EFTA00601154

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1 
$80,000 of their own money to start the charity. 
2 
She didn't indicate which lawyers. But the lawyers 
3 
had contributed $80,000 of their own money to start 
4 
the charity and that they were going to fund the 
5 
charity by contribution from Leslie -- from the man 
6 
from Columbus who owned Victoria's Secret and they 
7 
expected a very substantial contribution. 
8 
They also said that -- 
12:05:02 
9 
Q. 
I'm sorry, but "they" is not helpful to 
12:05:04 
10 
me. 
11 
A. 
She -- when I say "they" -- when I talk 
12:05:07 
12 
about the substance, I'm always talking about her. 
13 
I never had any conversations about the substance 
14 
with him. 
15 
She said that they were hoping to fund the 
12:05:17 
16 
charity by substantial contribution from Leslie 
17 
Wexner and that they thought that by getting on 
18 
television, they would increase the chances of 
19 
raising this money from Leslie Wexner. 
20 
And that she thought they had already made 
12:05:37 
21 
contact with Wexner and that they had already 
22 
made -- with the man from Columbus, and they had 
23 
already made contact with ABC. But I don't think 
24 
she knew at that point whether the actual interviews 
25 
did or did not occur. Oh, she did tell me that she 
EFTA00601254

102 
1 
went to New York at some point for the interviews. 
2 
Q. 
"She" who? 
12:06:04 
3 
A. 
She, Rebecca, told me that 
had 
12:06:05 
4 
gone to New York and so she assumed that she was 
5 
into New York for the interviews. 
6 
Q. 
So this was a conversation that you 
12:06:17 
7 
assumed took place after 
was 
8 
interviewed in New York? 
9 
A. 
I don't know. I don't know. 
12:06:25 
10 
Q. 
That's what you were told? 
12:06:26 
11 
A. 
No. I was told that she was in New York. 
12:06:27 
12 
I'm just giving you the facts, sir. 
13 
Q. 
Okay. Any other information exchanged 
12:06:31 
14 
between you and Rebecca and/or Michael during the 
15 
third conversation? 
16 
A. 
I can't recall during the third 
12:06:44 
17 
conversation any further information that was 
18 
exchanged, no. 
19 
Q. 
Did you place that phone call on a 
12:06:50 
20 
landline or cell phone? 
21 
A. 
I don't remember. 
12:06:54 
22 
Q. 
Do you have a landline in New York? 
12:06:58 
23 
A. 
I do. 
12:07:00 
24 
Q. 
Do you have a landline in Massachusetts? 
12:07:01 
25 
A. 
Yes. 
12:07:05 
EFTA00601255

103 
1 
Q. 
What's the next communication that you had 
12:07:07 
2 
with Rebecca and/or Michael? When did it occur? 
3 
A. 
I don't recall. I don't recall. I know 
12:07:16 
4 
we had further communications. They were mostly 
5 
repetitions and I have no specific recollection of 
6 
when -- when they occurred. And I was constantly 
7 
saying to her, can I -- you know, are you feeling 
8 
comfortable about being public with this? And she 
9 
kept saying no. 
10 
Q. 
Were there any more substantive 
12:07:47 
11 
communications that occurred between you and Rebecca 
12 
and/or Michael? 
13 
A. 
I would say that none that gave me new 
12:07:54 
14 
information. I would constantly ask them, you know, 
15 
to reiterate has anything changed, have you changed 
16 
your mind, have you remembered anything new. But 
17 
basically what I've told you was the substance of 
18 
the information: A, that she didn't ever mention 
19 
me; B, that she was pressured into mentioning me by 
20 
her lawyers; C, that she was going to raise a 
21 
billion dollars or half of the net worth of the guy 
22 
from Columbus, Ohio. 
23 
And the next, that she was going to be 
12:08:25 
24 
interviewed by ABC in an effort to make it clear 
25 
that she had, A, credibility, that ABC would give 
EFTA00601256

