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1 
MR. SCAROLA: We have a very strong 
1 
record. I mentioned to Rick yesterday I have to 
2 
opinion on that. 
2 
leave here at 3:45 this afternoon. so he made 
3 
MS. McCAWLEY: Right. And I just want to 
3 
representations that there wouldn't be any 
4 
be clear. Mr. Epstein's counsel has not 
4 
testimony with respect to Boies Schiller 
5 
appeared in this case. I argued this issue 
5 
Flexner or those allegations that have 
6 
before the judge. and I have a confidentiality 
6 
repetitively come up in the deposition outside 
7 
order from Judge Lynch signed based on my 
7 
of counsel's presence. But I do have to leave 
8 
motion to quash. 
8 
because I have to catch a plane. so I won't be 
9 
SPECIAL MASTER POZZUOLk 1 ve rereviewed 
9 
here this afternoon, and they've agreed to 
10 
both your motions and the order. 
10 
that. 
11 
Darren. anything else? 
11 
MR. SIMPSON: She's correct about the 
12 
MR. INDYKE: No. that's as far as I 
12 
agreement. 
13 
understand right now. 
13 
SPECIAL MASTER POZZUOLI: What we might 
14 
SPECIAL MASTER POZZUOLI: Mr. Scant. you 
14 
do. then is break at that point if were going 
15 
wanted to say something? You were -- you had 
15 
to have to come back anyway. 
16 
sonic strong opinion I wanted to hear. 
16 
MR. EDWARDS: What time is that? 
17 
MR. SCAROLA: The purpose of the 
17 
MS. McCAWLEY: 3:45. 
18 
confidentiality motion was to exclude 
18 
THE WITNESS: If we could finish in a 
19 
Mr. Epstein from the deposition among other 
19 
couple of hours. Id like to do that, if that's 
20 
purposes. But we did not want to be in a 
20 
possible. 
21 
position where 
was 
21 
SPECIAL MASTER POZZUOLI: It's not my 
22 
obliged to give her testimony in front of any 
22 
deposition. 
23 
of her abusers, but most specifically not in 
23 
MR. EDWARDS: At this stage and at this 
24 
front of the individual accused of having 
24 
pace. I don't see how that's possible. That 
25 
maintained her as a sex slave for an extended 
25 
was my goal. but I don't see it happening. 
726 
728 
1 
period of tint. 
1 
Well see where we are. 
2 
SPECIAL MASTER POZZUOLI: So. I've 
2 
THE WITNESS: I hope we get to this 
3 
reviewed both the motion that was filed as well 
3 
letter. I spent all night reading it last 
4 
as the order. While the order lacks any real 
4 
night at your request. 
5 
specificity. my view of the order is as 
S 
MR. EDWARDS: I think we'll at least make 
6 
follows: That the deposition on Saturday. 
6 
a dent. 
7 
obviously the named panics and their 
7 
SPECIAL MASTER POZZUOLI: Let's go back on 
8 
representatives can attend. The witness and 
8 
and plow forward. 
9 
their counsel can attend. The court reporter 
9 
VIDEOGRAPHER: Okay. We're going back on 
10 
and myself. And that will be it. 
10 
the record. The time is 10:50 am. 
11 
If there is any further clarification from 
11 
BY MR. EDWARDS: 
12 
Judge Lynch. I'm happy to consider it. But as 
12 
Q. So, in addition to the statements that --
13 
of right now, those arc the only panics and 
13 
or the information that you had in your pm:session 
14 
people that will be allowed to attend the 
14 
at the time that you made the public statement on 
15 
deposition. 
15 
January 5. 2015. regarding Brad Edwards, you also 
16 
MS. McCAWLEY: Thank you. 
16 
indicated initially that you had certain information 
17 
MR. SCOTT: You are excluding Ms. Cohen? 
17 
in your possession with respect to Paul Cassell as 
18 
SPECIAL MASTER POZZUOLI: I'm excluding 
18 
well, correct? 
19 
Ms. Cohen and excluding Mr. Epstein's 
19 
A. That's right, yes. 
20 
attorneys. 
20 
Q. One of the things I wrote down is that you 
21 
MR. INDYKE: I just want to note my 
21 
were told that Paul Cassell is a zealot. 
22 
objection. but I will take that up with Florida 
22 
A. Right. 
23 
counsel. 
23 
Q. When were you told Paul Cassell is a 
24 
(Recess was held from 10:37 a.m. until 10:50 a.m.) 
24 
zealot? 
25 
MS. McCAWLEY: Just for something for the 
25 
A. Immediately. 
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MR. INDYKE: Same objection. same 
1 
led me to the conclusion that he was a zealot. 
2 
instruction. 
2 
I also read a great deal of his material. 
3 
A. Shortly them -- shortly after the 
3 
MR. EDWARDS: I move to strike as 
4 
allegations were made. 
4 
nonresponsive to this question. 
5 
BY MR. EDWARDS: 
5 
A. Okay. I'll give you some descriptions. 
6 
Q. And who told you that Paul Cassell is a 
6 
Q. I want the names of individuals. 
7 
zealot? 
7 
SPECIAL MASTER POZZUOLI: Listen. 
8 
MR. INDYKE: Same objection. same 
8 
BY MR. EDWARDS: 
9 
instruction. 
9 
Q. The names of individuals who told you that 
10 
MR. SIMPSON: Outside the privilege. 
10
Paul Cassell is a zealot. 
11 
A. Numerous people. That was a common term 
11 
A. I can't remember names, but I can give you 
12 
used to describe him. I can tell you the people I 
12
some descriptions. if you want. 
13 
spoke to. but, again. I can't identify who precisely 
13 
Q. No, I want names of people. 
14 
would have used that term. 
14 
A. Okay. 
15 
BY MR. EDWARDS: 
15 
SPECIAL MASTER POZZUOLI: Hang on one 
16 
Q. You previously said that numerous 
16 
second. He's now answered the question. So --
17 
people -- 
17 
BY MR. EDWARDS: 
18 
A. They did. 
18 
Q. At this stage, you cannot provide me the 
19 
Q. -- told you that Paul Cassell is a zealot. 
19 
name,. of any individuals that told you Paul Cassell 
20 
and that assisted in providing the basis for your 
20
is a zealot; is that correct? 
21 
statement that you made publicly about Paul Cassell. 
21 
A. I can give you descriptions, which would 
22 
I'm only asking for you to identify by 
22 
lead you to be able to probably find out the names. 
23 
name the individuals that specifically told you Paul 
23 
Q. Descriptions of people? 
24 
Cassell is a zealot. I just want a list of names. 
24 
A. Description of people. yeah. 
25 
MR. SIMPSON: Objection. a.ked and 
25 
Q. Okay. Not descriptions of the statements; 
730 
732 
1 
answered. 
1 
descriptions of the people? 
2 
MR. INDYKE: Same objection. same 
2 
A. No. description of people. 
3 
instruction. 
