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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL 
CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA 
CASE NO.: CACE 15-000072 
BRADLEY J. EDWARDS and PAUL G. 
CASSELL, 
Plaintiffs, 
vs. 
ALAN M. DERSHOWITZ, 
Defendant. 
VIDEOTAPE CONTINUED DEPOSITION OF 
ALAN M. DERSHOWITZ 
VOLUME 5 
Pages 648 through 781 
Wednesday, January 13, 2016 
9:04 a.m. - 11:59 a.m. 
Tripp Scott 
110 Southeast 6th Street 
Fort Lauderdale, Florida 
Stenographically Reported By: 
Kimberly Fontalvo, RPR, CLR 
Realtime Systems Administrator 
www.phippsreporting.com 
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1 
APPEARANCES: 
1 
INDEX 
2 
2 
3 
On behalf of Plaintiffs: 
3 
SEARCY. DENNEY. SCAROLA 
Examination 
Page 
4 
BARNHART & SHIPLEY. P.A. 
4 
2139 Palm Beach Lakes Boulevard 
s 
West Palm Beach. Florida 33402-3626 
5
VOLUME 5 (Pages 648 - 781) 
BY: JACK SCAROLA. ESQ. 
6 
7 
6 
jsx esearcyhw.com
7
Certificate of Oath 
778 
a 
On behalf of Defendant: 
Certificate of Reporter 
779 
9 
COLE. SCOTT & KISSANE. P.A. 
8
Read and Sign Letter to Witness 
780 
10 
Dadeland Centre II - Suite 1400 
9150 South Dadeland Boulevard 
Miami. Herida 33156 
9 
Errata Sheet (forwarded upon execution) 
781 
11 
BY: THOMAS EMERSON SCOTT. JR.. ESQ. 
10 
PLAINTIFF EXHIBITS 
thotnas.scou6ksklegal.com 
11 
12 
BY: STEVEN SAFRA. ESQ. (Via phone) 
steven.safranieskkgalcom 
12
No. 
Page 
13 
-and- 
13
25 Transcript from Don Lemon Interview 
689 
14 
SWEDER & ROSS. 112 
14 
15 
Ill Oliver Street 
Boston. MA 02110 
15 
BY: KENNETH k SWEDER. ESQ. 
16 
16 
kswederesweder-ross.com 
17 
17
18 
-and- 
WILEY. REIN 
18 
17769 K Suet, NW 
19 
19 
Washington. DC 20006 
20 
20 
BY: RICHARD A. SIMPSON. ESQ. 
RSimpson6wilepein.com 
21 
21 
22 
22 
23 
23 
24 
24 
25 
25 
650 
652 
1
APPEARANCES (Continued): 
1 
Thereupon. the proceedings continued at 9:04 a.m. 
2 
2 
VIDEOGRAPHER: Are now on the video 
3
On behalf of Jeffrey Epstein: 
3 
record. This is the 13th day of January. 2016. 
4 
DARREN K. INDYKE. PLLC 
4 
The time is 9:04 am. This is the videotaped 
575 Lexington Ave.. 4th Fl. 
5
New York, New York 
5 
deposition of Alan Dershowitz in the matter of 
BY: DARREN K. INDYKE, ESQ. (Via phone) 
6 
Bradley Edwards and Paul Cassell versus Alan 
6 
7 
Dershowitz. 
7
On behalf of 
8 
My name is Marcy Martinez_ I am the 
8 
BOLES. SCHILLER & FLEXNER, LLP 
9 
videographer representing Above & Beyond 
401 E. Las Olas Blvd_ Ste. 1200 
10 
Reprographics. Will the attorneys please 
9 
Fat Lauderdale. Florida 33301 
BY: SIGRID STONE MCCAWLEY, ESQ. 
11 
announce their appearances for the record. 
10 
[email protected] 
12
MR. EDWARDS: Sure. On behalf of the 
11 
13 
plaintiff today Brad Edwards. Jack Scarola 
12 
ALSO PRESENT: 
19 
Brittany Henderson and Paul Cassell. 
13
Edward I. P012U011. Special Master 
15 
MR. SIMPSON: On behalf of the defendant 
14 
Sean D. Reyes. Utah Attorney General Office 
16 
and the witness. Richard Simpson. and Thomas 
15
Marcy Martinez. Videographer 
16 
17 
Scott will be joining. He just walked in. 
17 
18 
MS. McCAWLEY: On behalf of nonparty 
18 
19 
Sigrid McCawley and my 
19 
20 
colleague Meredith Schultz from Boles. Schiller 
20 
21 
& Plexner. 
21 
22 
22 
MR. INDYKE: On behalf of Jeffrey Epstein. 
23 
23 
Darren Indyke. 
24 
24 
SPECIAL MASTER POZZUOLI: Ed Ponuoli as 
25 
25 
the special master. 
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MR. SIMPSON: Is there anyone else on the 
1 
And I knew, of course, that I had never 
2 
phone? 
2 
met -- had no contact with 
I knew 
3 
MR. MAISEL: Yeah, this is Nicholas 
3 
that she was lying. I read her deposition. and as 
9 
Maisel. 
9 
an experienced lawyer with 50 years of experience, 
5 
THE COURT REPORTER: Would you raise your 
5 
it was absolutely clear to me that no lay person 
6 
right hand. please? 
6 
with her lack of education could have written that 
7 
Do you swear or affirm that the testimony 
7 
deposition. 
8 
you are about to give will be the truth, the 
8 
I sought the advice of friends and others 
9 
whole truth, and nothing but the truth? 
9 
with experience who confirmed the view that that 
10 
THE WITNESS: I do. 
10 
affidavit clearly had to have been written by 
11 
MR. SCAROLA: Nick would you announce the 
11 
lawyers and certainly drafted by lawyers: the level 
12 
capacity in which you're appearing, please. 
12 
of detail, the structure of the sentences, all of 
13 
MR. MAISEL: Special research assistant 
13 
which led me conclusively to the belief that the 
14 
for Alan Dershowitz, 
14 
lawyers had written this affidavit. 
15 
MR. SCAROLA: Thank you. 
15 
I suspected from the very beginning that 
16 
MR. EDWARDS: Are we ready? 
16 
this was part of an extortion plot in order to 
17 
SPECIAL MASTER POZZUOLI: Go ahead. 
17 
obtain money. I later learned many. many. many 
18 
BY MR. EDWARDS: 
18 
facts. 
19 
Q. Mr. Dershowitx, in January of 2015. when 
19 
MR. EDWARDS: I object and move to strike 
20 
you made the statements that Paul Cassell unit Brad 
20 
as nonresponsive and that the question calls 
21 
Edwards participated in the fabricating of the 
21 
for information in his possession in January of 
22 
allegations that were made against you, what 
22 
2015. I would ask for a ruling on that. 
23 
information or evidence did you have in your 
23 
A. I'm providing that. but I'm giving the 
24 
possession at that time to support those statements? 
29 
context. 
25 
MR. SIMPSON: Object to the form as overly 
25 
SPECIAL MASTER P0ZZUOLI: Denied. Move 
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1 
general. You may answer. 
1 
forward. 
2 
A. As soon as the allegations were made 
2 
A. Okay. I knew that there was a financial 
3
against me. I received a series of phone calls and 
3
motivation here. I also knew that Cassell and 
4
people approached me at various events and they 
4
Edwards had lied when the said they were
5
warned me about the reputation of Bradley Edwards. 
5
representing 
in a pro bono basis. 
6 
They told me that he had, in their view. 
6 
I had been informed repeatedly that they 
7
participated in a major fraud with a man named 
7
were in it for the money and that they expected to 
8
Rothstein. that he should be in jail for the 
8
earn a lot of money from representing her and others 
9
Rothstein events. 
9
in this case and that they pretended to be pro bono 
10 
I received a phone call saying that he had 
10
lawyers when they were, in fact. money-grubbing. 
11 
11 
money-hungry lawyers who had earned a very 
fabricated evidence when he was a plos,utor and 
12 
that he had knowingly failed to investigate police 
12 
substantial amount of money already on these cases 
13 
fabrication of evidence in a case. Generally was 
13
and were expecting to earn mom money. 
19 
warned about the terrible reputation that 
14 
Let me think of what other information I 
15 
Mr. Edwards had. 
15
had. 
16 
I also received phone calls telling me 
16 
SPECIAL MASTER POZZUOLI: At the time of 
17
that Mr. Cassell was a zealot, that he had used me 
17 
the question. 
18 
in class as a whipping — as a kind of an object of 
18 
A. At the time of my statements, right. 
19 
hate and painted me as a liberal supporter of the 
19 
It's just inconceivable to me that this 
20 
exclusionary rule and opponent of the death penalty. 
20 
uneducated woman could have come up with this story 
21 
and that he had no concern for the truth when it 
21 
on her own. 
22 
came to his zealotry on behalf of alleged victims. 
22 
I understood the motives of the lawyers. 
23 
The calls were just -- the people who told 
23 
and I was convinced, therefore, it was my opinion 
29 
me this were just -- there were so many of them that 
24 
based on my experience, in fact. that she could not 
25 
it was amazing to me. 
25 
have done this by herself and that she had to have 
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worked in coordination with her lawyers. 
1 
no. no. no. Na Respond to the question that 
2 
Her lawyers were also at that point 
2 
was answered and go ahead because I haven't 
3
claiming that the story should be believed because 
3 
heard any objection yet. 
4 
of who they were. Mr. Cassell. in my view. 
4 
MR. EDWARDS: I'm objecting to all of this 
5
unethically signed his pleading with the University 
5 
as being nonresponsive to the question. 
6 
of Utah imprimatur. suggesting that he was a State 
6 
SPECIAL MASTER POZZUOLI: Is there 
7
actor. suggesting that he acted an behalf of his 
7 
anything else that you would like to add to the 
8
university, something I would never do and I've 
8 
answer? 
9
stopped clients from doing. When I represent 
9 
THE WITNESS: Yes. 
10
people. I represent them on my own behalf. not on 
10 
A. When the newspapers called me. they all 
11 
behalf of any university. 
11
asked me the following question --
12 
The very fact that the Attorney General of 
12 
SPECIAL MASTER POZZUOLI: Was this in 
13
Utah was here yesterday indicates that he may very 
13 
January? 
14 
well be a State actor and subject to the rules of 
14 
A. This was in January. 
15
State action rather than individual action. 
15
BY MR. EDWARDS: 
16 
SPECIAL MASTER POZZUOLI: That portion I 
16 
Q. The question on the table Is —
17 
will strike. That sentence. 