104 
1 
her credibility, and that that would help her in her 
2 
efforts to obtain money from her -- I think at some 
3 
point she also mentioned that she would go after 
4 
other people that she hadn't yet named in an effort 
5 
to obtain money from them as well. 
6 
Q. 
Did you ever directly ask Rebecca if 
12:08:58 
7 
had admitted that she had never met 
8 
you? 
9 
A. 
No. 
12:09:08 
10 
Q. 
Did you ever -- well, why not? Why didn't 
12:09:09 
11 
you ask that question? 
12 
A. 
I just -- 
12:09:13 
13 
MR. SCOTT: Objection. Go ahead. 
12:09:15 
14 
A. 
I just wanted to get her to tell me what 
12:09:15 
15 
she was going to tell me. I was very satisfied with 
16 
her answers. There were a lot of questions I could 
17 
have asked. I had to treat her very gently. I 
18 
wanted to keep her on the phone for as short a 
19 
period of time as possible. I didn't want to be 
20 
perceived as in any way harassing her. And so I 
21 
didn't ask that question directly. 
22 
BY MR. SCAROLA: 
12:09:41 
23 
Q. 
Well, certainly one of the most 
12:09:41 
24 
significant questions that you could have asked her 
25 
was: Did 
ever admit she never met me? 
EFTA00601257

105 
1 
That would be pretty significant, wouldn't 
12:09:52 
2 
it? 
3 
MR. SCOTT: Objection, form, 
12:09:55 
4 
argumentative. 
5 
A. 
What I asked her was to please recall 
12:09:57 
6 
everything that 
had said to her. 
7 
BY MR. SCAROLA: 
12:10:00 
8 
Q. 
Yes, sir. But that's not my question to 
12:10:00 
9 
you. 
10 
A. 
I didn't -- 
12:10:02 
11 
Q. 
It would have been very significant had 
12:10:03 
12 
ever said, I never met Alan 
13 
Dershowitz, right? 
14 
MR. SCOTT: Objection, argumentative. Go 
12:10:10 
15 
ahead. 
16 
A. 
It wouldn't have been significant to me 
12:10:11 
17 
because I know that 
never met Alan 
18 
Dershowitz. It would have been significant to me if 
19 
she could have so testified. But I didn't want to 
20 
in any way turn off her as a source of information. 
21 
And so I didn't ask her very many questions at all. 
22 
I wanted her to tell me her best recollection 
23 
unprompted and unquestioned. 
24 
I didn't want to subject her to a series 
12:10:37 
25 
of examination questions. I wanted her to tell 
EFTA00601258

106 
1 
me -- for example, the whole thing about the guy 
2 
from Columbus, I didn't know anything about that. 
3 
She just said that in the course of conversing with 
4 
me and led me to conclude that there was an 
5 
extortion plot. 
6 
I had actually believed there was an 
12:10:52 
7 
extortion plot from the very beginning and said 
8 
that. But I had no real knowledge about who the 
9 
ultimate object of the extortion plot was until I 
10 
was able to confirm with Leslie Wexner's people 
11 
that, in fact, overtures been made to him at about 
12 
the same time as my name was publicly and falsely 
13 
revealed. So it all fit together. 
14 
And my own view is that a prosecutor would 
12:11:21 
15 
look very, very harshly at the sequence of events 
16 
that occurred in this case and might welcome the 
17 
conclusion that there was a criminal extortion plot. 
18 
Which is my belief. 
19 
BY MR. SCAROLA: 
12:11:37 
20 
Q. 
Well, we know you never made a Bar 
12:11:37 
21 
complaint. 
22 
A. 
Huh-huh. 
12:11:39 
23 
Q. 
Did you ever file a criminal complaint 
12:11:39 
24 
against any of these extortionists or perjury 
25 
suborners? 
EFTA00601259

107 
1 
A. 
We actually talked about that. And -- 
12:11:47 
2 
Q. 
Who's the "we"? 
12:11:50 
3 
MR. SIMPSON: Don't disclose any -- 
12:11:53 
4 
THE WITNESS: Okay -- 
12:11:53 
5 
MR. SIMPSON: -- lawyer-client 
12:11:54 
6 
A. 
I had conversations about that with 
12:11:55 
7 
appropriate persons, yes. And I discussed it with 
8 
Wexner's lawyers. 
9 
BY MR. SCAROLA: 
12:12:07 
10 
Q. 
Are you answering yes to my question that 
12:12:08 
11 
you have filed a criminal complaint? 
12 
A. 
Not yet. 
12:12:12 
13 
Q. 
Okay. So it has been ten months since you 
12:12:14 
14 
allegedly became aware of that suborning of perjury 
15 
and some eight months since your allegedly having 
16 
become aware of the extortion plot, but you have 
17 
filed no criminal complaints against anyone, 
18 
correct? 
19 
A. 
To answer that question requires me to 
12:12:40 
20 
disclose conversations I had with David Boies. I 
21 
would love to answer that question. 
22 
Q. 
No, sir, it does not. 
12:12:48 
23 
A. 
Yes, it does. 
12:12:49 
24 
MR. SCOTT: Whoa, you can't -- how can you 
12:12:49 
25 
say --
EFTA00601260

