what is the quote about the 6 massages? What are the words that are used? 7 A. "I never got a massage from anybody, it's 8 made up out of whole cloth." I did not say that. 9 Q. Okay. So the reporter -- 10 A. Is wrong. 11 Q. -- is wrong? 12 A. Who is the reporter? Is it the same 13 Ms. Churchill? 14 So this is an article you said, again, 15 the Daily Mail. This sounds like it's the Daily 16 News, not the Daily Mail. 17 Q. Okay. 18 A. But it's not true. I never said in the 19 context of generally massage. Because why would I 20 say that if I said it on television, I said it on 21 the radio, I've said it over and over again that I 22 got a massage? 23 Q. You deny making the statement that was 24 attributed to you in the Daily Mail article that's 25 attached to the deposition as Exhibit 24? www.phi sre orting.com EFTA00615749

629 1 A. That's right. 2 Q. Okay. It does say the Daily News. 3 A. Or -- now, let me be very clear. If I 4 said it, I said it in the context of 5 Q. Daily News. 6 A. If I said it, I said it in the context of 7 ' massage or a massage during the 8 relevant period because I never would say that I 9 didn't get a massage when I got one, and I always 10 said I did. 11 Go back and check earlier statements, 12 statements before this, and you'll see that I said 13 it. So what sense would it make for me to say that 14 I didn't get it? 15 Q. So is your testimony that you only had one 16 massage at Mr. Epstein's home? 17 A. That's -- let me be very clear. I never 18 had a massage in the New York place. I of course 19 never had a massage in the -- in the ranch. I have 20 no recollection of having a massage -- I never had a 21 massage on airplane. And I had one massage in the 22 Palm Beach home. 23 Q. What year it was that you had the massage 24 in the Palm Beach home? 25 A. I don't know, but I suspect it was in -- www.phi sre orting.com EFTA00615750

630 1 very early in my friendship or my acquaintanceship 2 with Jeffrey Epstein, probably '96 or '97, but I 3 would be guessing. 4 It was not during the relevant time period 5 because I was not in Jeffrey Epstein's -- my records 6 show I was not in Jeffrey Epstein's home in Palm 7 Beach during the relevant time period, so I couldn't 8 have had a massage during that period. 9 Q. So is it your testimony, then, that the 10 only massage we're getting some background from 11 the phone. 12 MR. SIMPSON: On the phone, there's some 13 background. 14 MR. INDYKE: Am I the only one on the 15 phone? This is Darren. Because if I'm not -- 16 (Discussion off the record.) 17 BY MR. EDWARDS: 18 Q. So is your testimony today that at any of 19 Jeffrey Epstein's homes, you have only had one 20 massage, and that was only at the Palm Beach home 21 and it was sometime in the mid to later '90s? 22 A. No, let me be very clear. I know for 23 absolute certainty I never had a massage in the 24 New York home. I know for absolute certainty I 25 never had a massage in the ranch. www.phi sre orting.com EFTA00615751

631 1 I do recall having one massage in the Palm 2 Beach home. I do know for certain that I never had 3 a massage in the airplane. And I'm fairly certain I 4 never had a massage at the -- on the island. 5 Q. And the one massage that you had at the 6 Palm Beach home was sometime early in your 7 relationship with Jeffrey Epstein, '96 or '97 8 approximately? 9 A. I'm not sure. I'm not sure about that. I 10 just don't remember exactly when it was. But it 11 wasn't -- obviously it was when I was in his house, 12 and the records show that I wasn't in his house 13 during the relevant time period. 14 Q. Is it your memory, though, that it was in 15 the '90s? 16 A. I can't remember. It could have been -- 17 it could have been later. I know that when my 18 children and grandchildren came to stay at Jeffrey 19 Epstein's house in 2005, I think there was some 20 massages that were -- oh, yeah, I think some of them 21 had massages. I did not -- 22 Q. But -- 23 A. -- is my recollection. 24 Q. But your massage was many years before 25 that experience in -- www.phi sre orting.com EFTA00615752