3 
Q. Okay. I'll lake right now descriptions of 
4 
SPECIAL MASTER POZZUOLI: In a 
4 
the people who told you that Paul Cassell is a 
5 
nonprivileged context. 
5
zealot. 
6 
MR. SCAROLA: So that the record is clear. 
6 
A. I got a number of calls from people who 
7 
the question does not limit itself to a 
7
were in litigation with Paul Cassell. He purports 
8 
nonprivileged context because our position is 
8 
to be an expert on false confessions. Apparently 
9 
the privilege has been waived. We understand 
9
he's not. 
10 
that we may only get a limited response. but 
10 
MR. EDWARDS: Object and move to strike as 
11 
the question does not include the limitation. 
11 
nonresponsive. 
12 
MR. SCOTT: And this is -- our position is 
12 
SPECIAL MASTER POZZUOLI: I would agree 
13 
that this is the entire arca. and that even if 
13 
and grant that Motion to Strike. Provide the 
14 
you accept. which we don't. that he waived the 
14 
descriptions of the names pursuant to the 
15 
other conversation, this has not been touched 
15 
question. 
16 
on or waived. 
16 
A. Okay. So a number of people who were 
17 
MR. INDYKE: My position is that 
17
involved in litigation concerning his alleged 
18 
Mr. Epstein waived no such privilege. 
18
expertise as a witness on false confessions --
19 
SPECIAL MASTER POZZUOLI: Okay. So with 
19 
BY MR. EDWARDS: 
20 
that said, please provide an answer outside of 
20 
Q. Okay. 
21 
the context of the privilege. which will be 
21 
A. -- called me. 
22 
reserved for a later argument. 
22 
Q. Category number one, then, is people 
23 
A. Right now all I can think of is the number 
23 
involved in litigation currently with Paul Cassell 
24 
of people who gave me information about Paul 
24 
on false confession cases? 
25 
Cassell. but I cannot with specificity indicate who 
25 
A. That's right, yes. 
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1 
Q. And are these people that you are 
1 
correct. And I also did my own investigation. 
2 
describing lawyers or litigants? 
2 
MR. SCAROLA: Did those include privileged 
3 
A. Lawyers. lawyers. But not in a privilege. 
3 
and nonprivileged communications? 
4 
Q. Do you remember which party these lawyers 
4 
BY MR. EDWARDS: 
5
that you're describing represent? 
5 
Q. Did those communications that led you to 
6 
A. Yes. The party opposed to Paul Cassell, 
6 
the conclusion that Paul Cassell is a zealot iot holt-
7
the party that were challenging his expertise. 
7 
both privileged and nonprivileged conummiL at II rots.' 
8 
Q. How many different lawyers are you 
8 
A. Yes. 
9
describing that are currently in litigation with 
9 
Q. And with respect to the privileged 
10
Paul Cassell? 
10 
communications, are you claiming that the 
11 
A. To my best recollection, two. 
11 
communication that Paul Cassell is a zealot came 
12 
Q. Do these two lawyers work at the same law 
12 
from people with whom you share an attorney-client 
13
firm? 
13 
privilege because they're your attorneys or with 
14 
A. No. 
14 
whom you share a joint defense attorney-client 
15 
Q. Do these two — are these two lawyers, to 
15 
privilege because they are attorneys or 
16 
the best of your understanding, working on separate 
16 
representatives of Jeffrey Epstein? 
17
false confession cases against Paul Cassell? 
17 
MR. SCOTT: Wait a minute. I'm objecting 
18 
A. I think so. but Int not absolutely 
18 
to that on work product and were going to --
19
certain. 
19 
SPECIAL MASTER POZZUOLI: Go ahead. 
20 
Q. Do you know where it is that these two 
20 
Darren. get your --
21
lawyers that you're describing practice? 
21 
MR. INDYKE: Objection. Same objection. 
22 
A. My best recollection, this is just a 
22 
same instruction on a number of grounds. 
23 
recollection- one of them is in the midwest. maybe 
23 
including attorney-client privilege as well as 
24 
Chicago. And another I think in the mid south. I'm 
24 
common interest. 
25 
not positive, maybe Atlanta. But those are -- 
25 
SPECIAL MASTER POZZUOLI: Read the 
734 
736 
1
again. I can probably find these names, but I don't 
1 
question back. 
2
have them off the top of my head. 
2 
COURT REPORTER: "And with respect to the 
3 
Q. Have you provided these names or these 
3 
privileged communications. are you claiming 
4 
descriptions in response to any requests for 
4 
that the communication that Paul Cassell is a 
5
production in this case? 
5 
zealot came from people with whom you share an 
6 
A. I don't provide that. My lawyers do. But 
6 
attorney-client privilege because they're your 
7
I don't think anybody has ever -- these are not -- 
7 
attorneys or with whom you sham a joint 
8 
MR. SIMPSON: Answer the question. 
8 
defense attorney-client privilege because they 
9 
A. I don't know the answer to that. 
9 
are attorneys or representatives of Jeffrey 
10 
BY MR. EDWARDS: 
10 
Epstein?" 
11 
Q. Is there anything more that you can 
11 
MR. INDYKE: In doing so. you're not only 
12 
provide me in the way of description of the 
12 
identifying the people but you're also 
13
individuals that told you that Paul Cassell is a 
13 
identifying the contents of the disclosure. 
14 
zealot? 
14 
MR. SCAROLA: No. we're identifying the 
15 
A. No, but what I can do is give you names of 
15 
nature of the privilege being asserted. 
16 
people who called me and discussed with me Paul 
16 
SPECIAL MASTER POZZUOLI: The nature or 
17
Cassell. 
17 
the privilege — hang on a second. 
18 
Q. We'll get there. Different category. Did 
18 
MR. SCAROLA: Thank you. I'm sorry. 
19
these other people that called you, did they also 
19 
SPECIAL MASTER POZZUOLI: They're trying 
20 
tell you Paul Cassell is a zealot? 
20 
to identify the nature of the privilege being 
21 
A. Well, I can only tell you again. as I said 
21. 
asserted. And I do think that if the witness 
22 
previously, on the basis of all the conversations I 
22 
does know the answer as opposed to a legal 
23 
had with about Paul Cassell. I came to the 
23 
discussion. whoever's going to assert it. I 
24 
conclusion, as some people had told me. that the 
24 
think they're entitled to an answer on that. 
25 
people who told me that he was a zealot were 
25 
MR. SCOTT: Without any type of waiver 
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1 
position. 
1 
record is clear as to which privilege is being 
2 
SPECIAL MASTER POZZUOLI: Without a 
2 
asserted. 
3 
waiver, but they're entitled -- because I don't 
3 
MR. SCOTT: Jack. I totally agree with 
4 
think that waives -- I think it's the nature of 
4 
you. Thank you. 
5 
what's being asserted. 
S 
SPECIAL MASTER POZZUOLk Hang on one 
6 
A. So without waiving — 
6 
second. So based upon the correction. the 
7 
MR. SCOTT: Well. wait a minute. So let's 
7 
privilege being asserted is both work product 
8 
ask the question again so we have it again. 