17 
SPECIAL MASTER POZZUOLI: Hang on one 
18 
A. Sony. 
18 
second. 
19
BY MR. EDWARDS: 
19 
A. I'm going to tell you. 
20 
Q. Okay. 
20 
MR. EDWARDS: What information that 
21 
A. Tm not finished. 
21 
Mr. Dershowitz had in January 4.2015. when he 
22 
SPECIAL MASTER POZZUOLI: Is there any 
22 
made the statement that Paul Cassell and Brad 
23 
other information that you haven't touched 
23 
Edwards fabricated the allegations against him. 
24 
on — 
24 
MR. SIMPSON: The question was about in 
25 
THE WITNESS: I'm (tying to— 
25 
January of 2015. 
658 
660 
1 
SPECIAL MASTER POZZUOLI: -- as of. what. 
1 
SPECIAL MASTER POZZUOLI: That's what it 
2 
January? 
2 
was. That was the original question. which is 
3 
MR. EDWARDS: January of 2015. 
3 
why he was afforded a tremendous amount of 
4 
THE WITNESS: Oh. yes. 
4 
latitude. 
5 
MR. SCAROLA: January 4. 
5 
MR. EDWARDS: Understood. 
6 
MR. EDWARDS: January 4.2015. 
6 
A. And I got continuing information all 
7 
A. Okay. that's the question. But. of 
7
through January and amended my statements as 
8 
course. I made a sales of statements that continued 
8
consistent with the information that I ga. 
9
beyond January 4. and they always took into account 
9 
The newspapers called me. They all said 
10
new developments and new information that I had. 
10
to me. why would anybody make a false allegation if 
11 
I was also aware that Mr. Cassell was 
11
he's a former Federal judge. if he's a professor. if 
12 
promoting himself as a former federal judge and 
12 
he's a distinguished trial lawyer? 
13 
using his status and imprimatur in a false effort to 
13 
Clearly the -- on the 4th of December. 
14 
try to add credibility to the story. 
14 
talking about that day. that's the day on which 
15 
And I did not make -- this is very 
15
Mr. Cassell wrote to ABC —
16 
important to this. I did not make a single call to 
16 
BY MR. EDWARDS: 
17 
a single newspaper or single television station. to 
17 
Q. January. 
18 
my knowledge. or a single newspaper. I was 
18 
A. January 4. 2015. that's the date on which 
19 
constantly responding. 
19 
Mr. Cassell wrote to ABC News asking them to 
20 
MR. SCAROLA: That's not responsive. 
20 
publicize his client's story and to — and again 
21 
A. Excuse me. In the last deposition -- 
21 
making it clear to ABC who he was and what he -- and 
22 
SPECIAL MASTER POZZUOLI: No. no. 
22 
who he had been and what offices he had held. 
23 
A. -- there was an interruption by 
23 
And so it was clear to me at that point. 
24 
Mr. Scarola that I want to put on the record. 
24 
and through January it became clearer and clearer 
25 
SPECIAL MASTER POZZUOLI: No. no. no. no. 
25 
that she could not have done this on her own, that 
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she had to have sat with her lawyers and concocted 
1 
MR. EDWARDS: Affidavit. 
2 
this story. added the kind of detail to the story 
2 
A. — if I hadn't seen it at that point. I 
3
that would make a lie seem plausible and credible. 
3 
don't remember the exact day when her affidavit came 
4 
And I think that any reasonable lawyer reading that 
4 
in. I referred obviously to the pleadings. That 
5
affidavit would have come to exactly the same 
5 
was the allegation, the allegation in the pleadings. 
6 
conclusion that I came to. 
6 
So if I said that you and Cassell sat and 
7 
SPECIAL MASTER P0ZZUOL1: Okay. 
7 
helped her make it up. it was based on -- at that 
8 
BY MR. EDWARDS: 
B 
point in time, based on you and her. primarily you 
9 
Q. Mr. Dershowitz, when you first made the 
9 
and Cassell. because she didn't submit -- it wasn't 
10
statement on January 4..2015 that Mr. Cassell and 
10 
an affidavit at that point. 
11 
Brad Edwards had participated in the fabrication of 
11 
It was your words. you. that were accusing 
12 
these allegations. did you have before you any 
12 
me of these heinous crimes without any basis. So I 
13
affidavit or, as you have repeatedly called it, 
13 
surely had a basis on January 4th of attributing it 
14 
deposition of 
14 
to you because it was your signature on the —
15 
MR. SIMPSON: Object to the form. It's 
15 
SPECIAL MASTER POZZUOLI: Hold on a 
16 
referring to a specific statement that has not 
16 
second. So I understand. the question is what 
17 
been identified for the witness. 
17 
did you have on January 4th —
18 
A. Affidavit of 
' What I had 
18 
MR. EDWARDS: -- 2015 to support that 
19
was the lawyers statements that were included in 
19 
statement. 
20 
the Complaint, which they then sought to publicize 
20 
SPECIAL MASTER POZZUOLI: Just answer that 
21
all around the world and got more than a thousand 
21 
question first and then you can explain. but —
22
newspapers to cover the story. every television 
22 
A. With due respect. Your Honor. I think the 
23 
station in the world. every radio station virtually 
23 
question was, did you have the affidavit in front of 
24 
in the world. based on what they themselves had 
24 
you. 
25 
written. actually gives me even a greater basis. 
25 
662 
1 
because it wasn't at that point based on her 
1 
BY MR. EDWARD$: 
2 
affidavit, it was based on what the lawyers had 
2 
Q. Right. Okay. Did you have the affidavit 
3
said. 
3
or deposition of 
on that day? 
4 
MR. EDWARDS: I object. Can I have the 
4 
A. To my recollection. I did not. 1 had only 
5 
question read back. I'm lost as to what the 
5 
your characterization of the accusation which you 
6 
question is anymore. 
6 
were making against me. 
7 
SPECIAL MASTER POZZUOLI: Ask — reread 
7 
Q. And in your experience as an attorney, 
8 
the question. 
8 
isn't it common knowledge that attorneys drafting 
9 
COURT REPORTER: 'Mr. Dershowitz. when you 
9
complaints or pleadings take the word of the client 
10 
first made the statement on January 4. 2015 
10 
to form the basis of that Complaint or pleading? 
11 
that Mr. Cassell and Brad Edwards had 
11 
A. No. it's not common knowledge. It's 
12 
participated in the fabrication of these 
12 
common knowledge that unethical lawyers of the kind 
13 
allegations. did you have before you any 
13 
that your reputation told me you were help the 
14 
affidavit or. as you have repeatedly called it. 
14 
clients —
15 
deposition of 
r 
15 
MR. EDWARDS: I object. Move to strike as 
16 
BY MR. EDWARDS: 
16 
nonresponsive. 
17 
Q. Did you? 
17 
SPECIAL MASTER POZZUOLI: That. I am going 
18 
SPECIAL MASTER POZZUOLI: So that's the 
18 
to strike. Try -- try to answer the question. 
19 
question. Answer that question only. 
19 
A. But I think the generic answer is ethical 
20 
MR. SCAROLA: Move to strike everything 
20 
lawyers — let me put it this way. ethical lawyers 
21 
else he's said. 
21 
should not elaborate on what a client tells them in 
22 
A. On January 4th. to my memory. I did not 
22 
an affidavit. 
23 
refer to a deposition or to whatever other word you 
23 
In my experience. there's a continuum. 
24 
used -- what was the word? 
24 
Many. many lawyers. when they see a statement by a 
25 
MR. SIMPSON: Affidavit. 
25 
client they'll say. no. no. no. no. could you 
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please elaborate on that. You say you had sex with 
1 
MR. INDYKE: Instruct Alan not to answer 
2 
him. Was it one time? Was it two times? Could it 
2 
to the extent it would disclose communications 
3 
have been six times? Could it have been on the 
3 
of who made those —
4 
airplane? Could it have been -- et cetera. 
4 
SPECIAL MASTER PO'CLUOLI: Objection noted. 
5 
So I think it's a continuum of the way 
S 
You can answer it. 
6 
lawyers work with clients. The most ethical lawyers 
6 
A. What framework are you giving me in terms 
7 
don't change what a client says. They word for word 
7 
of time? 
8 
repeat what the client says. 
8 
SPECIAL MASTER PO'CLUOLI: In January. 
9 
The most unethical lawyers will put all of 
9 
BY MR. EDWARDS: 
10 
their own thoughts. words. ideas if it strengthens 
10 
Q. You told me that before you made these 
11 
their position and strengthens their case. 
11 
statements. one of the things that you had in your 
12 
From what I had been -- from the 
12 
possesskm was a series of phone calls. "a bunch of 
13 
information I knew at that time. I put you on the 
13 
people called me" —
14 
extreme unethical end of the continuum. 
14 
A. That is right. That's true. 
15 
SPECIAL MASTER POZZUOLI: That wasn't the 
15 
Q. -- "and told me Brad Edwards participated 
16 
question. so I will strike the last sentence. 
16 
in major fraud with Rothstein." That's the first 
17 
We need to get focused on answering the 
17 
question I want answered. What are the names of 
18 
question. so please try to do that. 
18 
those people? 
19 
A. Okay. I will do that. 
19 
A. A number of them who called me were ones 
20 
BY MR. EDWARDS: 
20 
who volunteered —
21 
Q. When you first made the statements that 
21 
MR. SCAROLA: That's not a response to the 
22 
Paul Cassell and Brad Edwards fabricated the 
22 
question. 
23 
allegations — 
23 
BY MR. EDWARDS: 
24 
A. Would you read me the statement that you 
24 
Q. What are the names? 
25 
say I made on January 4th so I can understand what 
25 
SPECIAL MASTER POZZUOLI: Stop. stop. 
666 
668 
1 
rem saying? 
1 
please. please. please. 
2 
Q. Do you deny making the statement that Brad 
2 
A. I'm invoicing the privilege, if you would 
3
Edwards and Paul Cassell fabricated the allegations 
3
allow me. please. A number of those who called me 
4 
against you? 
4 
called me in tandem to volunteer to be my lawyer. 
5 
A. I remember making a series of statements 
5 
I'll give you an example. 
6 
over time. I do not remember what I said on 
6 
SPECIAL MASTER PUELUOLI: No. no. hang on. 
7
January 4th. In order to ask me what I had at the 
7 
A. I can't name this person because he called 
8
time I made the statement. I need to know with 
8 
to give me legal advice. and I — he gave me that 
9 
precision the exact statement you are referring to 
9
information as pan of his legal advice. 
10
and the exact date. I think that's a fair request. 