108 
1 
BY MR. SCAROLA: 
12:12:51 
2 
Q. 
Whether you filed a criminal complaint or 
12:12:51 
3 
not. 
4 
A. 
Yes, it does. 
12:12:52 
5 
MR. SCOTT: Please, Jack, he can't say 
12:12:53 
6 
that. 
7 
A. 
It does involve conversation I had with 
12:12:54 
8 
David Boies. 
9 
BY MR. SCAROLA: 
12:12:57 
10 
Q. 
Well, in that case, in light of the fact 
12:12:57 
11 
that that is a matter that will be addressed by the 
12 
Court, we'll save that question for another time. 
13 
A. 
I'm anxious to answer it. 
12:13:05 
14 
Q. 
And I'm anxious to get an answer. 
12:13:09 
15 
A. 
Well, I hope we can agree I should be able 
12:13:10 
16 
to answer it. 
17 
Q. 
Have we exhausted your recollection of the 
12:13:20 
18 
details of conversations that you had with Rebecca 
19 
and Michael? 
20 
A. 
About the substance of what she told me. 
12:13:27 
21 
There were many conversations involving would she do 
22 
this, would she do that. But the conversations, the 
23 
substance we've exhausted. 
24 
Q. 
Okay. Well -- 
12:13:40 
25 
A. 
That is A, B, C, D, E, as I said, those 
12:13:40 
EFTA00601261

109 
1 
those are what I've told you is the substance, the 
2 
details of what she said. And she said nothing 
3 
different or new, to my recollection, in any of the 
4 
brief subsequent conversations that we may have had. 
5 
Q. 
Which phone call was it when she finally 
12:14:01 
6 
disclosed her full name? 
7 
A. 
Not the first. It was either the second 
12:14:19 
8 
or the third conversation. Probably the second 
9 
conversation. First I got his name and I checked 
10 
him out, checked on Google to make sure that he was 
11 
who he says he was and lived where he lived. And 
12 
then she gave me her name. 
13 
Q. 
So, when you say you checked Michael out, 
12:14:39 
14 
what you did is you Googled him; is that right? 
15 
A. 
I just Googled him to see that he lived in 
12:14:43 
16 
the place where he lived and was 
17 
Q. 
Okay. Did you do any other background 
12:14:46 
18 
information? 
19 
A. 
Well, I was -- no, I was obviously 
12:14:49 
20 
concerned that maybe I was being set up by your 
21 
clients. And so I wanted to be sure that this 
22 
wasn't a setup, that this was an honorable person, 
23 
which is why I asked my wife also to listen to 
24 
the -- I think it was the second conversation. And 
25 
she concluded that she sounded completely honest, 
EFTA00601262

110 
1 
trustworthy and -- and anxious just to say exactly 
2 
and precisely what happened. And so I became 
3 
convinced that she was authentic and not -- not a 
4 
setup. 
5 
Q. 
Okay. So, in order to investigate 
12:15:26 
6 
Michael, you Googled him but did nothing else? 
7 
A. 
That's all. To my recollection, that's 
12:15:32 
8 
all I did is Google him. 
9 
Q. 
But you also relied upon both your and 
12:15:35 
10 
your wife's personal assessment of the credibility 
11 
of these people; is that right? 
12 
A. 
Absolutely. That's right, yes. 
12:15:44 
13 
Q. 
A skill that you've developed over the 
12:15:46 
14 
course of your years of practice, right? 
15 
MR. SCOTT: Objection. Go ahead. 
12:15:52 
16 
A. 
I just relied on it. I mean, I'm not -- I 
12:15:52 
17 
don't know how good I am at it. But some people are 
18 
very good liars. But I believed her. That was my 
19 
judgment. 
20 
My wife, who is a, you know, Ph.D. 
12:16:06 
21 
neuropsychologist with a lot of experience, we all 
22 
thought she sounded -- we both thought she sounded 
23 
incredibly truthful. 
24 
BY MR. SCAROLA: 
12:16:16 
25 
Q. 
But was it all or was it both? 
12:16:17 
EFTA00601263