8 
and attomey-client. 
9 
A. I know the question. 
9 
MR. SCOTT: Both. 
10 
MR. SCOTT: I don't. I'm not as smart as 
10 
SPECIAL MASTER POZZUOLI: And so the same 
11 
you are, 
11 
ruling for now on the reservation. 
12 
THE WITNESS: I'm sorry. 
12 
MR. SCOTT: And. Mr. Special Master. I'm 
13 
SPECIAL MASTER POZZUOLI: Let's go ahead 
13 
objecting on both grounds consistent with what 
14 
and reread the question back so we get it 
14 
we discussed yesterday. I apologize. And 
15 
precisely because that's how I ruled. 
15 
thank you. Mr. Scorpio. 
16 
COURT REPORTER: "And with respect to the 
16 
MR. SCAROLA: No apologies necessary. I 
17 
privileged communications. are you claiming 
17 
just wanted the record to be clear. 
18 
that the communication that Paul Cassell is a 
18 
MR. SCOTT: I appreciate it. 
19 
zealot came from people with whom you share an 
19 
SPECIAL MASTER POZZUOLI: Well. I would 
20 
attomey-client privilege because theyre your 
20 
accept your apology. 
21 
attorneys or with whom you share a joint 
21 
BY MR. EDWAR1)S: 
22 
defense attorney-client privilege because they 
22 
Q. Mr. Dershowitz. are you willing to waive 
23 
are attorneys or representatives of Jeffrey 
23 
the attorney-client privilege to provide us the 
24 
Epstein?" 
24 
names of the individuals with whom you share a 
25 
MR. SCOTT: Answer that very concisely. 
25 
privilege that told you that Paul Cassell --
738 
740 
1 
A. Both. 
1 
MR. SCOTT: Don't answer the question. 
2 
MR. INDYKE: fm sorry. if them is 
2 
BY MR. EDWARDS: 
3 
discussion going on. I can't hear any of the 
3 
Q. -- is a zealot, a fact that you relied 
4 
discussion. 
4 
upon before making your public statement? 
5 
SPECIAL MASTER POZZUOLI: No. there's -- 
5 
MR. SCOTT: Objection. Work product. 1)o 
6 
we've been quiet. 
6 
not answer that. He has a right to consult 
7
BY MR. EDWARDS: 
7 
with counsel, and we haven't spoken. 
8 
8 
MR. INDYKE: Objection. 
Q. With I asiAti to the communications with 
9
these individuals where you are the client, can you 
9
BY MR. EDWARDS: 
10 
provide me with the names of those individuals? 
10 
Q. My only question is, are you willing to 
11 
MR. SCOTT: Objection. work product. 
11 
waive. 
12 
SPECIAL MASTER POZZUOLI: Yeah. ma I'm 
12 
SPECIAL MASTER POZZUOLI: Hang on one 
13 
going to grant the objection and allow them to 
13 
second. 
14 
assert the privilege at this point pending 
14 
MR. INDYKE: Arc we talking about only a, 
15 
further review. 
15 
to where Mr. Dershowitz is the client? 
16 
MR. SCAROLA: I want to -- excuse me. 
16 
MR. EDWARDS: Yes. 
17 
Before we proceed. I want to get a 
17 
MR. INDYKE: Okay. 
18 
clarification. This privilege that's being 
18 
SPECIAL MASTER POZZUOLI: So. now repeat 
19 
asserted is a work product privilege. correct? 
19 
your question so it's clear. 
20 
MR. SCOTT: And attorney-client privilege. 
20 
BY MR. EDWARDS: 
21 
MR. SCAROLA: Okay. Well. you said only 
21 
Q. Sure. Are you. Alan Dershowitz. willing 
22 
work product. 
22 
to waive the attorney-client privilege to provide us 
23 
MR. SCOTT: Okay. I apologize. If I use 
23 
the names of the individuals that told you Paul 
24 
one. I'm referring to both consistent with — 
24 
Cassell is a zealot? 
25 
MR. SCAROLA: I wanted to be sure that the 
25 
MR. SCOTT: Objection. Work product. 
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attorney-client privilege. and I'm instructing 
1 
sorry. 
2 
him not to answer that question. 
2 
Q. Okay. The communications that Paul 
3 
SPECIAL MASTER POZZUOLI: Okay. And where 
3
amen is a zealot --
4 
he is the client? 
4 
A. Right. 
5 
MR. EDWARDS: Where he is the client. 
5 
Q. -- outside of the two individuals with 
6 
SPECIAL MASTER POZZUOLI: Waite 
6 
whom you do not share privilege that you've 
7 
instructing him not to answer? 
7
described --
8 
MR. SCOTT: Not to answer. I will discuss 
8 
A. That's right. 
9 
it with him, and after a break. we can come 
9 
Q. -- are the remaining individuals that told 
10 
back to that question. 
10
you that information and people that you have met 
11 
SPECIAL MASTER POZZUOLI: I believe the 
11
with in person. are those people all people with 
12 
witness has the right to consult with counsel 
12
whom you share a privilege? 
13 
before answering that question. So well 
13 
A. No. 
14 
proceed on that grounds. 
14 
Q. Okay. What people have you met with in 
15 
MR. EDWARDS: Okay. 
15
person with whom you do not share a privilege that 
16 
BY MR. EDWARDS: 
16 
have told you Paul Cassell is a zealot? 
17 
Q. Other than the two lawyers that you have 
17 
A. I told you I spoke with numerous people. 
18 
described that told you that Paul Cassell is a 
18 
I can't now specify a particular name with the word 
19 
zealot, and any attorneys with whom you share a 
19
"zealot" I can give you names of people I spoke to 
20 
privilege, can you identify or describe any others 
20
who gave me intonation about Cassell. 
21 
that you have not yet told us about that told you 
21 
MR. SCOTT: If they're not privileged. 
22 
Paul Cassell is a zealot? 
22 
A. They're not privileged. 
23 
A. It's a common term that has been given to 
23 
SPECIAL MASTER POZZUOLI: That was his 
24 
me by numerous lawyers. but I can right now give 
24 
question. 
25 
yet any more specificity. Sometimes it's "zealot" 
25 
742
1 
sometimes the term is "true believer." sometimes the 
1 
BY MR. EDWARDS: 
2
tom is an "extremist." But I've heard many terms 
2 
Q. Please provide me the names of the 
3
along those lines that would laid to a consistent 
3
individuals you spoke to that provided you 
4 
conclusion. 
4 
information about Paul Cassell. 
5 
Q. When did you receive these communications 
5 
A. I received a phone call from Senator Orrin 
6
from these various individuals that Paul Cassell is 
6
Hatch from whom -- for whom he worked. I received 
7
a zealot? 
7
phone call from a lawyer now -- a lawyer who he had 
8
A. From the beginning up through recently. 
8
a litigation against somewhere in Arizona or 
9 
Q. Is it your testimony that you received 
9
somewhere in the southwest whose name I don't right 
10 
that information prior to January 5, 2015? 
10 
now have on hand. 