10 
BY MR. EDWARDS: 
11 
Q. We'll get that for you. It would be 
11 
Q. I'm not asking if one of the lawyers who 
12 
easier had you made less statements, but we'll sift 
12 
represented you and you have an attorney-client 
13
through them. 
13 
privilege with has shared with you some information 
14 
A. If would be easier if you had called -- 
14 
that they believe to he the case. 
15 
MR. SIMPSON: There's no question. Object 
15 
I'm asking if you are using as support for 
16 
to the sidebar comments. 
16 
your statement that certain people told you and you 
17 
SPECIAL MASTER POZZUOLI: Yes, let's -- 
17 
relied upon this -- and the particular "this" at 
18 
BY MR. EDWARDS: 
18 
this point is that Brad Edward participated in a 
19 
Q. What are the names -- please list for me 
19 
major fraud with Scott Rothstein -- I want to know 
20
all of the names of the people who told you that -- 
20 
the names of those people that you are relying upon 
21 
in quotes -- Brad Edwards was -- participated in a 
21 
to test veracity of that statement, please. Names 
22 
major fraud with Rothstein. Names of people. 
22 
of people. 
23 
MR. INDYKE: Objection based upon 
23 
A. One of the names was of a person who I was 
24 
attorney-client, work product. common interest. 
24 
seeking legal representation from. and it was pan 
25 
SPECIAL MASTER POZZUOLI: Well, okay. 
25 
of my conversation with him regarding legal 
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representation. 
1 
MR. INDYKE: Sane objection. same 
2 
MR. SCAROLA: That's not a name. 
2 
instruction. 
3 
MR. EDWARDS: I'm sorry. I object and I 
3 
SPECIAL MASTER POZZUOLI: He's — 
4 
ask — 
4 
MR. EDWARDS: Calls for a yes or no. 
5 
A. If I give you the name — 
S 
SPECIAL MASTER POZZUOLI: He's only asked 
6 
SPECIAL MASTER POZZUOLI: I do think you 
6 
if you aware that the case was dismissed at 
7 
have to give the name. 
7 
that time. 
8 
A. Okay. The name of that person would be 
8 
A. I don't think I was. But a case being 
9
David Markus. 
9 
dismissed does not mean the allegation isn't true. 
10 
BY MR. EDWARDS: 
10 
SPECIAL MASTER POZZUOLI: 1 understand. 
11 
Q. Okay. 
11 
but --
12 
A. And he told me to check the docket -- 
12 
BY MR. EDWARDS: 
13 
MR. SIMPSON: Just the question. 
13 
Q. Okay. In addition to David Markus, can 
14 
BY MR. EDWARDS: 
14 
you please complete this list of people that you 
15 
Q. When did David Markus call you to tell you 
15 
testified called you to tell you specifically that 
16
that he knew or believed that Brad Edwards 
16 
Brad Edwards participated in a major fraud with 
17
participated in a major fraud with Rothstein? 
17 
Rothstein? 
18 
A. Within days. Within probably a day or 
18 
A. So, I spoke several times during that 
19
two. 
19 
period of time at various events. And people • -
20
Q. Did he tell you what it was that formed 
20 
lawyers came over to me and told me --
21
the basis for that statement that he made to you 
21 
Q. I'm not asking where. Who? What are the 
22 
that you so relied upon? 
22 
names? 
23 
A. I don't recall. 
23 
A. I can tell you one of them --
24
Q. Was it more than the fact that your 
24 
SPECIAL MASTER POZZUOLI: He's trying to 
25 
client, Jeffrey Epstein. had filed a lawsuit making 
25 
be -- I would allow him to answer it. He's 
670 
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1 
those allegations? 
1 
trying to be responsive to the question. 
2 
A. I don't think he was aware that Jeffrey 
2 
Please proceed. 
3 
Epstein had nude an allegation of that kind. 
3 
A. One of them was a Conner president or 
4 
Q. At the time when David Markus called you 
4 
chairman or at least member of the Florida Bar 
5 
to tell you that Brad Edwards participated in a 
5 
committee who warned me about you. 
6 
major fraud with Rothstein did you already — 
6 
BY MR. EDWARDS: 
7 
A. That's not — 
7 
Q. Does he have a name? 
9 
Q. -- have or know that Scott Rothstein had 
8 
A. I dont remember his name. I don't 
9 
testified under oath about that specific subject 
9
remember his name. no. Of course he has a name, but 
10 
matter? 
10
I don't remember his name. 
11. 
A. Well. I cant imagine that mite relying 
11 
Another was — I mean — just hard to 
12 
on Scott Rothstein's credibility. 
12 
pinpoint names. but it was something that was 
13 
Q. I'm asking, did you know? 
13 
clearly in my mind that so many people were telling 
14 
MR. SIMPSON: Just answer the question. 
14 
me -- telling me to look into the case of Rothstein. 
15 
BY MR. EDWARDS: 
15 
telling me that you were his protege. 
16 
Q. Yes or no? 
16 
Q. Okay. Is it true, then, that you have the 
11 
SPECIAL MASTER POZZUOU: Did you know? 
17 
name of one person who you can identify told you 
18 
A. I did not know. 
18 
that Brad Edwards participated in a major fraud with 
19 
BY MR. EDWARDS: 
19 
Rothstein? 
20 
Q. Did you know at that point in time that 
20 
A. I was also aware, of course. of the 
21 
the Complaint that was tiled by your client. Jeffrey 
21 
Complaint that had been filed against you. And that 
22 
Epstein. against Brad Edwards. making those exact 
22 
was one — I mean, I cant comment on that because 
n 
allegations, had been dismissed at the stage -- at 
23 
of lawyer-client privilege. 
24 
the point in time when David Markus was making these 
24 
SPECIAL MASTER POZZUOLI: Listen to the
25 
statements to you that you so relied upon? 
25 
question, Professor. Go ahead. 
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BY MR. EDWARDS: 
1 
MR. SIMPSON: He did not testify that 
2 
Q. Is it now your testimony that you can only 
2 
he — we went through long questions and 
3 
provide me with one name of one human being that 
3 
answers in response to Mr. Edwards' questions. 
4 
called you and told you Brad Edwards participated in 
4 
He did not say he was relying on what his 
5 
a major fraud with Rothstein? 
5 
lawyers told him in this case. 
6 
A. 1 will try to think of others. 
6 
SPECIAL MASTER POZZUOLI: I think that 
7 
Probably -- I may have some notes of others. I will 
7 
there is — let me say this: I think the 
8 
call around and find out whether my memory is 
8 
question was from Mr. Edwards whether he relied 
9 
correct or not. 
9 
on statements from his lawyers. I do think 
10 
MR. SIMPSON: Professor -- 
10 
that you have to answer that question. 
11 
A. But I don't want to mention names without 
11 
A. I would say that the statements from my 
12 
being sure. 
12
lawyers played a small role. The larger role --
13 
MR. SIMPSON: Just do you recall, as you 
13 
BY MR. EDWARDS: 
14 
sit here, the names? 
14 
Q. I want to know about that small role. 
15 
A. And right now. I don't recall names. other 
15 
SPECIAL MASTER POZZUOLI: Hang on one 
16 
than a general discussion with my lawyers. And in 
16 
second. So now proceed. 
17 
the general discussion with my lawyers -- and I 
17 
BY MR. EDWARDS: 
18 
don't want to get into it -- 
18 
Q. Sure. I would like to know whose 
19 
SPECIAL MASTER POZZUOLI: Then don't do 
19 
statements it was that played a small role in your 
20 
it. 
20
belief that Brad Edwards fabricated cases based on 
21 
BY MR. EDWARDS: 
21 
the statements that they made to you that 
22 
Q. Are you relying upon the statements from 
22 
Brad Edwards participated in a major fraud with 
23 
your lawyers to support this allegation that the 
23 
Rothstein. What arc the name of those individuals? 
24 
basis of your statement that Brad Edwards 
24 
A. It's a complicated question here. So 
25 
participated in the fabrication of the allegations 
25 
there are three issues that I understand. One, what 
674 
676 
1 
against you was a list of people told you 
1 
was the basis for my belief that you had fabricated 
2 
Brad Edwards participated in a major fraud with 
2 
along with Mr. Cassell --
3 
Rothstein: and, if so. I want to know the names of 
3 
Q. No, I'm asking for names of human beings. 
4 
those lawyers that you are using to support that 
4 
SPECIAL MASTER POZZUOLI: No. let me stop 
S 
allegation? 
5 
you. My understanding of your testimony was 
6 
SIR. SIMPSON: Well, we have asserted 
6 
that whatever you received — whatever 
7 
privilege as to communications with those who 
7 
information you received from your laws 
8 
represented you. Please dont disclose that. 
8 
played a small role. That's what you testified 
9 
MR. SCAROLA: Respectfully — pardon me — 
9 
to. 
10 
the witness is the possessor of that privilege. 
10 
THE WITNESS: That's right. 
11 
He cannot make a statement disclosing the 
11 
SPECIAL MASTER PUELUOLI: Correctly. 
12 
content of the communications that he is 
12 
Mr. Edwards then followed up on that question 
13 
relying on and then he himself assert a 
13 
and said. let's go into that small role. 
14 
privilege to refuse to provide further 
14 
THE WITNESS: Okay. 
15 
information with regard to the statement that 
15 
SPECIAL MASTER POZZUOLI: So row... 
16 
he has made. We would request a ruling on the 
16 
BY MR. EI)WARI)S: 
17 
record as to whether there has already been a 
17 
Q. What arc the names of those people that 
18 
waiver. 
18 
gave you this information that played a small role 
19 
A. What I said, of course. was that— 
19 
in --
20 
SPECIAL MASTER POZZUOLI: Excuse me. Hang 
20 
A. In what? 
21 
on a second. 
21 
Q. -- in your belief that Brad Edwards had 
22 
MR. SCAROLA: %Vete requesting a oiling on 
22 
participated in a major fraud with Rothstein which 
23 
the record as to whether there has been a 
23 
somehow furthered your belief that Brad Edwards and 
24 
waiver as a consequence of what has already 
24 
Paul Cassell fabricated the allegations against you? 
25 
been stated. 
25 
So I'm asking for names of the people. 
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A. So my best recollection, and its now over 
1 
came over to me and told me -- he may have given me 
2 
a year. is that that was a subject of conversation 
2 
a card. which I conceivably may have at home. told 
3
with David Markus. It was also the subject of 
3
me that he was a former official of the Florida Bar 
4
conversation with — 
4 
and was outraged at what had happened and told rte to 
5 
MS. McCAWLEY: Fm sorry. I didn't hear 
5
please look into your background and then told me 
6 
that. If he's talking about conversations -- 
6
about your background. 