111 
1 
A. 
Just both, just the two of us. 
12:16:19 
2 
Q. 
You and your wife? 
12:16:20 
3 
A. 
Just me and my wife, yeah. 
12:16:21 
4 
Q. 
So -- 
12:16:24 
5 
A. 
My wife is southern, so I'm used to the 
12:16:24 
6 
phrase "all." 
7 
Q. 
You relied upon your personal assessment 
12:16:27 
8 
of 
9 
A. 
That's right. 
12:16:30 
10 
Q. 
-- Rebecca's credibility? 
12:16:30 
11 
A. 
That's right. 
12:16:32 
12 
Q. 
And you relied upon your wife's assessment 
12:16:33 
13 
of Rebecca's credibility? 
14 
A. 
That's right. 
12:16:37 
15 
Q. 
And did you do any further investigation 
12:16:38 
16 
of her? 
17 
A. 
No. Well, yes, of course, I corroborated 
12:16:44 
18 
everything she said by talking to Leslie Wexner's 
19 
wife, talking to Leslie Wexner's lawyers, talking to 
20 
ABC, and finding out that everything she said to me 
21 
was absolutely true, yes. 
22 
Q. 
Well, the one thing that you didn't 
12:17:01 
23 
corroborate was anything that 
24 
allegedly said to her about you? 
25 
A. 
Of course I did. Of course I did. 
12:17:10 
EFTA00601264

112 
1 
Q. 
How did you do that? 
12:17:12 
2 
A. 
I corroborated what 
said, 
12:17:13 
3 
that she was -- was going to sue Leslie -- she was 
4 
going to go after Leslie Wexner to try to get a lot 
5 
of money --
6 
Q. 
Let me make sure you understand my 
12:17:26 
7 
question. 
8 
A. 
Yeah. Yeah. 
12:17:27 
9 
Q. 
Okay? You have corroborated surrounding 
12:17:28 
10 
circumstances --
11 
A. 
Right. 
12:17:36 
12 
Q. 
related to you by Rebecca? 
12:17:36 
13 
A. 
Right. Right. 
12:17:40 
14 
Q. 
You did not corroborate anything that 
12:17:41 
15 
Rebecca told you about what 
said 
16 
regarding you personally, correct? 
17 
A. 
Of course I did. No, of course I did. I 
12:17:53 
18 
corroborated it by my absolute firm and complete and 
19 
unequivocal knowledge that your clients' allegations 
20 
against me and 
' allegations against 
21 
me were totally and completely false and completely 
22 
made up. So I knew that. That knowledge 
23 
corroborated her statements. 
24 
Q. 
Well, the statement that you have related 
12:18:14 
25 
is that Rebecca said 
was pressured 
EFTA00601265

13.3 
1 
into naming you --
2 
A. 
There were -- 
12:18:24 
3 
Q. 
-- correct? 
12:18:25 
4 
A. 
No, there were two statements. One that 
12:18:26 
5 
never mentioned me in connection 
6 
with anybody that she had any sexual contact with. 
7 
I knew that was true. Your clients know that that 
8 
is false. And me knowing it's true served to 
9 
corroborate that statement by her. 
10 
Q. 
How could you possibly know whether 
12:18:45 
11 
ever mentioned your name before 
12 
December of 2014? 
13 
A. 
Because it was false and because she would 
12:18:54 
14 
not have mentioned my name until her lawyers 
15 
pressured her into doing it because I had no contact 
16 
with her. 
17 
Q. 
Do you have a copy of the statement that 
12:19:11 
18 
made to the FBI? 
19 
A. 
I don't have it here, no. 
12:19:16 
20 
Q. 
Have you seen it? 
12:19:17 
21 
A. 
Her statement to the FBI? 
12:19:20 
22 
Q. 
Yes. 
12:19:22 
23 
A. 
No, but I do know that she never told the 
12:19:23 
24 
FBI anything about me whatsoever. Because I was 
25 
told that by Jeffrey Sloman, who was the assistant 
EFTA00601266