632 1 A. I think so, but I'm not sure. It could 2 have been later too. I just don't have any distinct 3 chronological frame of reference for when I had a 4 massage, but I do remember it very clearly and I 5 remember that it was painful and I remember that the 6 massage therapist wanted to put her knees on my 7 shoulder, and I called my wife immediately after I 8 had the massage and told her that this therapist 9 wanted to put her knees on my shoulder and I said I 10 wasn't really anxious to have that, because she had 11 hurt me. She was a very deep therapy massage 12 person. 13 Q. Have you seen Juan Alessi's testimony 14 wherein he indicates that you had massages at 15 Jeffrey Epstein's home? 16 A. Would you show it to me, please. 17 MR. INDYKE: Same objection and 18 instruction. 19 MR. SCOTT: Didn't we cover this with 20 Mr. Scarola the last time, the massage issue? 21 I could be wrong. 22 THE WITNESS: I was asked about it last 23 time. 24 MR. SCOTT: Last time I think I covered 25 this. www.phi sre orting.com EFTA00615753

633 1 SPECIAL MASTER POZZUOLI: Is this the 2 deposition from this matter? 3 MR. EDWARDS: The deposition that was in 4 the civil matters against Jeffrey Epstein, and 5 I think I've bracketed each of the pertinent 6 parts. 7 A. I don't see him saying more than one 8 massage. It says, "Did he have massages sometimes 9 when he was there? 10 "Yes. A massage was like a treat for 11 everybody. If they wanted, we called the massage 12 and they had a massage." 13 That doesn't sound to me like it's very 14 specific. I was offered massages on numerous 15 occasions by the house staff, and I said no. I did 16 have that one massage. And then you have bracketed 17 material about big dildos. That clearly refers to 18 an area of the house that I was never in, never 19 allowed into. Do you have any other brackets 20 material? 21 BY MR. EDWARDS: 22 Q. Not for this question. 23 A. So this is not any statement that I had 24 massages or multiple massages, doesn't contradict 25 what I said at all. He's testifying as to the www.phi sre orting.com EFTA00615754

634 1 general procedure, and he's right, people were 2 offered massages, and they were real massages, the 3 ones that I know about. 4 Q. Okay. Well -- 5 A. Let me say this. Jeffrey Epstein would 6 never dare to offer me an erotic massage. He would 7 know that I would walk out of that room so fast, I 8 would never speak to him again. He knows about my 9 relationship with my wife. He knows how much I love 10 her. He would never in a million years offer me 11 anything that was in any way improper, and he 12 didn't. 13 SPECIAL MASTER POZZUOLI: Brad, you have 14 five minutes before Jack smartly wants to get 15 out of here, so if you want to look for an 16 appropriate break. 17 MR. EDWARDS: I'll finish after -- a few 18 more questions on this, and then we're done. 19 BY MR. EDWARDS: 20 Q. Okay. The question was: 21 "Do you have any recollection of ■ coming to the house when Prince Andrew was 23 there? 24 "ANSWER: It could have been, but I'm not 25 sure." www.phi sre orting.com EFTA00615755

635 1 MR. INDYKE: Object -- 2 BY MR. EDWARDS: 3 Q. "QUESTION: When Mr. Dershowitz was 4 visiting 5 "ANSWER: Uh-huh. 6 "QUESTION -- how often did he come? 7 "ANSWER: He came pretty -- pretty often. 8 I would say at least four to five times a year. 9 "QUESTION: And how long would he 10 typically stay? 11 "ANSWER: Two, three days. 12 "QUESTION: Did he have massages sometimes 13 when he was there? 14 "ANSWER: Yes. A massage was like a treat 15 for everyone. If they wanted, we'd call the massage 16 and they have a massage." 17 He does indeed say that you stayed for two 18 or three days at a time and had plural massages, 19 right? That's his testimony. 20 A. No, he says I stayed for two or three 21 days. He doesn't say I was there with ■ And he says -- first of all, English is 23 not his first language, and he's talking about did 24 you have massages. "Yes, a massage is a treat for 25 everybody." www.phi sre orting.com EFTA00615756

636 1 I was offered massages. I had one 2 massage. Just -- I'm trying to think of something 3 else he said. Can I see it again, please? 4 BY MR. EDWARDS: 5 Q. The whole deposition? 6 A. Just that part of it. 7 The only time I stayed for -- he's right, 8 I stayed for two or three days with my wife, my 9 daughter-in-law, my son, and two grandchildren and 10 my daughter. We stayed for about five days. 11 Jeffrey Epstein was not in the house at that point 12 in time. 13 He found out we were looking for a 14 vacation place, and he offered his empty house with 15 the housekeeper and his wife, and we stayed there 16 during that period of time. 17 The only other time that I stayed for more 18 than one day was when I was involved in the case 19 with my research assistants. I stayed for two days 20 once with my nephew, Adam, who was coming to watch a 21 launch of the space shuttle. But I have no 22 recollection of ever staying three days alone. 23 There would be no reason I would do that. And I 24 didn't. 25 Q. While you were staying at the house, did www.phi sre orting.com EFTA00615757