7 
MR. EDWARDS: lie said Davis Markus. 
7 
Q. Dade Markus, Is he a former student f 
8 
MS. McCAWLEY: Fm sorry. I couldn't 
8
yours? 
9 
hear. 
9 
A. Yes, yes. 
10 
A. Another lawyer -- other people sent me 
10 
Q. Did he have anything to do with the 
11 
newspaper clippings. 
11 
investigation into the -- Scott Rothstein or any of 
12 
SPECIAL MASTER POZZUOLI: No. no. no. 
12 
that? 
13 
A. Lawyer. Okay. The other lawyer who told 
13 
A. I don't know. 
14
me about that was a lawyer named David Efron. 
14 
Q. David Efron. did he have any inside 
15 
MR. SCAROLA: First of all. make sure the 
15
personal information into who was or who was not 
16 
list is complete. and then you want to know 
16
culpable in any aspect of the fraud with Scott 
17 
everyone. 
17
Rothstein? 
18 
BY MR. EDWARDS: 
18 
A. I don't know. 
19 
Q. Is that It? David Markus, David Efron? 
19 
MR. SCAROLA: You want to know exactly 
20 
A. Those are the two I remember offhand. 
20 
what they said. 
21 
Plus. as I said. when I spoke -- I spoke 
21 
BY MR. EDWARDS: 
22 
at several events in January — 
22 
Q. Before we go to the next statement that 
23 
Q. Right now -- 
23
apparently formed your basis for believing that 
24 
A. — and lawyers came -- people -- 
24 
Brad Edwards and Paul Cassell fabricated the 
25
lawyers — 
25
allegations against you. can you tell me exactly 
678 
680 
1 
SPECIAL MASTER POZZUOLI: Let me stop you. 
1 
word for word as you remember it what David Markus 
2 
BY MR. EDWARDS: 
2 
and then what David Efron told you —
3
Q. Let me get to the next question. 
3 
SPECIAL MASTER POZZUOLI: Let's start with 
4 
A. Yes. 
4 
the first one. 
5 
SPECIAL MASTER POZZUOLI: Let me ask the 
5 
BY MR. EDWARDS: 
6 
witness, the question is limited to — 
6 
Q. -- what David Markus told you about the 
7 
MR. EDWARDS: Yes, the lawyers who played 
7
participation of Brad Edwards in a fraud with 
8 
a small role. 
8 
Rothstein? 
9 
SPECIAL MAMMA POZZUOLI: The small role 
9 
MR. SINIPSON: We assert privilege to the 
10 
around the lawyers, and I think the followup 
10 
extent that it's someone who he was getting 
11 
question was, you've mentioned a second lawyer. 
11 
legal advice from. 
12 
is there anybody else on that list? 
12 
SPECIAL MASTER POZZUOLI: I'm going to 
13 
BY MR. EDWARDS: 
13 
allow the question. You can answer over 
14 
Q. Yes. 
14 
objection. 
15 
A. Two lawyers. yes. The lawyers who came 
is 
A. Atli can tell you is what the total 
16 
over to me at the events that I spoke at. 
16 
information I had at that point. I can't now, as I 
17 
Q. 14'hat are their names? 
17 
sit here, separate out what Markus said, what Efron 
18 
A. 1 don't know. 
18 
said. what the lawyers who I met at the events said. 
19 
Q. How do you know that they're lawyers? 
19 
I can give you a totality of what the conclusion was 
20 
A. Because it was a lawyers' event. And they 
20 
that was reached. Each of themcontributed 
21 
were trial lawyers. This was all trial lawyers at 
21 
something. 
22 
the event. Florida trial lawyers. 
22 
BY MR. EDWARDS: 
23 
Q. You don't have the names of any of them: 
23 
Q. Where were you when you received this 
24 
is that right? 
24 
communication from David Markus about his 
25 
A. I can describe one of them as somebody who 
25 
understanding or belief that Brad Edwards 
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participated in a major fraud with Rothstein? 
1 
the generalities. but I don't remember the 
2 
A. In my apanntent. I suspect. 
2 
particulars of that. I would be happy to try to 
3 
Q. Do you remember 11th? 
3
refresh my recollection. 
4 
A. 1 remember being in my apartment when the 
4 
MR_ SCAROLA: Were going to take a short 
9 
story broke and getting call after call after call 
5 
break. 
6 
from lawyers. 
6 
VIDEOGRAPHER: Going off the record. The 
7 
Q. Was this a telephone call with David 
7 
time is 9:38 a.m. 
8 
Markus — 
8 
(Recess was held from 9:38 a.m. until 9:45 am.) 
9 
A. Probably. 
9 
VIDEOGRAPHER: Going back on the record. 
10 
Q. — or an in-person meeting? 
10 
The time is 9:45 a.m. 
11 
A. It was -- well, I had both. I had both 
11 
BY MR. EDWARDS: 
12 
with him. I had a telephone call and then we had a 
12 
Q. Did David Markus say Brad Edwards 
13 
meeting. 
13
participated in a major fraud with Rothstein? 
14 
Q. And in this, did he describe to you what 
14 
MR. SCOTT: Objection. work product and 
15 
support he had for this statement that he was making 
15 
privileged. 
16 
to you regarding the involvement of Brad Edwards in 
16 
SPECIAL MASTER POZZUOLI: I'll overrule 
17 
a major fraud with Rothstein? 
17 
the objection. 
18 
MR. SCOTT: Objection. work product on 
18 
MR. SCOTT: I have a question. Are we 
19 
this whole line of questioning. He has the 
19 
taking the position that he has to answer the 
20 
name. If we're going to go beyond this, we 
20 
question now and pending an appeal to the 
21 
need a judicial ruling from the judge and you. 
21 
judge? Is that what were doing? 
22 
SPECIAL MASTER POZZUOL1: Well. I'm going 
22 
SPECIAL MASTER POZZUOLI: Or -- I will 
23 
to allow the witness to answer it at this point 
23 
reserve your right --
24 
and overrule the objection without prejudice. 
24 
MR_ SCOTT: Because you reserved on all 
25 
A. What is the question again? 
25 
their stuff yesterday. 
682 
684 
1 
SPECIAL MASTER POZZUOLI: Well, go back to 
1 
SPECIAL MASTER POZZUOLI: I will reserve 
2 
the question. 
2 
on that. but I want him to answer the question 
3 
COURT REPORTER: 'And in this, did he 
3 
at this point I believe that at this point. 
4 
describe to you what support he had for this 
4 
given the inquiry and given the witness's 
5 
statement that he was making to you regarding 
5 
answers previously, that they've opened the 
6 
the involvement of Brad Edwards in a major 
6 
door, at least to this extent. But I will 
7 
fraud with Rothstein?" 
7 
reserve, but I want him to answer. 
8 
A. I'm sum he told me some information 
8 
A. I will. I do not recall precisely what 
9
involving his state of knowledge. but I can't 
9
David Markus or David Efron said. I do recall that 
10 
separate out now what different people told me. All 
10
they — to the best of my recollection, that they 
11 
I remember is the totality of the conclusion that I 
11
both contributed to my general sense of what your 
12 
reached based on what they told me. 
12 
reputation was. 
13 
BY MR. EDWARDS: 
13 
BY MR. EDWARDS: 
14 
Q. What specifically did he tell you, if you 
14 
Q. I want to only slick with David Markus and 
15 
remember? 
15
then we'll move on to David Efron. 
16 
MR. SCOTT: Same objection standing. I 
16 
A. Okay. 
17 
just wanted to make sure we have a standing 
17 
Q. All right. Did David Markus say anything 
18 
objection. 
18 
along the lines of, close to, Brad Edwards 
19 
SPECIAL MASTER POZZUOLI: I'll give you a 
19 
participated in a major fraud with Rothstein? 
20 
standing objection. I understand that piece. 
20 
MR. SCOTT: Same objection. 
21 
If you don't remember, you don't remember or if 
21 
A. My best recollection is that he said 
22 
you can't describe it. rather than going 
22 
something along those lines. He certainly said 
23 
through again the generalities. so try to 
23 
something that led me to that conclusion. 
24 
answer his specific question. 
24 
BY MR. EDWARDS: 
25 
A. Sure. Okay. The answer is I do remember 
25 
Q. Did he tell you to look into a court file 
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or did he tell you Brad Edwards participated in a 
1 
assistance and to tell me how outrageous he thought 
2 
major fraud with Rothstein? 
2 
this was. And in the count of the conversation. he 
3 
MR. SIMPSON: We have a continuing 
3
mentioned to me that I should be very careful about 
4 
objection on this, and also object to the form 
4 
you. that you had this reputation. and then he told 
5 
of that one. 
5
me some things about your reputation that helped 
6 
SPECIAL MASTER POZZUOLI: Yeah, well, the 
6
form my general impression about who you were and 
7 
form I'm not going to rule on. but the form is 
7
what you would do. 
8 
awkward, at best. 
8 
Q. With respect to the reputation of 
9 
MR. SIMPSON: We just want in the record 
9
Brad Edwards. did he tell you anything beyond 
10 
we have a continuing objection. 
10
describing what he understood to he as facts related 
11 
SPECIAL MASTER POZZUOLI: Yes. 
11 
to the Scott Rothstein fraud? 
12 
BY MR. EDWARDS: 
12 
A. I think he -- others also told me that --
13 
Q. I've heard two statements. One is that 
13 
Q. I'm only talking about David Markus. 
19 
David Markus said to look into a court file. And 
14 
A. Well. I can't separate out completely what 
15 
the other I understood you to say is. David Markus 
15
David Markus told me and what others told me. I 
16 
told me Brad Edwards participated in a major fraud 
16 
for mod the holistic impression based on what a large 
17 
with Rothstein. which is what gave the support for 
17
number of people told me. That's the best I can do. 
18 
the statement that I ultimately made about 
18 
Q. When was your first communication with 
19 
Brad Edwards participating in the fabrication of 
19 
David Markus? 
20 
these allegations. 
20 
A. Oh. probably the day of the allegation or 
21 
So I'm trying to understand, did David 
21 
maybe the day after. But very, very soon 
22 
Markus tell you that Brad Edwards pa 
paled in a 
22 
thereafter. 
23 
major fraud with Rothstein? 
23 
Q. Do you have journal entries indicating the 
29 
SPECIAL MASTER POZZUOLI: You have a 
24 
telephone call that you had with David Markus? 
25 
continuing objection. but you can answer. 