114 
1 
United States attorney in charge of this case. 
2 
Jeffrey Sloman said he was prepared to file a sworn 
3 
affidavit that my name never came up, period, during 
4 
any investigation whatsoever, and that if my name 
5 
had in any way come up, I would not have been 
6 
allowed to participate in the negotiations because I 
7 
would have had a conflict of interest. 
8 
Jeffrey Sloman said that to me and to 
12:19:55 
9 
other people and tried very hard to get the Justice 
10 
Department to allow him to file an affidavit 
11 
asserting that. So I know it's true. And I know 
12 
it's false what you're alleging; namely, that she 
13 
said she had sex with me or implying that to the 
14 
FBI. 
15 
If she did, she's committed yet an 
12:20:14 
16 
additional crime, 1001, by lying to an FBI agent, 
17 
which if she did I'd like to know about that because 
18 
I'd like to then file a formal complaint with the 
19 
FBI about that, or with the Justice Department. 
20 
I recommend that you speak to Jeffrey 
12:20:33 
21 
Sloman. 
22 
Q. 
You know that 
is not the 
12:20:35 
23 
only person who has sworn under oath that you were 
24 
present at Jeffrey Epstein's Palm Beach home with 
25 
young girls, right? 
EFTA00601267

in 
1 
A. 
No. 
12:20:54 
2 
Q. 
You don't know that? 
12:20:55 
3 
A. 
No. I know that -- 
12:20:57 
4 
Q. 
Well, that's fine. You've answered my 
12:20:59 
5 
question. That's not something you know? 
6 
A. 
A, I was not present in Jeffrey Epstein's 
12:21:02 
7 
home with any underage young women, period. Never, 
8 
ever under any circumstances. 
9 
B, I am not aware that anyone has sworn 
12:21:12 
10 
under oath that I was there during the relevant 
11 
periods of time, which is a three-year period 
12 
between the summer of 1999 and the summer of 2002. 
13 
Because I was never -- as far as I know, I was never 
14 
in Jeffrey Epstein's home during that period of 
15 
time, period. 
16 
Q. 
I want to go back to the Ashes, if I 
12:21:36 
17 
could. Joanne Ashe is not a lawyer, is she? 
18 
A. 
Joanne Ashe is not a lawyer, no. 
12:21:42 
19 
Q. 
And is Alexi Ashe a lawyer? 
12:21:44 
20 
A. 
Yes. 
12:21:46 
21 
Q. 
Has Alexi Ashe ever been your lawyer? 
12:21:49 
22 
A. 
I have discussed the case with Alexi Ashe. 
12:21:53 
23 
She is a full-time sex trafficking prosecutor whose 
24 
whole career has been going after sex traffickers in 
25 
the Brooklyn District Attorney's office and I have 
EFTA00601268

116 
1 
discussed my case with her. 
2 
Q. 
Has Alexi Ashe ever been your lawyer? 
3 
A. 
I would say not, no. 
4 
Q. 
Beginning approximately January 3 or 4 of 
5 
2015, you began a mass media campaign battle against 
6 
7 
that they were sleazy, unethical lawyers who 
8 
9 
A. 
That's a false 
10 
11 
12 
A. 
That's a false statement. 
13 
I did not begin. It was your clients who 
14 
began it. Your clients began it by filing false 
15 
statements in a federal court which the judge struck 
16 
and sanctioned them for as being irrelevant and 
17 
pertinent and he used other language. 
18 
19 
began it in order to get massive press attention to 
20 
21 
called me, the press called me immediately and asked 
22 
me for my reaction. I was totally shocked that any 
23 
lawyer would make these kinds of outrageous 
24 
career-destroying allegations without even calling 
25 
me and asking me if I would deny it or have any 
Bradley Edwards and Professor Paul Cassell alleging 
fabricated false charges against you, correct? 
MR. SCOTT: Objection, argumentative, mass 
media, et cetera. 
They began it. It is my belief that they 
it. And my -- my responses were when the press 
12:22:09 
12:22:11 
12:22:23 
12:22:46 
12:22:46 
12:22:46 
12:22:49 
12:23:10 
EFTA00601269

117 
1 
evidence to provide for them. 
2 
And when I was called by the media, I did 
12:23:47 
3 
what you would do, Mr. Scarola, or what your clients 
4 
would do, I defended myself. What any American 
5 
would do under the First Amendment, I categorically 
6 
denied career-destroying false statements and I told 
7 
the truth, which is what the United States 
8 
Constitution is all about and why we fought for 
9 
liberty. Yes, I told the truth to the media. 
10 
BY MR. SCAROLA: 
12:24:10 
11 
Q. 
You engaged in a mass media campaign to 
12:24:11 
12 
convince the world that Bradley Edwards and 
13 
Professor Paul Cassell were unethical lawyers who 
14 
had fabricated false charges against you, correct? 
15 
MR. SCOTT: Objection, argumentative. 
12:24:30 
16 
A. 
No, that's not correct. I responded to 
12:24:31 
17 
press inquiries by telling the truth. My goal was 
18 
to let the world know that 
19 
allegations against me were totally false. These 
20 
stories appeared, as far as I can tell, in every 
21 
single newspaper in the world and on every media, 
22 
which was part of their plot and the plan of your 
23 
clients, which is why they absurdly mentioned 
24 
Prince Andrew, claiming in the most absurd way --
25 
that they mentioned him because he was trying to 
EFTA00601270