11 
A. Yes- yes. 
11 
Another name that's popping into my mind, 
12 
Q. Okay. And what was the form of that 
12 
but it's privileged. I had a conversation with the 
13 
communkadon, written or verbal? 
13
former President of Ecuador. who had been a student 
14 
A. I don't remember. Well. I have to check. 
14 
in one of my classes and was a colleague of 
15 
I don't remember anything in writing. I think it's 
15
Mr. Cassell. We spoke --I think I may have called 
16 
all been — I think it's all been verbal on the 
16
him or he may have called me. I don't remember 
17
phone and in person. 
17
exactly. 
18 
Q. Have you met In person with the two 
18 
Q. This is the President of Ecuador? 
19 
individuals that you described? 
19 
A. The former President of Ecuador. 
20 
A. No. no. 
20 
Mr. Cassell knows who he is. And — lean try to 
21 
Q. So when you are speaking about in-person 
21 
think of other names of people who called me. I 
22 
communication of the statement that Paul Cassell is 
22 
will check and see if I have any information 
23 
a zealot. you're talking about conununications that 
23 
further. 
24 
are privileged communications? 
24 
Q. If you think of them while we're talking. 
25 
A. I didn't understand the question. fin 
25
then let me know. 
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1 
A. Sure. 
1 
constitutionally protected expression of opinion. 
2 
Q. What did the lawyer in Arizona tell you 
2 
and it was based on the totality of circumstances 
3
about Paul Cassell? 
3 
that I had available to me at the time. That 
4 
A. That he was a zealot and that he was a 
4 
included reputations of the two people who had made 
5
pain in the ass. That was -- I remember that was 
5 
up the story. It included the statements themselves 
6
his exact words. 
6 
and how they were written and framed. Included the 
7 
Q. Is this somebody in addition to the other 
7 
fact that there was no affidavit, that it was 
8
two lawyers that you described? 
8 
written, in fact, by the two lawyers. 
9 
A. Yes. 
9 
So of course the lawyers played a role. 
10 
Q. So now we are up to three lawyers that 
10 
It was their own words that were being circulated to 
11 
were in litigation with Paul Cassell that told you 
11 
millions — hundreds of millions of people around 
12 
that Paul Cassell is a zealot? 
12 
the world. 
13 
A. At least three. yes. 
13 
Q. But you were — you were saying and you 
14 
Q. Three that you've been able to describe? 
14 
said and you conveyed something more than Paul 
15 
A. Yeah. 
15 
Cassell and Brad Edwards simply listened to their 
16 
Q. But as you sit here right now, unable to 
16 
client and put it on paper, you were saying --
17
name today? 
17 
A. That's right. 
18 
A. I can't. no. 
18 
Q. — you were saying and are still saying 
19 
Q. Including this lawyer in Arizona? 
19 
Paul Cassell and Brad Edwards and 
20 
A. Yeah. I don't remember if it was Arizona 
20 
concocted this story about me together? 
21
or New Mexico o• Utah. It was a southwest case that 
21 
A. That's right. 
22 
was a long, long -- apparently a lengthy litigation. 
22 
Q. Meaning it wasn't just her words: the 
23 
Q. Did this lawyer in Arizona telling that 
23 
lawyers came up with these allegations. That's what 
24 
you Paul Cassell is a, quote, pain In the ass, 
24 
you were saying, right? 
25 
unquote, contribute — 
25 
A. I'm saying a combination. I said —my 
746 
748 
1 
A. No. no. not that statement. I mean, many 
1
exact words were: 
2
lawyers could be described that way. That would not 
2 
"MR. DERSHOWTTZ: So they and the woman 
3
contribute to that. I myself have been described 
3 
got together and contrived and made this up: 
9 
that way. 
4 
Yes. 
5 
Q. Okay. So is there anything about the 
5 
Q. Right. So. when I asked you what formed 
6 
communications that you had with this lawyer in 
6
the basis of your public statement that the lawyers 
7 
Arizona that in any way contributed -- 
7
were involved in contriving and making this up. you 
8 
A. Yes. 
8
gave me a list of things. and one is --
9 
Q. Let me just finish the statement so that 
9 
A. That's right. 
10 
we have a clean record. 
10 
Q. — Paul Cassell's reputation --
11 
-- contributed to your confidence in 
11 
A. That's right. 
12 
making the public statement in January 5.2015. that 
12 
Q. — that was supported by various people 
13 
Paul Cassell contrived or assisted in making up the 
13
telling you various things. 
19 
allegations? 
14 
A. That's right. 
15 
A. First let me be very clear that that was 
15 
Q. One of those things being Paul Cassell is 
16 
an expression of an opinion. 
16 
a zealot. And so that's where we are right now in 
17 
Q. What was? Be clearer. 
17
understanding who these people were, when you got 
18 
A. "So they sat down together. the three of 
18 
this information. And that's what you're describing 
19 
them, these clearly disbarrablc. unprofessional 
19 
for me, right? 
20 
lawyers." when you read it in context, it's clear I 
20 
A. That's correct. But I'm saying to you 
21 
wasn't saying I was there. I wasn't saying I was saw 
21 
that it was the totality of circumstances. For 
22 
it. I was giving a scenario. They profiled me. 
22 
example. if a very imminent lawyer with a superb 
23 
they did this, so they sat down together and they 
23 
reputation had made serious allegations. I would 
29 
made up this story. 
24 
be — I mean. I knew in this case they were totally 
25 
So it was an expression-- 
25
false, but if I didn't know. if I didn't have that 
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personal information. I would be more reluctant to 
1 
confidence in the public statement you made about 
2 
express this opinion. 
2 
him on January 5,2015? 
3 
But knowing everything I knew. that the 
3 
A. Yes. 
4 
allegations were false, that there had to be 
4 
Q. Okay. Who are those individuals? 
5
financial motive, that there was so much 
S 
A. But I want to be very clear. I'm talking 
6 
specificity. that it was written by the lawyers 
6 
about individuals who I spoke to about Paul Cassell. 
7
themselves, that they didn't put it under seal, that 
7 
who gave me information that formed part of the 
8
they were trying to get the story out and circulated 
8 
large picture. 
9
as widely as possible. all of that combined with 
9 
Q. You've been clear on that. I get that. 
10
their reputation led me to the opinion that this was 
10 
A. One of them is Akhil Amar. who is a 
11
the scenario. 
11 
professor at Yale Law School. 
12 
By the way. I think it was partial 
12 
Q. When did you talk to Akhil Amar? 
13 
scenario. I think as I've said before, there were 
13 
A. Shortly after this happened. Again, my 
14 
dual motivations. One motivation was to profile me 
14 
recollection is he called me because he was so 
25
to try• to — that was a cover. really. 
15 
shocked. 
16 
MR. EDWARDS: Object. Move to strike as 
16 
Q. And would that have been some date prior 
17 
nonresponsive. 
17 
to January 5,2015? 
18 
SPECIAL MASTER POZZUOLI: Yeah. I think 
18 
A. 1 don't remember for sure. But it's —1 
19 
we've gone far afield. So granted. Move 
19 
don't remember for sure. 