25 
A. I don't journals entries of that kind. no. 
686 
688 
1 
A. To the best of my recollection, it's more 
1 
Q. Do you have phone records that would serve 
2 
than a year ago now, he told me facts that led me to 
2 
as evidence of the telephone call between yourself 
3
conclude that you had participated in a major fraud. 
3
and David Markus? 
4 
He told me. for example. that what 
4 
A. I suspect -- he called me. I remember that 
5 
Brad Edwards — that what Rothstein was selling were 
5 
for sure. He called me. 
6 
ft Edwards cases made up by people who didn't 
6 
Q. Do you have telephone records that support 
7 
exist. 
7 
his can to you? 
8 
He told me --I think it was he who told 
8 
A. I don't know if the telephone records show 
9
me. but I can't be sure. that you were a protege. 
9
who called you. If they do. probably we do. 
10 
that you had offices that were very close to each 
10 
Q. On the days that you claim that you met 
11 
other, that the fraud was very similar to what was 
11
with David Markus, do you have journal citric.  or 
12 
being alleged against me. That's. again. my best 
12 
any other diary notation that would -- that .1 mild 
13 
recollection of a conversation that occurred over a 
13 
serve as evidence of such a meeting? 
14 
year ago. 
14 
A. Ill check. I remember where we net. I 
15 
BY MR. EDWARDS: 
15 
don't remember exactly when. And if I paid for it, 
16 
Q. Did he tell you where he gathered that 
16 
I may have paid for it by credit card. I'll check. 
17
information that you just described to us? 
17
Ill be happy to do that. 
18 
A. He did not. I think he — no, he did not 
18 
Q. Did you meet with David Markus before or 
19 
tell me precisely where he got it from, no. 
19 
after appearing on the Don Lemon show on January 5. 
20 
Q. Did he share with you his own conclusion 
20 
2015? 
21 
that Brad Edwards participated in a major fraud with 
21 
A. I think 1 met with him before. I think I 
22 
Rothstein? 
22 
met with him before. I certainly communicated with 
23 
A. I don't recall that. That's not the 
23 
him before. 
24 
nature of the way a conversation happens. I wasn't 
24 
Q. Was it before your appearance on the Don 
25 
cross examining him. He was calling me to offer his 
25 
Lemon show when David Markus provided you with 
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information that led you to conclude that 
7 
now to strike. 
2 
Brad Edwards participated in a major fraud with 
2 
SPECIAL MASTER POZZUOLI: Hang on. Motion 
3
Rothstein? 
3 
to strike is granted. But here's the issue. 
4 
A. I never said that publicly. of course. on 
4 
Let him identify the document first and lay the 
5
Lemon or any of the other shows. So. you're asking 
5 
predicate down and then go back into the 
6
me a compound question. Was it before I came to 
6 
document. I don't want to tell you how to do 
7
that conclusion that then contributed to my belief 
7 
the deposition. but it makes it cleaner. 
8
that you had worked -- that you had created false 
8 
So. Brad. please have him identify the 
9
testimony? It did 
9 
document first and see what he knows about the 
10 
MR. EDWARDS: What number exhibit are we 
10
document and then now forward. 
11 
up to? 
11 
MR. SIMPSON: I think it's the portion of 
12 
COURT REPORTER: Twenty-five. 
12 
it you're asking about. that's what wete 
13 
MR. EDWARDS: Twenty-five, okay. I'll go 
13 
trying to identify. 
14 
ahead and mark this transcript from the Don 
14 
BY MR. EDWARDS: 
15 
Lemon interview as 25. 
15 
Q. Sure. Well, the first question has 
16 
(Thereupon. marked as Plaintiff 
16 
nothing do with the document. It is. did you appear 
17 
Exhibit 25.) 
17 
on the Don Lemon show January 5.2015? 
18 
BY MR. EDWARDS: 
18 
SPECIAL MASTER POTLUOIJ: That's an easy 
19 
Q. I'm going to show you the interview and 
19 
question. 
20 
particularly the bracketed paragraph. 
20 
A. Yes, yes. 
21 
A. Sure. 
21 
BY MR. EDWARDS: 
22 
Q. Do you see the section that we bracketed 
22 
Q. Okay. In that interview -- can you 
23 
there? 
23 
identify the transcript that you're holding in your 
24 
A. Yeah. Yeah, let me just -- 
24 
hand as a transcript of that interview? 
25 
SPECIAL MASTER POZZUOLI: fin going to 
25
A. It seems like it is. yes. 
690 
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look over your shoulder. 
1 
Q. Okay. And does it seem to accurately have 
2 
THE WITNESS: Sure. 
2
transcribed, to the best of your memory, that 
3 
BY MR. EDWARDS: 
3
interview that you had with Don Lemon? 
4 
Q. Is that a statement that you made on 
4 
MR. SIMPSON: Object to the form. 
5 
January 5, 2015? 
5 
A. Yes. 
6 
A. Let me read into the record what I said. 
6 
BY MR. EDWARDS: 
7 
Q. I'm asking right now is that a statement 
7 
Q. Can you read for us the portions that are 
8 
that you made? 
8
bracketed? 
9 
SPECIAL MASTER POZ7_UOLI: Which statement? 
9 
A. No. because they're out of context. I 
10 
BY MR. EDWARDS: 
10 
refuse to do that. That's what happened yesterday. 
11 
Q. The statement that is bracketed. 
11
and you totally read it out of context. I will read 
12 
MR. SlhIPSON: Can fajta? The record 
12 
it for you in context. 
13 
doesn't reflect what that is. SO the answer 
13 
I will read the question that was asked me 
14 
will be misleading. You can't ask about a 
14 
and I will read the entire answer, but I won't read 
15 
statement that no one knows what it is. 
15
your selected excerpts which mislead everybody in 
16 
BY MR. EDWARDS: 
16
this transcript. No. I won't do that. 
17 
Q. You can read the statement into the 
17 
Q. Okay. 
18 
record, but right now I'm just asking is that -- is 
18
A. Because that would be a lie, and I'm under 
19 
that an accurate transcript of your statement that 
19
oath. So I'll be happy to read the entire thing. 
20 
you're holding in your hand? 
20
MR. SCOTT: Seems like a fair request. 
21 
MR. SIMPSON: Object to the thrm. 
21 
MR_ EDWARDS: If we're going to read 
22 
A. let me respond to that. Yesterday you 
22 
entire transcripts. not just the defamatory 
23 
read transcripts. and it turned out you left out 
23
remarks. we're going to be here all clay. 
24 
absolutely critical exculpatory — 
24
A. We have time. The truth takes time and in 
25 
MR. EDWARDS: Objection. nonresponsive. 
25
full context. 
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SPECIAL MASTER POZZUOLI: Okay. 
1 
A. I think he called me the day of the event. 
2 
MR. SIMPSON: Wait for a question. please. 
2 
the day the story was in the newspapers. 
3 
SPECIAL MASTER POZZUOLI: I believe its 
3 
Q. Would you have calendar entries or 
4 
fair for the question starting -- the question 
4 
telephone records to support the date of that call? 
5 
that starts right above the bracketed where 
5 
A. I don't know about telephone records. I 
6 
Mr. Lemon asks. "So why arc you being targeted! 
6 
don't have a calendar entry. 
7 
As you mentioned the lawyers. why would someone 
7 
Q. Did you meet with David Efron in person or 
8 
target you. Alan Dershowitz. with these very 
8 
only by telephone? 
9 
serious allegations?" And then from there 
9 
A. I did. I met with hint in person. 
10 
down, you don't need to read the whole thing. 
10 
Q. And what did — or did David Efron say 
11 
but I think you'll get your point across that 
11 
Brad Edwards participated in a major fraud with 
12 
way. 
12 
Scott Rothstein? 
13 
MR. EDWARDS: Okay. 
13 
A. Again. I can only say that he gave rte 
14 
SPECIAL MASTER POZZUOLI: That standpoint 
14 
facts and statements that led me to that conclusion. 
15 
would provide some level of context. 
15 
which I stated in the interview. namely that 
16 
A. "Don Lemon: So. why are you being 
16 
Rothstein had sold Epstein cases. and that Edwards 
17 
targeted? As you mentioned the lawyers. why would 
17 
was his partner. and that his reputation was not 
18 
someone target you. Alan DCTS11OWiiI. with these very 
18 
good in the community. 
19 
serious allegations?" 
19 
Q. Did David Efron provide you with the 
20 
My response: 'Well. I fit beautifully 
20 
support for his alleged conclusion that 
21 
into the profile because they want to be able to 
21 
Brad Edward? reputation is not good? 
22 
challenge the plea agreement. and I was one of the 
22 
MR. SIMPSON: Object to the form. Do we 
23 
lawyers who organized the plea agreement. I got the 
23 
have the continuing objection. sir? 
24 
very good deal for Jeffrey Epstein. I plead guilty 
24 
SPECIAL MASTER POZZUOLI: Yes. continuing 
25 
to getting him a good deal. That's my job. And if 
25 
objection. 
694 
696 
1 
they can find a lawyer who helped draft the 
1 
MR. SIMPSON: Thank you. 
2
agreement who was also a criminal having sex. wow. 
2 
A. I think he — I think he either brought me 
3
that could help them blow up the agreement. So they 
3
or told me about some newspaper articles, which I 
4 
sat down together. the three of them, these two 
4 
then read and formed my own conclusion. And he 
5
sleazy. unprofessional. disbanabk lawyers. Paul 
5 
also --
6 
Cassell. a former federal judge and current 
6 
BY MR. EDWARDS: 
7
professor, and another sleazy lawyer from Florida 
7 
Q. Which newspaper articles did David Efron 
8
Brad Edwards, whose partner is in jail for 50 years 
8 
provide you? 
9
to trying to sell Epstein cases fraudulently. they 
9 
A. I don't remember. But I -- at that point 
10
sat down together and they said, who would fit into 
10 
in time. I was not reading the local newspapers, and 
11
this description, a lawyer who knows Epstein who 
11 
apparently there was some large coverage of the 
12 
helped draft. ha. Dershowitz. So they and the woman 
12 
Rothstein matter. 
13
got together and contrived and made this up: 
13 
I didn't really know about the Rothstein 
14 
That is a truthful statement, and I stand 
14 
matter much at all. But when my accusation 
15 
by
15 
occurred. I got lots and lots of calls from people 
16 
SPECIAL MASTER POZZUOLI: Okay. 
16 
telling me about the Rothstein matter and giving me 
17 
BY MR. EDWARDS: 
17
all kinds of information about it. 
18 
Q. In January -- on January 5, 2015, when you 
18 
Q. Wtnn't it within the context of what 
19
made the statement that Brad Edwards and Paul 
19 
you're now describing the Rothstein matter that Jack 
20
Cassell sat down with the woman together and 
28 
Scarola attempted to depose you in 2011? 