118 
1 
lobby prosecutors to get a reduced sentence for 
2 
Jeffrey Epstein, they obviously put Prince Andrew in 
3 
there in order to get massive publicity around the 
4 
world. And every media in the world practically 
5 
6 
7 
BY MR. SCAROLA: 
8 
9 
10 
were unethical lawyers who fabricated false charges 
11 
against you, right? 
12 
A. 
The truth --
13 
MR. SCOTT: Objection, form. 
14 
15 
that the charges against me were false and 
16 
fabricated, that I never had any sexual contact 
17 
18 
19 
20 
21 
22 
23 
24 
25 
called me from the BBC, to CBS, to ABC, to CNN and I 
responded to lies with the truth. 
12:25:26 
Q. 
And the truth that you attempted to convey 
12:25:27 
was that Bradley Edwards and Professor Paul Cassell 
A. 
The truth that I intended to convey was 
BY MR. SCAROLA: 
Q. 
Fabricated by whom, sir? 
A. 
Please don't interrupt me. 
MR. SCOTT: Objection, interrupting. 
BY MR. SCAROLA: 
Q. 
Please answer the question. 
A. 
Please don't interrupt --
MR. SCOTT: He's answering them. You may 
not like the answer, but he's answering them. 
12:25:42 
12:25:43 
12:25:44 
12:25:52 
12:25:52 
12:25:54 
12:25:55 
12:25:55 
12:25:55 
12:25:56 
12:25:57 
EFTA00601271

119 
1 
A. 
Now you've -- you've made me lose my train 
12:26:02 
2 
of thought, so --
3 
MR. SCOTT: Can you read the question back 
12:26:05 
4 
and the -- read the question back and his 
5 
answers, please. 
6 
(Requested portion read back.) 
12:26:08 
7 
THE COURT REPORTER: The question was: 
12:26:08 
8 
"And the truth that you attempted to convey was 
9 
that Bradley Edwards and Professor Paul Cassell 
10 
were unethical lawyers who fabricated false 
11 
charges against you, right?" 
12 
And the answer was: "The truth that I 
12:26:08 
13 
intended to convey was that the charges against 
14 
me were false and fabricated, that I never had 
15 
any sexual contact" -- and then the question 
16 
was -- the answer was interrupted. 
17 
A. 
Okay. Let me continue. That I never had 
12:26:42 
18 
any sexual contact with 
because 
19 
Professor Cassell insisted on conveying to the 
20 
public that he was a former judge and that he was a 
21 
professor and that he was using, improperly in my 
22 
view, the stationery and name of his university to 
23 
add credibility to his claims, I felt that it was 
24 
imperative for me to indicate that he was engaging 
25 
in improper and unethical conduct. 
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120 
1 
It would have been improper for me to have 
12:27:18 
2 
allowed his use of his credibility as a former 
3 
federal judge, as a professor who uses, misuses his 
4 
university imprimatur, it was very important for me 
5 
to attack the credibility of the messengers of the 
6 
false information. 
7 
And it was important for me to also remind 
12:27:43 
8 
the public that Bradley Edwards was a partner of 
9 
Rothstein, a man who is spending 50 years in jail 
10 
for fraudulently creating a Ponzi scheme to sell 
11 
Jeffrey Epstein cases that didn't exist. Yes, it 
12 
was very important for me to indicate the back --
13 
the real backgrounds of these lawyers and to make 
14 
sure that the public didn't believe that because 
15 
they were credible, their story must be credible. 
16 
In fact, one of the first questions that I 
12:28:22 
17 
was asked repeatedly by the media is: Why would a 
18 
former federal judge level a false charge against 
19 
you? Why would a distinguished personal injury 
20 
lawyer level a false charge against you? 
21 
And it was important for me to indicate 
12:28:36 
22 
why they would, that they were trying to do it for 
23 
crass financial reasons, they were trying to do it 
24 
to open up a non-prosecution agreement, they were 
25 
trying to do it for reasons that were improper. 
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