20 
forward. 
20 
Q. Can you tell me what the substance of the 
21 
BY MR. EDWARDS: 
21 
conversation was that you had with Akhil Amar about 
22 
Q. What did the former President of Ecuador 
22 
Paul Cassell? 
23 
tell you about Paul Cassell? 
23 
A. Well. how shocked he was that Cassell 
24 
A. Again, all I remember is we had a 
24 
would make a statement like this. And that he would 
25 
conversation. You asked me who did I have a 
25 
try to talk to Cassell and persuade him that it 
750 
752 
1 
conversation with about Paul Cassell. My 
1 
couldn't be true. And that it would be a difficult 
2
recollection is that he did not use the term 
2 
conversation. That's my basic recollection. 
3
"zealot" or anything like that. He just gave me 
3 
Q. Did Akhil Amar tell you that he thought 
4 
information. 
9 
highly of Paul Cassell? 
5 
Q. What Information did he give you? 
5 
A. No. 
6 
A. That he is stubborn. that he would be 
6 
Q. Did he give you positive or negative 
7
difficult to get to change his views, that kind of 
7 
information about Paul Cassell or Paul's reputation? 
8
thing. in general. But all of it contributed to an 
8 
A. I would say it was neutral but consistent. 
9
image. 
9
You have to know something about Akhil Amar. Akhil 
10 
I had never met Paul Cassell. I didn't 
10 
Amer is the nicest person in the world. I've never 
11
know who he was other than having read some of his 
11 
heard him say anything negative about any human 
12 
articles. But then I did a lot of research on him 
12 
being on the face of the earth. and I would never 
13 
before I made these statements. 
13 
expect him to say in specific terms anything 
14 
Q. Okay. My question that's pending is, what 
19 
negative about anybody. But the information he 
15 
did the former President of Ecuador tell you? 
15 
provided me helped form the total picture that I had 
16 
A. That he was stubborn and probably would he 
16 
of Mr. Cassell. 
17
difficult to get him to change his mind. 
17 
Q. Other than telling you that Mr. Cassell 
18 
Q. Okay. Is there anyone else other than the 
18 
was stubborn, what other information did he provide 
19 
people that you have already either identified -- 
19 
you which helped to form the total picture? 
20 
A. Yes. 
20 
A. I think we discussed his views of 
21 
Q. -- by name or described for me that gave 
21 
victimization. his views of false confessions. We 
22 
you information -- 
22 
had a general discussion about his academic 
23 
A. Yes. 
23 
standing. about his general reputation. about --
24 
Q. -- about Paul Cassell that contributed to 
29 
Q. When you says "his," you're speaking of 
25 
your belief about his reputation that gave you a 
25 
Paul Cassell's or Akhil Amar's? 
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A. No. about Paul Cassell's. This is a 
1 
you that Paul Cassell's character or reputation 
2 
conversation with Akhil Anur. 
2 
were such that he would place assertions or 
3 
Q. Okay. What specifically, then, was the 
3 
allegations in pleadings in which Paul Cassell 
4
substance of that conversation about Paul Casscll's 
4 
did not believe? 
5
reputation that's helped to form the basis of the 
5 
"My best recollection -- again this could 
6
big picture? 
6 
be him, it could be others. but it was partly 
7 
A. The conclusion that I drew from it was 
7 
from what I spoke to him about is that Paul 
8
that he with a zealot and he was stubborn and that 
8 
Cassell does not believe that any woman is 
9
he was an idealoguc. and that he was rigid in his 
9 
capable of lying about sexual assault: that 
10 
views. But, again, this is a conclusion that I 
10 
when a woman makes a claim of sexual assault. 
11
reached on the basis of all the conversations I had. 
11 
it must be believed and it must be credited 
12 
I reached out, some people reach out to me. and 
12 
without regard to the evidence. 
13
these are the kinds of things that we discussed. 
13 
"That was certainly the impression I came 
14 
Q. Did Akhil Amar, in speaking about Paul 
14 
away with from my various conversations with a 
15 
Cassell and his character and his reputation, tell 
15 
range of people. And that was a pretty uniform 
16 
you that he feels Paul Cassell must genuinely 
16 
view that I got from the people around -- the 
17 
believe in the allegations? 
17 
people I spoke to." 
18 
A. No. 
18 
BY MR. EDWARDS: 
19 
Q. Did he tell you or convey to you that Paul 
19 
Q. Is there anything more about your 
20 
Cassell did not believe in the allegations of this 
20 
conversation with Akhil Amor that contributed to 
21
claim? 
21 
your overall perspective on the reputation of Paul 
22 
A. No. 
22 
Cassell, other than what you've already told me? 
23 
Q. Did Akhil Amin- convey to you that Paul 
23 
A. Not that I can now think of. 
24
Cassell's character or reputation were such that he 
24 
Q. How many times did you speak with Akhil 
25
would place assertions or allegations in pleadings 
25 
Amar about Paul Cassell? 
754 
756 
1 
in which Paul Cassell did not believe? 
I 
A. I think twice. 
2 
A. My best recollection -- again, this could 
2 
Q. And are you able to say with any certainty 
3
be him it could be others. but it was partly from 
3
whether or not it was before or after January 5. 
4 
what I spoke to him about is that Paul Cassell does 
4
2015? 
5 
not believe that any woman is capable of lying about 
5 
A. I can't say. 
6 
sexual assault: that when a woman makes a claim of 
6 
Q. Did you ask Akhil Anne to reach out to 
7 
sexual assault, it must be believed and it must be 
7
Paul Cassell? 
8 
credited without regard to the evidence. 
8 
A. I did. 
9 
That was certainly the impression I came 
9 
Q. Other than Akhil Amar% is there anyone 
10 
away with from my various conversations with a range 
10 
else that you haven't already described or named 
11 
of people. And that was a pretty uniform view that 
11 
that gave you Information about Paul Cassell? 
12 
I got from the people around -- the people I spoke 
12 
A. Okay. let me be very clear. Pm not 
13 
to. 
13
including people with whom I have a privilege, fm 
14 
MR. EDWARDS: We're getting a little 
14 
not including people that have a privilege with me. 
15 
feedback on the phone. 
15 
And I want to be very clear about this. I 
16 
SPECIAL MASTER POZZUOLI: On the phone. 
16
am not now allowed to describe any conversations 
17 
there is some background -- 
17
with the person who Sigrid McCawley is now here on 
18 
VIDEOGRAPHER: We're going off the record. 
18
behalf of. So. I don't want a negative inference to 
19 
The time is II:21 a.m. 
19
be drawn. 
20 
(Recess was held from 11:21 a.m. until 11:27 a.m.) 
20 
I would like to comment. if I could, about 
21 
VIDEOGRAPHER: We are back on the record. 
21 
a person who fm not allowed to comment about. But 
22 
The time is II:27 a.m. 
22 
I want the recap' to be -- I don't want -- I have to 
23 
MR. EDWARDS: Can you read back for me the 
23 
answer your question completely. 