637 1 Mr. Epstein have underage girls over to give him 2 massages? 3 A. Certainly not to my knowledge. If I had 4 seen a single underage girl in that house that 5 looked like she was there for any inappropriate 6 person, I would have been out of there 7 instantaneously. That would not be covered by the 8 lawyer-client privilege. And I would have called 9 the police and turned him in. That's how strongly I 10 feel about sex with underage people, male or female. 11 Q. Even though these girls were 14, 15, 16 12 years old? 13 A. I never saw -- not even though. 14 Especially. Of course. A fortiori. I never saw 15 anything like that, not on the airplane, not in the 16 ranch, not on the -- in the island, not in Palm 17 Beach, and not in New York. 18 MR. SCOTT: It's 4:45. 19 A. He did always travel with an entourage, 20 and he had people in his encourage who looked like 21 they were in their middle 20s. And, of course, 22 Mr. Scarola tried to accuse me of being on an plane 23 with an underage girl who turned out to be 25. 24 BY MR. EDWARDS: 25 www.phi sre orting.com EFTA00615758

638 1 Q. My last question, are you aware -- we can 2 pick back up here off of my last question. Are you 3 aware that another housekeeper, Alfredo Rodriguez, 4 put you in the home at a time when underage girls 5 were also in the home? 6 A. Would you please show me that? Because 7 your last question was a mischaracterization 8 MR. INDYKE: Same objection, same 9 instruction. 10 A. -- so let me see this one as well. 11 BY MR. EDWARDS: 12 Q. Sure. I'll just read it to you. 13 A. No, just let me see it. You can read it 14 to me. Let me see it. 15 Q. "And did you have knowledge of" -- 16 SPECIAL MASTER POZZUOLI: What are you 17 reading from? 18 MR. EDWARDS: Sure. It's the deposition 19 of Alfredo Rodriguez that was taken July 29, 20 2009. 21 BY MR. EDWARDS: 22 Q. "Was there a lawyer from Harvard named 23 Alan Dershowitz? 24 "Yes, ma'am. 25 "How often during the six months or so www.phi sre orting.com EFTA00615759

639 1 when you were there was Alan Dershowitz there?" 2 A. What were the six months, by the III? 3 Q. I don't know. We'll find out from his 4 employment with Jeffrey Epstein. Your client would 5 know. 6 "Two or three times. 7 "How did you have knowledge of why he was 10 11 12 friend? 13 14 15 at the time he was there? 16 17 18 instance, 19 20 21 22 23 24 25 8 visiting a -- and did you have knowledge of why he 9 was visiting? "No, ma'am. "Was he acting as a lawyer or there as a "ANSWER: I believe a friend. "Were there also young ladies in the house "ANSWER: Yes, ma'am. "And would those and have included, for "Yes, ma'am. "Were there other young ladies there when Mr. Dershowitz was there? "Yes, ma'am. "Do you have any idea who those young women were? "No, ma'am. www.phi sre orting.com EFTA00615760

640 1 "Were any of those young women that you 2 have said came to give massages? 3 "Yes, ma'am." 4 "Ms. Esell, who was representing at the time, asked you about Mr. Dershowitz 6 being present in Mr. Epstein's home, and I think she 7 said -- and I think you said Mr. Epstein was -- and 8 he and Mr. Dershowitz were friends? 9 "ANSWER: Yes. 10 "She also, I think, asked was 11 Mr. Dershowitz ever there when one of the women who 12 gave a massage was present in the home. 13 "ANSWER: I don't remember that. 14 "QUESTION: That's what I want to clear 15 up. Is it your testimony that Mr. Dershowitz was 16 there when any of the women came to Mr. Epstein's 17 home to give a massage? 18 "ANSWER: Yes. 19 "QUESTION: And when Mr. Dershowitz was at 20 the house, I understood you to say that these local 21 Palm Beach girls would come over to the house while 22 he was there, but you're not sure if he had a 23 massage from any of the girls. 24 "ANSWER: Exactly. 25 "QUESTION: And what would he do while the www.phi sre orting.com EFTA00615761