21 
contrived and made this up, had you already spoken 
21 
A. I don't recall whether that was the 
22 
with David Efron? 
22 
Rothstein matter. But I wasn't following it. 
23 
A. Yes. 
23 
Q. When you communicated with Mr. Scuola 
24 
Q. Okay. What is the date when you spoke to 
24 
about whether or not you could be subject or would 
25 
David Efron? 
25 
be subject to deposition, are you saying that you 
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1 
had no idea which case — that the case in which you 
1 
instruction. 
2 
were being asked for deposition? 
2 
A. Yeah. I mean. obviously --
3 
A. I wasn't following that case. I was only 
3 
SPECIAL MASTER POZZUOLI: Short of that. 
4 
interested in the fact that I was being asked to be 
4 
A. — I'm not the talking about material. 
5 
deposed on. A. lawyer-client privileged information 
5
much of which I got from lawyer-client privileged 
6 
or. B. facts that weren't true: namely an allegation 
6
information. But I can't talk about that. 
7 
that I had observed young women in the presence of 
7 
So I will talk about another person called 
8 
Jeffrey Epstein. I didn't focus on the nature of 
8
me, I don't remember the date, who had sued you. 
9 
the case at all. 
9
because he said you had --
10 
Q. So did David Efron provide you with 
10 
BY MR. EDWARDS: 
11 
newspaper articles about the Rothstein matter or did 
11 
Q. Wail. We haven't left the Rothstein 
12 
he my Brad Edwards participated in a major fraud 
12
matter yet we're going to move to that --
13 
with Rothstein? 
13 
A. He told me about the Rothstein matter. 
14 
MR. SIMPSON: Object to the form and -- 
14 
Q. Oh, really? Okay. 
15 
object to the form. 
15 
A. Yeah. So he called me and he said. be 
16 
SPECIAL MASTER POZZUOLI: I'm not ruling 
16 
very careful about this sleazy guy Rothstein (sic). 
17 
on the -- those are -- those are reserved for 
17
he was sleazy when he represented me. he helped fake 
18 
later. But I mean -- you should try to ask one 
18 
evidence. he helped doctor a tape. he was sued. it 
19 
question and give him one question at a time 
19 
was dismissed on prosecutorial privilege, but not on 
20 
and break that up. 
20
the merits. And he was also involved in the 
21 
BY MR. EDWARDS: 
21 
Rothstein. and he just gave me also general 
22 
Q. Did David Efron do anything more than 
22 
information about the Rothstein matter, which many. 
23 
provide you with newspaper articles on the Rothstein 
23 
many people gave me. That -- you are burdened with 
24 
matter? 
24 
that as part of your reputation. for better or 
25 
A. Yes. 
25
worse. 
698 
1 
Q. Okay. What specifically did he do in 
1 
Q. I just want the names of the people who 
2 
addition to providing you with -- do or say in 
2 
gave it to you. That's all I'm asking. 
3 
addition to providing you with newspaper articles 
3 
A. I don't remember his name. hut you would 
4 
about the Rothstein matter? 
4 
know his name, the man who sued you. 
5 
A. To the best of my recollection. this is a 
s 
Q. Okay. What facts specifically were you 
6 
year-old conversation he told me that you were all 
6 
given or were given to you by David Markus or David 
7 
tied up in the Rothstein matter. that this was — 
7 
Efron or anyone else regarding Brad Edwards 
a 
involved your whole firmt that you were a protege of 
8 
participating in a major fraud with Rothstein? 
9 
his, and that the firm was selling Epstein taus and 
9 
A. I would like to answer that question. 
10 
defrauding lots and lots of people. That's the 
10 
MR. INDYKE: Same objection. same 
11 
general thrust of what he told roc. 
11 
instruction. 
12 
Q. Just so I'm clear. did he -- are you 
12 
SPECIAL MASTER POZZUOLI: Let me stop for 
13 
saying he shared with you his conclusion that 
13 
a second. You can answer it. but I think we've 
14 
Brad Edwards was involved in the Rothstein fraud? 
14 
plowed this ground some. So go ahead. 
15 
MR. SIMPSON: Object to the form. 
15 
A. Let me answer it. I was told that you 
16 
A. I wouldn't use the term -conclusion.* 
16 
were his protege. that you were Rothstein's protege. 
11 
That's not the way conversations occur. He gave me 
17 
That the two of you were essentially joined at the 
18 
bets front which I drew my own conclusion. 
18 
hip. or were inseparable. That you had offices near 
19 
BY MR. EDWARDS: 
19 
each other. That Rothstein didn't do anything 
20 
Q. Is there anyone else whose name you can 
20 
without conferring with you. That you were "the 
21 
provide us today in addition to David Markus and 
21 
brains of the operation." he was the rainmaker, you 
22 
David Efron that provided you information from which 
22 
were the brains of the operation. 
23 
you concluded that Brad Edwards participated in a 
23 
I was told that the case for which he went 
24 
major fraud with Rothstein? 
24 
to jail for 50-something years involved Epstein. 
25 
MR. INDYKE: Same objeaion. same 
25 
That you had kind of jointly worked on Epstein 
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mattes. That I was -- let me see what else. 
1 
testified in your deposition? 
2 
Mars the thrust of it. That was the thrust of it. 
2 
Q. No, I'm asking you. 
3 
BY MR. EDWARDS: 
3 
A. I certainly have absolutely no memory of 
4 
Q. Who told you that Scott Rothstein and 
4 
that. Where would that have been? When would it 
5
Brad Edwards were "joined at the hip"? 
5 
have been? 
6 
A. I heard that probably from more than one 
6 
Q. Just answer, were you sitting at the 
7
person. 
7 
table? 
8 
Q. Then give me more than one pennies name. 
8 
A. I have no mentor• of that whatsoever. 
9
That's fine. 
9 
Q. Okay. Okay. Who told you that —
10 
A. I daft remember specifically who told me 
10 
A. But if I was --
11 
that but that certainly came out of my 
11 
Q. -- Scott Rothstein --
12 
conversations with the various lawyers. that you 
12 
A. --I would like to see the transcript. 
13
were very close. 
13 
SPECIAL MASTER POZZUOLI: Hang on a 
14 
Q. Were you aware of my deposition being 
14 
second. 
15
taken in Mr. Scarola's office on the subject matter 
15 
BY MR. EDWARDS: 
16 
of the Jeffrey Epstein suit against me and my 
16 
Q. Who told you that Scott Rothstein didn't 
17
countersuit that related to the Rothstein matter 
17 
do anything without conferring with Brad Edwards? 
18
you're referring to? 
18 
A. I heard that routinely front a number of 
19 
MR. INDYKE: Same objection• same 
19 
people. that you were his brains. 
20 
instruction. 
20 
Q. Can you please provide the names of those 
21 
SPECIAL MASTER POZZUOLI: Well, short of 
21 
number of people that told you that Scott Rothstein 
22 
that objection. I didn't -- I didn't understand 
22 
did not do anything without me? 
23 
the question. 
23 
A. That would require going into privilege. 
24 
MR. EDWARDS: I'm -- 
24 
MR. SCAROLA: We would like a ruling on 
25 
SPECIAL MASTER POZZUOLI: If you 
25 
whether there has been a waiver with respect to 
702 
704 
1 
understood it. you can answer. But I didn't 
1 
that privilege as a consequence of having 
2 
understand the question. 
2 
disclosed the content of this information. 
3 
MR. SIMPSON: Object to the form. Nor did 
3 
MRANDYKE: If Mr. Dershowitz is 
4 
I. 
4 
referring to Mr. Epstein. then I would object 
5 
BY MR. EDWARDS: 
5 
to — 
6 
Q. So you testified that you were not really 
6 
SPECIAL MASTER POZZUOLI: Did you gel 
7
aware of the Rothstein matter: is that right? 
7 
that'? 
8 
A. Yes. 
8 
COURT REPORTER: No. 
9 
Q. And my question is. when my deposition was 
9 
SPECIAL MASTER POZZUOLI: Can you repeat 
10
taken in that matter, were you aware of the fact 
10 
the -- I want to make sure that we get the 
11
that my deposition was taken? 
11 
record clear. 
12 
A. I think so. I think I was. yes. 
12 
Go ahead and repeat your objection on the 
13 
Q. And how were you aware of the fact that my 
13 
phone. Darren. 
14 
deposition was taken? 
19 
MRANDYKE: If Mr. DLTS11OWiii. by 
15 
MR. INDYKE: Same objection. saris• 
15 
referring to privilege, is referring to 
16 
instruction. 
16 
anything that he may have learned through his 
17 
BY MR. EDWARDS: 
17 
representation of Mr. Epstein or through a 
18 
Q. And were you aware of the testimony that I 
18 
common interest agreement with Mr. Epstein. 
19
provided at that deposition? 
19 
then I would object to disclosure of the 
20 
A. Not the details of it. certainly. 
20 
contents. 
21 
Q. Weren't you sitting at the table as I 
21 
MR. SCOTT: We also object on work product 
22 
testified for my deposition? 
22 
because this is whole new area now, and I don't 
23 
A. No. 
23 
think there's been any waiver. 
24 
Q. You weren't? 
24 
SPECIAL MASTER PO72UOLI: Well. fm going 
25 
A. I was sitting at the table when you 
25 
reserve, consistent with yesterdays rulings. 
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that we will protect the privilege for now and 
1 
was told. But I was told that by a number of 
2 
we'll reserve for a later fuller discussion on 
2 
people --
3 
this. So well mark this and we'll move 
3 
Q. Did —
4 
forward. 
4 
A. — using different phrases. 
5 
MR. EDWARDS: Okay. 
S 
Q. Can you provide me the name of the number 
6 
BY MR. EDWARDS: 
6 
of people that are outside of any of the common 
7 
Q. At the time when you were told that Scott 
7 
interest or attorney-client privilege that told you 
8 
Rothstein did not do anything without conferring 
8 
Brad Edwards was the brains behind the Scott 
9 
with Brad Edwards. were you representing Jeffrey 
9 
Rothstein operation? 
10 
Epstein? 
10 
A. I cant give you a name of somebody who 
11 
A. Yes. 
11 
said those precise words outside the privilege. 
12 
Q. Wind were the circumstances of your 
12 
Q. Can you give me the name of somebody who 
13 
learning that information that Scott Rothstein did 
13 
said words similar to that effect outside the 
19 
not do anything without conferring with 
14 
privilege? 
15 
Brad Edwards? 