24 
last question and the last answer? 
24 
Q. Okay. But this is all -- all of thew 
25 
COURT REPORTER: 'Did Akhil Amar convey to 
25 
questions are about the basis that gave you the 
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confidence to make the January 5,2915 statement 
1 
my view. invade the privilege without 
2 
that provided you information on Paul Cassell. 
2 
identifying the people. And so based on the 
3 
A. I misunderstood. I think your last 
3 
objection. I will grant the objection pending a 
4 
question said the universe of information about Paul 
4 
reservation to review the entire issue on the 
5 
Cassell. That's why I had to put that on the record 
5 
privilege, as we've done before. 
6 
involving the sealed -- 
6 
So move on. I think right now. move on on 
7 
Q. Maybe it did, so let me just say — let me 
7 
this — on the question because you specified 
8 
break this down. 
8 
the question. 
9 
SPECIAL MASTER POZZUOLI: That's how I 
9 
BY MR. EDWARDS: 
10 
understood it. 
10 
Q. Did privileged communications assist in 
11 
BY MR. EDWARDS: 
11 
forming your opinions about Paul Cassell? 
12 
Q. Let's break this down into the people that 
12 
MR. SCOTT: Same objection. same 
13 
you were describing you spoke to prior to making the 
13 
instruction. 
14 
public statement that we've been talking about, and 
14 
MR. INDYKE: Same objection. 
15 
then we'll expand it beyond that time. 
15 
SPECIAL MASTER POZZUOLI: And the same 
16 
A. Okay. 
16 
ruling as the previous question. 
17 
Q. Okay. So, in addition to Akhil Amar. who 
17 
BY MR. EDWARDS: 
18 
is next on the list? 
18 
Q. Are we clear that I'm not asking what 
19 
A. You want rte to repeat the names I gave you 
19 
those opinions are or the names of the individuals? 
20 
or -- 
20 
Just arc there individuals — is there privileged 
21 
Q. No, no, outside of the people we've 
21 
communications that form the basis of your -- that 
22 
already discussed? 
22 
help to form the basis of your opinions? Just ycs 
23 
SPECIAL MASTER POZZUOLI: Who is next on 
23 
or no. IS there privileged communication --
24 
the list for what? 
24 
MR. SCOTT: Same objection. same 
25 
25 
instruction. 
758 
1 
BY MR. EDWARDS: 
1 
MR. INDYKE: Same objection. same 
2 
Q. Who is next on the list of people that you 
2 
instruction. 
3
spoke with about Paul Cassell or his reputation that 
3 
SPECIAL MASTER POZZUOLk Here's -- let me 
4 
gave you the confidence to make the public statement 
4 
just — so I'm clear. we may — it may be me or 
5 
that you made about Paul Cassell on January 5.2015? 
5 
it may be Judge Lynch who visits this issue. 
6 
A. Outside of people within the various 
6 
and it may very well be that he will have to --
7 
privileges we've talked about. 
7 
the witness will have to answer these questions 
8 
Q. Well, I want to know are there people 
8 
after subsequent argument. 
9
within the privileges that we spoke about -- 
9 
However, because the question defines the 
10 
MR. SCUFF: Objection. 
10 
topic and the matter that you're inquiring so 
11 
BY MR. EDWARDS: 
11 
specifically without addressing the 
12 
Q. Are there people within the privilege that 
12 
individuals, but seeking the individuals whom 
13 
spoke to you that helped to form your opinions or 
13 
he shares whatever privilege is being asserted, 
14 
give you confidence to make the public statement 
19 
since the topic is so specifically defined in 
15 
that you made in January 5,2015? 
15 
your question. I think it would invade the 
16 
MR. SCOTT: Objection. work product — 
16 
privilege. as I understand it. 
17 
MR. INDYKE: Objection -- 
17 
And until we reach the overall decision on 
18 
MR. SCOTT: -- attorney-client. I'm 
18 
whether privileged information of this type can 
19 
instructing him not to answer that question. 
19 
be -- to force the witness to answer it —
20
MR. EDWARDS: I'm not even asking for the 
20 
require an answer from the witness, then I 
21 
identities first. rm asking am there people. 
21 
would like to move on. 
22 
MR. SCOTT: I'm not — objection. 
22 
MR. SCAROLA: So that our position is 
23 
MR. INDYKE: Objection. Same objections. 
23 
clear, there is no legal issue to address 
24 
SPECIAL MASTER POZZUOLI: Because you've 
24 
unless there are materials over which a 
25 
defined the topic so specifically. it would. in 
25 
privilege is being asserted. 
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1 
We arc entitled to know whether there are 
1 
you Paul Cassell. as a professor, used Alan 
2 
materials over which a privilege is being 
2 
Dershowitz as an object of hatred in his class? 
3 
a.ssetted. and we am entitled to know the 
3 
A. I heard that from some students. Welk 
4 
nature of the privilege that is being asserted 
4 
no. let mc be clear. From a student. And I have no 
5 
so that we can make a determination as to 
5 
recollection of the name. But a student called me 
6 
whether we even want to raise a legal issue. 
6 
and told me that a friend of his who was in Paul 
7 
There's no legal issue to raise unless 
7 
Cassell's class remembered that he went after me on 
8 
we've identified whether there is privileged 
8 
the -- two issues: on the death penalty and on the 
9 
material. 
9 
exclusionary rule, and used mc as a kind of object 
10 
That's what were attempting to do. to 
10 
example of. you know, a wrong-headed person. That 
11 
establish for the record whether there is 
11 
he seemed to -- at least the student got a 
12 
privileged material and the nature of privilege 
12 
perception that he seemed to have an animus towards 
13 
being asserted without getting into the 
13 
me. But I have to tell you that did not figure 
14 
substance of any privileged communication. 
14 
into -- that did not contribute to my conclusions 
15 
SPECIAL MASTER P0ZZUOLI: I -- well taken. 
15 
about that. I'm controversial: I know that. 
16 
But my ruling will stand for now. 
16 
Q. Didn't we get here by me asking what did 
17 
BY MR. EDWARDS: 
17 
contribute, and you told me. amongst a laundry list 
18 
Q. Did you receive any e-mails about Paul 
18 
of other things, that you were told that Paul 
19
Cassell or his reputation? 
19 
Cassell aced Alan Dershowitz as an object of hatred? 
20 
A. Not that I remember, but I can check. 
20 
A. I may have thought about that. But as I 
21 
MR. INDYKE: Sante objection. 
21 
think about it now. I don't think I really factored 
22 
BY MR. EDWARDS: 
22 
that in in any significant way into my assessment. 
23 
Q. Did you receive any e-mails about the 
23 
Q. So that I understand the source of that 
24 
reputation of Brad Edwards? 
24 
information, as you sit here today, it is a person 
25
MR. INDYKE: Sante objection. same 
25 
identify 
friend 
who you cannot 
told you that a 
of 
762 
1 
instruction. 