641 1 girls were in the house? 2 "He would read a book, glass of wine by 3 the pool or stay inside." 4 So my question is, are you aware that 5 Alfredo Rodriguez put you in Jeffrey Epstein's home 6 when the underage girls were coming to his home to 7 give massage? 8 A. Absolutely not. 9 MR. SIMPSON: Object to the form and 10 mischaracterizing and taking multiple separate 11 sections of a deposition and multiple different 12 pages read as though they were together. 13 Object to the form. 14 A. I'll answer. He talks about young 15 ladies -- 16 MR. SWEDER: I'm going to object to that, 17 too. This is Mr. Sweder. That is a misleading 18 reading of that deposition, leaving out a very 19 particular part of it -- 20 MR. EDWARDS: Okay. The whole 21 deposition -- 22 MR. SWEDER: -- that says that he didn't 23 know whether Dershowitz ever even saw these 24 young women. 25 MR. SCOTT: We covered this all in the www.phi sre orting.com EFTA00615762

642 1 last depo. 2 A. I never saw an underage person in Jeffrey 3 Epstein's house. I saw , who is a young 4 woman. I saw Giselle [sic] Maxwell, who is a young 5 woman. I saw women in their late 20s and 30s. 6 I never had a massage from any of these 7 young women. There's no mention of underage in the 8 entire deposition. And you again willfully and 9 deliberately misstated what you said the deposition 10 said, just like you misstated the deposition of 11 Mr. Rodriguez. 12 Q. Okay. The deposition will speak for 13 itself whether or not there's any mention of 14 underage women in the deposition. 15 A. Will you again point to met to the 16 underage? Point me to the word "underage" in that 17 deposition. 18 Q. I understand your statement that there is 19 not one. 20 A. There is not one, okay. I'm glad we have 21 that acknowledgment. 22 Q. I didn't acknowledge that. It's just not 23 true. 24 SPECIAL MASTER POZZUOLI: Is there any 25 other questions at this point? www.phi sre orting.com EFTA00615763

643 1 MR. EDWARDS: This is a good breaking 2 point. 3 VIDEOGRAPHER: Going off the record. The 4 time is approximately 4:49 p.m. 5 SPECIAL MASTER POZZUOLI: We're 6 reconvening 9:00 tomorrow? 7 MR. EDWARDS: Yes. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 www.phi sre orting.com EFTA00615764

644 CERTIFICATE OF OATH STATE OF FLORIDA COUNTY OF BROWARD I, the undersigned authority, certify that ALAN M. DERSHOWITZ personally appeared before me and was duly sworn on the 12th day of January, 2016. Signed this 14th day of January, 2016. 0 t a ( :4 • ,.. 6 g 4 ?-44c144,4/ . I BERLY FON::::RPR, CLR Notary Public, State of Florida My Commission No. FF 226848 Expires: 7/12/2019 www.phi sre orting.com EFTA00615765

645 CERTIFICATE OF REPORTER STATE OF FLORIDA COUNTY OF BROWARD I, KIMBERLY FONTALVO, Registered Professional Reporter, do hereby certify that I was authorized to and did stenographically report the foregoing videotape continued deposition of ALAN M. DERSHOWITZ; pages 462 through 455; that a review of the transcript was requested; and that the transcript is a true record of my stenographic notes. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. Dated this 14th day of January, 2016. KIMBERLY FONTALVO, RPR, CLR www.phi sre orting.com EFTA00615766

646 January 14, 2016 COLE, SCOTT & KISSANE, P.A. 10111111111111 BY: THOMAS EMERSON SCOTT, JR., ESQ. Re: Bradley Edwards, et al., v. Alan M. Dershowitz Please take notice that on the 12th day of January, 2016, you gave your deposition in the above cause. At that time, you did not waive your signature. The above-addressed attorney has ordered a copy of this transcript and will make arrangements with you to read their copy. Please execute the Errata Sheet, which can be found at the back of the transcript, and have it returned to us for distribution to all parties. If you do not read and sign the deposition within a reasonable amount of time, the original, which has already been forwarded to the ordering attorney, may be filed with the Clerk of the Court. If you wish to waive your signature now, please sign your name in the blank at the bottom of this letter and return to the address listed below. Very truly yours, KIMBERLY FONTALVO, RPR, CLR J101111. I do hereby waive my signature. ALAN M. DERSHOWITZ www.phi sre orting.com EFTA00615767

647 ERRATA SHEET DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE In Re: BRADLEY EDWARDS, ET AL., V. ALAN M. DERSHOWITZ Case No.: ALAN M. DERSHOWITZ January 12, 2016 PAGE LINE CHANGE REASON Under penalties of perjury, I declare that I have read the foregoing document and that the facts stated in it are true. Date ALAN M. DERSHOWITZ www.phi sre orting.com EFTA00615768

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