15 
A. As I sit here now. I cannot. But I will 
16 
MR. INDYKE: Sante objection. same 
16 
try to refresh my recollection. 
17 
instruction. 
17 
Q. Okay. You also testified that you spoke 
18 
SPECIAL MASTER POZZUOLI: If you can 
18 
with somebody that told you Brad Edwards fabricated 
19 
answer outside the privilege. 
19 
evidence as a prosecutor. 
20 
A. There's nothing outside of the privilege. 
20 
A. That's right. That's right. 
21 
SPECIAL MASTER POZZUOLI: So I would say 
21 
Q. What is the name of that person that told 
22 
the following: I'm going to. for now. grant 
22 
you that information? 
23 
the objection. consistent with yesterday. and I 
23 
A. You know that. I don't. As I'm sitting 
24 
think we need to either -- whether it's in 
24 
here today. I have no memory. But we can get that 
25 
front of me or in front of Judge Lynch. fully 
25 
for you. You, of course, know the name. 
706 
708 
1 
explore the timing of what -- the tinting of 
1 
Q. Why do you say that I know the name? 
2 
when -- the timetable you're inquiring relative 
2 
A. Because he sued you. 
3 
to his representation and the scope of that 
3 
SPECIAL MASTER PO2ZUOLL This is not —
4
representation to best determine whether there 
4 
Mr. Dershowitx. answer the question that's been 
5 
was a privilege and if it exists. So for 
5 
asked and let's not have crosstalk. 
6 
now — 
6 
A. I do not know the name. 
7 
MR. INDYKE I'm sorry Your Honor, just 
7 
BY MR. EDWARDS: 
8 
for the record, as well as any kind of common 
8 
Q. At our next break, can you get us the name 
9 
interest agreement as well. 
9
of this individual? 
10 
SPECIAL MASTER POZZUOLI: Fine. 
10 
A. I will try. I will try. 
11 
BY MR. EDWARDS: 
11 
Q. When did you have a conversation with this 
12 
Q. The last statement that you testified you 
12 
individual that told that you Brad Edwards 
13 
were told was that Brad Edwards was the brains 
13
fabricated evidence as a prosecutor? 
14 
behind the Scott Rothstein operation. 
14 
A. Shortly after the allegations in my cast. 
15 
A. That's right. 
15
he called me. 
16 
Q. Who outside of the privilege that you have 
16 
Q. Did you meet with this person? 
17
with Jeffrey Epstein told you that information? 
17 
A. I did not. But -- I did not. 
18 
A. Well, outside the privilege and outside of 
18 
Q. Did you attempt to ascertain the 
19 
common interest privilege and joint defense 
19
truthfulness --
20 
privilege. 
20 
A. Yes. 
21 
Q. Outside of the privileges -- 
21. 
Q. — of this —
22 
A. All those three privileges. 
22 
MR. SCOTT: Listen to the question. 
23 
Q. Yes. 
23 
SPECIAL MASTER PO2ZUOLI: Listen to the 
24 
A. I don't have any distinct -- I can't 
24 
question. 
25 
separate out necessarily the sources of everything I 
25 
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1 
BY MR. EDWARDS: 
1 
Brad Edwards. I don't -- I didn't focus an any 
2 
Q. — of this individual's statements that 
2 
other people who might have been sued. But I did 
3
Brad Edwards fabricated evidence as a prosecutor? 
3
focus on Brad Edwards and I did get the pleadings. 
4 
A. I did. 
4 
and last year early in the year I read them. I --
5 
Q. What did you do to -- 
5
my research assistant went through all the 
6 
6 
pleadings. Ether he or I or both of us viewed the 
7 
Q. What did you do to ascertain the 
7
videotape together. He note me some note about it. 
8
truthfulness of this gentleman's statements that 
8
And I came to the conclusion that the lawsuit was a 
9
Brad Edwards fabricated evidence as a prosecutor? 
9 
very valid one. 
10 
A. I obtained all of the pleadings that I 
10 
Q. Was that note that you just described a 
11 
could in the case. including the tampered videotape. 
11
part of that conclusion that you reached? 
12 
I obtained the expert analysis of the videotape. I 
12 
A. No. the note was probably just. here is 
13
think I personally viewed the videotape. It was a 
13
the video. here is this. here is that. It was 
14 
jail videotape. 
14 
just -- my recollection of the note, it was just an 
15 
And I came to my own independent 
15
inventory of some kind. 
16
conclusion that the videotape had been tampered 
16 
Q. Did you read the jury trial transcript 
17
with. that the defendant had been denied his due 
17
from the criminal case you're referring to? 
18
process rights. and that he would have prevailed in 
18 
A. Well, the civil case had no jury. had no 
19
that lawsuit but for prosecutorial immunity. 
19
trial. It was dismissed. The criminal case, I 
20 
MR. SCAROLA: Could we inquire as to 
20
don't remember if I read the jury trial or if my 
21 
whether these materials that Mr. Dershowitz 
21 
research assistant did or -- I just don't remember 
22 
contends he relied upon have been disclosed in 
22 
that. I do remember reading the pleadings. which 
23 
discovery in this case in response to 
23 
included excerpts from the trial. 
24 
production requests that clearly would have 
24 
Q. Did you read any of the transcripts from 
25 
called for that production? 
25 
the testimony regarding that defendant's motion for 
710 
1 
MR. SIMPSON: I don't -- I will answer 
1 
ineffective assistance of counsel? 
2 
that question at a break. I'm not agreeing 
2 
A. No. not that I can recall. 
3 
whether it's called for or not called. but I 
3 
Q. Did you read any of the transcripts from 
4 
don't have a microscopic memory of everything 
4 
the hearing on that defendant's complaints about 
5 
that's been produced in the case. But 
5 
misconduct on behalf of the City of Hollywood Police 
6 
certainly if it was called for and it was 
6 
Department or any others? 
7 
responsive, it was either produced or is on a 
7 
A. I did —I do remember reading about the 
8 
privilege log. 
8 
fact that the actual physical tampering was done by 
9 
SPECIAL MASTER POZZUOLI: Let's deal with 
9
the Hollywood Police Depanment. But the 
10 
that at break between you guys. Go ahead. 
10
allegation. to my best of my memory. it's been a 
11 
BY MR. EDWARDS: 
11
long time now, was that you covered it up or played 
12 
Q. Is the person you are referring to Donald 
12 
a role in it. 
13 
Baker? 
13 
Q. Did you review the criminal record of this 
14 
A. 1 don't have his name in my mind. but I 
14 
individual that provided you with the information 
15 
can find that out. 
15 
that Brad Edwards fabricated evidence as a 
16 
Q. Is this the lawsuit where the person sued 
16 
prosecutor? 
17
Michael Satz. Judge Micheal Gates. the entire 
17 
A. I don't remember reviewing his criminal 
18 
Hollywood Police Department, and in that list of 
18 
record. I do recall that the crime itself — no. I 
19 
defendants included the prosecutors of the case. 
19 
just -- I don't remember reviewing his criminal 
20 
which was Brad Edwards and some other prosecutor I 
20 
record. I may very well have. but I don't remember 
21 
don't remember the name? 
21 
it now. 
22 
A. That's not my recollection. 
22 
Q. When you say you do remember rut icy. ing the 
23 
Q. Is your recollection that this is a 
23 
crime itself, the crime was a battery on a law 
24 
lawsuit that was filed against Brad Edwards alone? 
24 
enforcement officer. Is that what you remember? 
25 
A. My focus was on the lawsuit filed against 
25 
A. My recollection is that in the course of 
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being arrested. he was accused of resisting arrest. 
1 
this gentleman was sentenced to prison after the 
2 
That's my best recollection. I may have that wrong. 
2 
jury verdict finding him guilty of battery on a law 
3
And that he complained that they cut off -- that he 
3
enforcement officer? 
4 
was assaulted and he was only defending himself, and 
4 
A. My recollection is that he was offered a 
5
that they cut off the video at the point that would 
5
plea if he would withdraw his lawsuit, and that he 
6
show the complete context. That's my best 
6 
refused to withdraw his lawsuit. I think that was 
7
recollection. And it's. again. a long time ago. 
7
part of his Complaint. that he was coerced, that 
8 
Q. Did you or your representative Initiate 
8
there was an effort to try to coerce him into 
9
the contact with this individual who -- 
9
pleading guilty. But again. these were all matters 
10 
A. No. 
10
of rccord, and its a year ago. so my recollection 
11 
Q. -- claimed that Brad Edwards fabricated 
11
is not as clear. 
12 
evidence as a prosecutor? 
12 
Q. What documents do you have to support that 
13 
A. No. no. To my knowledge and my 
13
this gentleman was offered a plea in exchange for 
14 
recollection, he initiated the contact. 
14
him agreeing to withdraw a lawsuit? 
15 
Q. Is this — did this individual's criminal 
15 
A. That was my memory. 
16 
record include a first-degree murder conviction? 
16 
Q. In order for that to be the case, wouldn't 
17 
A. Certainly I was not aware of that. if it 
17 
you agree that his lawsuit must have preceded his 
18 
did. 
18
jury trial in order for your logic to be correct? 
19 
Q. Did -- in your review of this record -- 
19 
A. Of course not. Of course not, no. Why 
20 
A. I would find that hard to believe. 
20
would that be? A lawsuit almost certainly -- he may 
21 
SPECIAL MASTER POZZUOLI: Listen. 
21 
have threatened a lawsuit previously and it was part 
22 
A. He was out on the street when he called 
22 
of a -- my understanding. again. it's long time ago. 
23 
me. 
23
was that there was -- there were plea bargaining 
24 
BY MR. EDWARDS: 
24 
efforts after he was convicted and that there 
25 
Q. Do you remember whether or not this 
25 
were -- this is just my memory of a long time ago --
714 
716 
1
defendant was sentenced to prison after his 
1 
that the — that they would give him a consideration 
2 
conviction? 
2
in sentencing if he didn't go through with his 
3 
A. I'm confused. Is the conviction you're 
3
threat to bring a lawsuit. That was my 
4 
referring to after the events at issue? 
4 
recollection. 
5 
Q. The conviction of battery on a law 
5 
Q. In addition to talking to this particular 
6
enforcement officer, the case I prosecuted. 
6 
individual who told you that Brad Edwards fabricated 
7 
A. Did that take place before or after his 
7 
evidence as a prosecutor —
S 
alleged conviction on a murder charge? 
8 
A. Right. or participated in the fabrication. 
9 
Q. Well after. 
9 
Q. -- did you speak to anyone else that was a 
10 
A. So. what you're asking me. if I knew about 
10
representative of his or his attorneys that 
11
a prior earlier first-degree murder conviction? 