I 
that person that you cannot identify --
2 
MR. SCOTT: Again. if they're in the 
2 
A. That's right. 
3 
context of privileged materials. 
3 
Q. -- told you that --
4 
A. Outside -- outside all of the privileges. 
4 
MR. SCAROLA: Told him. 
5
I will have to check. I don't recall. 
5 
BY MR. EDWARDS: 
6 
BY MR. EDWARDS: 
6 
Q. -- told him that Paul Cassell used you as 
7 
Q. Did you receive any smalls about the 
7
an example on two issues. the death penalty and 
8
reputation of Jack Scarola? 
8
exclusionary rule, in his class? 
9 
MR. INDYKE: Same objection. same 
9 
A. And more generally about my approach to 
10 
instruction. 
10 
criminal law. That's why I would never make a 
11 
A. I don't recall. 
11 
statement like that publicly. 
12 
BY MR. EDWARDS: 
12 
You're asking me what was in my mind. 
13 
Q. Did you receive any smalls about the 
13
That was a factor in my mind. When you get a phone 
14 
reputation of Sigrid McCawley? 
14 
call about somebody. you dont forget it. it stays 
15 
MR. SCOTT: Relevancy. 
15
in your mind and it becomes a small pan. 
16 
MR. INDYKE: Same objection. same 
16 
As I now think about it. I think too small 
17 
instruction. 
17
a part to even factor into my decision. I don't 
18 
A. No. I've always had a very high regard 
18 
think I really let that weigh on my decision. It 
19
for Sigrid McCawley prior to these allegations. 
19
may have weighed on my attitude toward Paul Cassell. 
20 
which is why I was so shocked that she would lend 
20
but I don't think it would have affected my decision 
21 
her name to these false allegations. 
21 
as to whether he would do what I said he did — what 
22 
BY MR. EDWARDS: 
22 
I believe he did. 
23 
Q. I don't believe there's any question 
23 
Q. What arc the names -- other than those 
24 
pending. 
24 
that you have identified or described for us -- what 
25 
Who are the individuals by name that told 
25
are the other names in addition to those that you 
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I 
have described or named for us that gave you 
1 
here now, but she's one of my lawyers and she's 
2 
information about Paul Cassell? 
2 
included on my list of lawyers and I regard her as 
3 
A. As I sic here now. rim sure there are 
3
one of my attorneys. 
4 
many, but I cant identify any specific names, and 
4 
Q. Is there anyone else that is on the list 
5 
if I can think of any. I will certainly let you 
5
of people other than those that you've either 
6 
know. 
6
described or named already that provided you 
7 
Q. Can you tell me the additional names other 
7
information about Paul Cassell? 
8 
than Akhil Amar that you communicated with and asked 
s 
A. I'm sure there are many, but not that I 
9 
to communicate with Paul Cassell? 
9
can identify now. Well. I can give you one more. 
10 
A. Nancy Gruner. former federal judge. 
10 
The BBC reposer who interviewed me showed me an 
11 
MR. SCOTT: Again, not privileged. 
11
e-mail from Paul Cassell in which Paul Cassell gave 
12 
A. Well. it's complicated. At the timer 
12 
her a list of questions to ask me. while claiming 
13 
asked her to reach out. I did not regard her as my 
13
that he was not speaking to the media. 
14 
attorney. Since that time, she has offered to help 
14 
That led me to conclude that he was a 
15 
represent me. So we're now in a privileged 
15
liar. And that happened very early on. That he was 
16 
relationship. 
16
absolutely a liar because he categorically stated 
11 
But when I called and asked her — I think 
17
that he had never spoken to the media, never would 
18 
she called me. I had no idea who knew Paul Cassell. 
18 
speak to the media. And here I had an e-mail from 
19 
but a number of people called and said. what can we 
19 
him showed to me by BBC that proved he was 
20 
do? Can we call Paul? How can he be doing this? 
20 
absolutely lying through his teeth. So I concluded 
21 
This is — even Senator Hatch offered to call Paul 
21 
that he is a liar who has no concern for the truth. 
22 
Cassell because he couldn't believe -- he said. I 
22 
Q. When did Paul Cassell categorically deny 
23 
cannot believe this allegation against you. I know 
23 
ever speaking to the media? 
24 
you. I know you to be a very honorable man. I 
24 
A. In his press releases where he says, we do 
25 
cannot believe that allegation against you. And Fm 
25 
not speak to the media, we've never spoken to the 
766 
768 
1 
going to call Paul Cassell. 
1 
media. only Dershowitz speaks to the media lying by 
2 
BY MR. EDWARDS: 
2 
omission and by commission, failing to state that he 
3 
Q. Okay. Going back to Nancy Gertner. when 
3
was trying to get publicity through ABC. that he was 
4 
did you establish an attorney-client relationship 
4 
pleading with ABC and he was trying to sell her 
5 
with Nancy Gainer? 
5 
story to tabloids. So he was lying by omission. 
6 
A. Sometime thereafter. 
6 
lying by commission. and so were you. 
7 
Q. Sometime? 
7 
Q. Have you produced -- do you have a list 
8 
A. After she called Cassell, and Cassell 
8 
from BBC or — reporter or anyone else that 
9
would not do anything to try to resolve the matter. 
9
indicates a list of questions or whatever it is 
10 
Q. Okay. Do you know when it was that you 
10
you're testifying to --
11 
asked Nancy Gertner to reach out to Paul Cassell? 
11 
A. Yes. 
12 
A. Shortly after the allegations. Again, she 
12 
Q. — that came from somebody other than Paul 
13 
called me. and she just couldn't believe that 
13 
Cassell? 
14 
anybody would be making these allegations. 
14 
A. I don't understand that question. 
15 
Q. Was it before or after the statement that 
15 
Q. Well, you just threw in "and so were you." 
16 
we have discussed that was made by you on the Don 
16 
and we're only talking about a list of questions 
17
Lemon show on January S. 2015. that you asked Nancy 
17 
that you know about from the BBC. 
18 
Gertner to reach out to Paul Cassell? 
18 
MR. SCOTT: I'm not sure — can you 
19 
A. I don't remember. It could have been 
19 
rephrase the question so we have it clear? 
20 
before. But it might have been after. I just dent 
20 
MR. EDWARDS: Sure. 
21 
remember. 
21 
BY MR. EDWARDS: 
22 
Q. And is there a formal memorialization of 
22 
Q. I asked for you to identify anyone else 
23 
the attorney-client relationship between yourself 
23 
that provided you information about Paul Cassell 
24 
and Nancy Gertner? 
24 
that helped to form your opinions. Your answer was. 
25 
A. I don't know the answer to that as we sit 
25 
a BBC reporter. Do you know her name? 
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A. You must. because you know its a her. 
1
understand exactly what you're saying to this BBC 
2 
Q. I'm asking you, do you know her name? 
2 
reporter that you have identified that provided you 
3 
A. I provided it and we have — it's pm of 
3
information that helped to support your opinions 
4 
the record. 
4 
about Paul Cassell. 
S 
Q. As you sit here today, do you know her 
5 
A. •That's right. 
6 
name? 