11
corroborated that allegation? 
12 
Q. Sure. My first question is, did you know 
12 
A. Representative of his? 
13
about a prior earlier first-degree murder conviction 
13 
Q. Anybody other than -
14 
of this person whose word you're accepting that 
14 
SPECIAL MASTER ROZZUOIJ Thai tin: 
15
Brad Edwards fabricated evidence as a prosecutor? 
15 
question. yes. 
16 
Did you know about that? 
16 
A. Not to my recollection. no. 
17 
A. I was not accepting his word. I'm aware 
17 
BY MR. EDWARDS: 
18
of how to be skeptical about words. I did an 
18 
Q. Have you — has anyone other than this 
19
independent evaluation of the evidence, then canner to 
19 
particular person you have identified told you that 
20
my conclusion. 
20 
Brad Edwards fabricated evidence as a prosecutor? 
21 
Q. Were you aware of this gentleman's prior 
21 
A. That's a conclusion -- first of all. I 
22 
murder conviction? 
22 
never, as fax as I remember. never publicly stated 
23 
A. I'm not aware of it as I sit here now. no. 
23 
that. I've told you that that was pan of what went 
24 
I don't think I was. 
24 
into my conclusion about your reputation and record 
25 
Q. Are you aware as you sit here now whether 
25 
and background. 
18 (Pages 713 to 716) 
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717 
719 
1 
But the question again? 
1 
no to a question that clearly can be answered 
2 
Q. Right. A person's name. Tell me what 
2 
with a "yes' or "no" or "I dont remember"? 
3 
other -- what other individual, if anyone, has ever 
3 
SPECIAL MASTER PO'CLUOLI: Before anybody 
4 
told you Brad Edwards fabricated evidence as a 
4 
objects to his answrr, let's see what he says. 
5 
prosecutor. 
S 
Go ahead, and then well work backwards. 
6 
A. I did not rely on his statement to me of 
6 
A. What's the question again? Just repeat -
7 
that. I did my own research. came to my own 
7 
BY MR. EDWARDS: 
8 
conclusion about the facts based on my review of 
8 
Q. Sure. Did you attempt to contact 
9 
the — 
9 
Brad Edwards or any representative of Brad Edwards 
10 
MR. EDWARDS: Object. Move to strike as 
10 
to talk to him about any allegation of misconduct on 
11 
Nonresponsive. 
11 
his part before you relied on those allegations from 
12 
SPECIAL MASTER POZZUOLk Stay focused on 
12 
these individuals you have identified? 
13 
the question being asked. 
13 
SPECIAL MASTER POrLUOLI: So. I've heard 
14 
A. No other name -- no other person told me 
14 
the question. I do think that it's either yes 
15 
that. I did it on the basis of my own research. 
15 
or no. and I'm going to allow you full latitude 
16 
BY MR. EDWARDS: 
16 
to explain. So please proceed in that manner. 
17 
Q. Can you tell me the names of all of the 
17 
A. It's no with an explanation. 
18 
individuals that told you Brad Edwards has a 
18 
SPECIAL MASTER PO'CLUOLI: Go ahead. 
19 
terrible reputation? 
19 
A. Because I was not making these allegations 
20 
MR. INDYKE: Objection. Same objection. 
20 
public, as you made your allegations against me 
21 
BY MR. EDWARDS: 
21 
public without calling me, because I was not making 
22 
Q. Outside of the attorney-client privilege, 
22 
these allegations public, because I was only using 
23 
the joint defense privilege and any other privileges 
23 
them as part of my own internal work product. my own 
24 
that you maintain with Jeffrey Epstein. Chislaine 
24 
internal dynamic. my own thinking process. I didnt 
25 
Maxwell or anyone else a part of that agreement. 
25 
think it was necessary for me to call you and ask 
718 
720 
1 
MR. SIMPSON: Object to the form as 
1 
you about it. And so I did not. 
2 
becoming very redundant. 
2 
BY MR. EDWARDS: 
3 
SPECIAL MASTER POZZUOLI: You can answer. 
3 
Q. Did you attempt to contact Brad Edwards or 
4 
A. Several people who came to me at these Bar 
4 
any agent of Brad Edwards to talk to him before 
5 
meetings told me that, and I just heard it from 
5 
making the allegation that "Brad Edwards and Paul 
6 
many. many people who called me. 
6 
Cassell and 
sat down together, the 
7 
BY MR. EDWARDS: 
7 
three of them, these two sleazy, unprofessional. 
8 
Q. Okay. I'm -- 
8 
disbarrable lawyers, they and the woman got together 
9 
A. But Pm having difficulty coming up with a 
9
and contrived and made this up"? 
10 
specific name. I will check to sec if I have any 
10 
k 
Well --
11 
notes. 
11 
Q. Yes or no? 
12 
Q. I just want the list of those many, many 
12 
A. The answer to that is with Brad Edwards. 
13 
people in response to this question that told you 
13 
no. With Cassell. it would be a different answer a 
14 
Brad Edwards has a terrible reputation. 
14 
you want to ask me about that. 
15 
A. Okay. And I. right now, cannot name any 
15 
Q. All right. Okay. Prior to January 5, 
16 
person other than the information that I have 
16 
2015, making the statement that they. Brad Edwards 
17
already provided you. 
17 
and Paul Cassell. and the woman got together and 
18 
Q. Did you ever attempt to contact 
18 
contrived and made this up. did you contact Paul 
19 
Brad Edwards or any representative of Brad Edwards 
19 
Cassell? 
20 
to talk to him about any allegation of misconduct on 
20 
A. 1 tried to reach out to Paul Cassell 
21 
his part before you relied on these allegations you 
21 
through a number of mutual acquaintances, and was 
22 
received? 
22 
told that he had no interest in having any 
23 
A. This will require — I can't do this yes 
23 
conversation with me. 
24 
or no. I can only do this with an explanation. 
24 
Q. Tell me the dale that you first reached 
25 
MR. SCAROLA: Could we start with a yes or 
25 
out to Paul Cassell through anyone. 
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721 
723 
1 
A. I don't recall the date. 
1 
under seal. And our position is that the 
2 
Q. Is it your testimony that the date you 
2 
individuals who need to be present at that 
3
tried to reach out to Paul Cassell preceded 
3 
deposition are the panics in this case. so the 
4
January 5,2015, when you made the statement that 
4 
actual — Brad and Paul. their lawyers. and 
5
Brad Edwards and Paul Cassell and this woman got 
5 
Mr. Dershowitz and his lawyers. 
6 
together and contrived and made this up? 
6 
No other individuals: for example. 
7 
A. That will require a "no- answer and an 
7 
Mr. Dershowitis wife or anybody else can be 
8
explanation. Okay. The explanation is that before 
8 
present at that deposition. It's a deposition 
9
you made your false allegation against me. you had 
9 
of who we contend is a sex abuse victim. It 
10
months and months and months to reach out and do all 
10 
should be closed and sealed, and nobody else 
11 
the checking. 
11 
should be present. 
12 
I was in an emergency situation. I was 
12 
SPECIAL MASTER POELUOLI: Do you not want 
13
getting calls. probably a hundred a day. from every 
13 
me there? 
14 
media in the world asking me to respond immediately. 
14 
MS. McCAWLEY: I do want you there. 
15
And I had to respond at that point based on the best 
15 
Sony. 
16 
information I had available to me. I could not hire 
16 
MR. SIMPSON: Our position is that 
17
an investigator. I could not conduct a massive 
17 
Professor Dershowitis wife should be permitted 
18
research operation. I was being accused of the most 
18 
to attend. They're married. Shell agree to 
19
heinous crime imaginable. absolutely falsely. and I 
19 
whatever confidentiality. She's worked with 
20 
had to respond immediately. 
20 
him on the case as a paralegal. She's entitled 
21 
And my response was based on my state of 
21 
to be there. 
22 
knowledge. my opinion. my professional opinion. and 
22 
We have advised -- and I don't know if 
23 
I gave those at the time because I had to give a 
23 
Darren is still on the line -- counsel for 
24 
response immediately. I couldn't say "no comment.' 
24 
Mr. Epstein that it's confidential and that 
25 
I couldn't say.1 refuse to answer." Others have 
25 
non-parties are net permitted to attend. per 
722 
724 
1 
done that. I was totally. totally innocent. And I 
1 
Ms. McCawley's position that its between those 
2
had to respond immediately to these false charges. 
2 
folks if they disagree about that. But as to 
3
which is what I did. 
3 
Mrs. Cohen. we're adamant she has a right to he 
4 
I need to take a break. 
4 
there and there's no legitimate basis for 
5 
MR. SCOTT: Take recess for a couple of 
5 
excluding her. 
6 
minutes. 
6 
SPECIAL MASTER POZZUOLI: Hang on one 
7 
SPECIAL MASTER POZZUOLI: Let's take a 
7 
second. Anything else? 
8 
ten-minute break. Lawyers. can you stay for 
8 
MR. SCOTT': No. 
9 
just a second. I want to deal with a secondary 
9 
SPECIAL MASTER POZZUOLI: Mr. Scarola. 
10 
matter dealing with a deposition on Saturday. 
10 
Mr. Edwards. do you have an opinion on this? 
11 
VIDEOGRAPHER: Going off the record. The 
11 
MR. SCAROLA: Na 
12 
time is 10:32 a.m. 
12 
MR. EDWARDS: Our opinion is consistent 
13
(Discussion held off video record only as follows:) 
13 
with the opinion of Sigrid McCawley or the 
14 
SPECIAL MASTER POZZUOLI: We are off the 
14 
argument of Sigrid McCawley. 
15 
video. but I wanted to have this on the record. 
15 
SPECIAL MASTER POZZUOLI: Darren. go 
16 
I've reviewed the confidentiality order that's 
16 
ahead. 
17 
pending that was issued by Judge Lynch. and I 
17 
MR. INDYKE: I would like to give this to 
18 
just want to be clear as we head into the 
18 
Florida counsel because this is the first I'm 
19 
deposition on Saturday as to get the party's 
19 
hearing of it. But I would say that at the 
20 
view as to who should be in attendance at that 
20 
very least. there's some confidentiality 
21 
deposition. So. Ms. McCawley, why don't you 
21 
obligations that are applicable to Ms. 
22 
start. 
22 
in connection with the settlement agreement 
23 
NIS. NIcCAWLEY: Sure. Sure. The 
23 
that was signed. And that Mr. Epstein should 
24 
deposition is a confidential deposition that is 
24 
have counsel there present to protect any 
25 
going to be held under seal. It will be filed 
25 
disclosures — 
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