6 
Q. Okay. That person provided you an e-mail 
7 
A. No. I don't know the names of 'Toners. 
7
or you saw through this person an e-mail that Paul 
8 
Q. Okay. And the thing that that BBC 
8
Cassell — that evidenced questions that Paul 
9 
reporter whose name you do not know right now -- 
9
Cassell wanted you to be asked? 
10 
A. But I can get it for you. 
10 
A. It was my recollection it was an c-null 
11 
Q. I'm just describing the reporter since you 
11
from Paul Cassell to the producer is my 
12 
don't know her name. The reporter whose name you do 
12
recollection. 
13 
not recall right now provided you an e-mail -- 
13 
Q. Okay. In addition -- so my question 
14 
A. No. 
14 
that's pending is., in addition to the questions. is 
15 
Q. Showed you an e-mail? 
15
there anything in the body of that e-mail or that 
16 
A. No. 
16
you were told by this reporter that Paul Cassell 
11 
MIL SCOTT: Let him ask the question. 
17
spoke or communicated with the BBC beyond the 
18 
SPECIAL MASTER POZZUOLI: Let hint finish. 
18 
content of those questions? 
19 
BY MR. EDWARDS: 
19 
A. Yes, the reporter told Inc that Paul 
20 
Q. I understood your testimony, and please 
20 
Cassell had spoken to him, and my recollection is 
21 
correct me if I'm wrong, that this BB(' reporter 
21 
that they had spoken and then he sent him a 
22 
showed you an e-mail of questions from Paul Cassell 
22 
follow-up e-mail is my recollection. Again, it's a 
23 
that were requested by Paul Cassell to be directed 
23 
year ago. And this was at the time that Paul 
24 
to you. 
24 
Cassell was saying and you were saying through your 
25 
A. Yes. But it 
done by 
25 
lawyers and certainly trying to convey the 
was not 
the reporter. 
770 
772 
1 
It was done by the producer. It was a man producer. 
1 
impression that you was trying to keep this case 
2 
And he told me and showed me on his BlackBerry or 
2 
out of the media and that it was I who was putting 
3
his iPhone the questions that Paul Cassell had asked 
3
it into the media. while it turns out that 
4 
him to ask me. 
4 
secretly --
5 
Q. In addition to the questions that Paul 
5 
MR. EDWARDS: Object. Move to strike as 
6 
Cassell had asked him to ask you. is it your 
6 
nonresponsive. 
7 
testimony that Paul Cassell spoke to the media about 
7 
SPECIAL MASTER POZZUOLI: Arc you almost 
8 
the allegations or the facts as Paul understood them 
8 
finished? 
9
in the case? 
9 
A. Almost done. 
10 
A. Yes. I don't about spoke. but we know that 
10 
Secretly you were communicating with the 
11
he -- yes. we know he spoke to ABC. I think I can 
11
media and trying very hard to get them to cover this 
12 
give you the names of the people he spoke to there. 
12 
story in a way negative to me. 
13 
Jim Hill. 
13 
BY MR. EDWARDS: 
19 
MR. SCAROLA: Pardon me. I think there's 
14 
Q. Was this a reporter or a producer that was 
15 
a feedback problem again. 
15 
telling you this information? 
16 
MR. SIMPSON: On the phone. there seems to 
16 
A. Producer. 
17 
be a feedback problem. 
17 
Q. And what is the name of that producer, if 
18 
MR. SCAROLA: Cross talk. 
18 
you know? 
19 
MR. INDYKE: Do you know if its coining 
19 
A. We can find that out. But I'm sure you 
20 
from Darren Indyke or another phone? 
20 
have the e-mail. rm sure Cassell has the e-mail. 
21 
SPECIAL MASTER POZZUOLI: There's no way 
21 
SPECIAL MASTER POZZUOLI: Do you know? 
22 
to know. 
22 
A. I don't know the name of the producer. 
23 
MR. SIMPSON: It's not there now. 
23 
BY MR. EDWARDS: 
29 
BY MR. EDWARDS: 
24 
Q. And what was it that this producer told 
25 
Q. [want to limit this so that I can 
25 
you that Paul told him? 
32 (Pages 769 to 772) 
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775 
1 
A. To please ask me very critical and hard 
1 
reached that 1 was guilty. So I can draw a 
2 
questions. And I assumed — this is an 
2 
reasonable inference that he was told that by Paul 
3
assumption -- that the reason the BBC may have 
3 
Cassell. 
4 
called me was they were put on to it by Paul 
4 
Q. Did the producer tell you that he was told 
5
Cassell. who urged them to call me. 
S 
anything beyond "ask Alan Dershowitz these 
6 
Q. My question. if we back up a few, though. 
6 
questions"? 
7
is beyond the substance of the questions from Paul 
7 
A. The producer told me that he had other 
8
()melt, do you have information that Paul Cassell 
8 
communications with Cassell. But beyond that. I had 
9
spoke to them? 
9 
to draw my own inferences. 
10 
A. Yes. 
10 
Q. Without you drawing your own inferences, 
11 
Q. Okay. And I think, as you said, yes. 
11 
did the producer tell you the substance of those 
12 
because I talked to this reporter. What did the 
12 
other communications with Paul Cassell beyond "ask 
13
reporter tell you that Paul Cassell said beyond the 
13 
Alan I krshon itz these questions"? 
14 
substance of those questions? 
14 
A. No. 
15 
A. It's the producer. 
15 
SPECIAL MASTER POZZUOLI: We're beginning 
16 
Q. Producer. 
16 
to approach a break. so as your deposition --
17 
A. Not the reporter. The repeater was part 
17 
find a time in the next 10 or 15 minutes or so. 
18 
of the conversation, too. but I think the 
18 
MR. EDWARDS: I think this is as good a 
19 
conversations had been between Paul Cassell and the 
19 
time as any. 
20 
producer. 
20 
711E WITNESS: I'm happy to go on. 
21 
The conclusion I drew from our 
21 
MR. SIMPSON: Take a break. 
22 
conversation was that Paul Cassell had reached out 
22 
MR. SCOTT: Take a break. 
23 
to BBC and asked to have them ask me hard questions. 
23 
SPECIAL MASTER POZZUOLI: 1 don't want to 
24 
and the questions were all very critical and hard 
24 
interrupt a flow. 
25 
questions designed to make her story believable. 
25 
MR. EDWARDS: This is good stopping point. 
774 
776 
1 
And that the producer then responded to 
1 
and then we'll take a break and be back. 
2 
Cassell and said send me an c-mail. and Cassell sent 
2 
VIDEOGRAPHER: We're going off the recccd. 
3
an e-mail with the questions listed. And they. in 
3 
The time is II:52 a.m. 
4 
fact, asked me those questions. 
9 
SPECIAL MASTER POZZUOLI: You can go off 
5 
Q. Okay. 
5 
the record but stay on the record. 
6 
A. But the point of my answer is that at the 
6 
With t‘spuct to the issues over privilege. 
7 
same time, you. Mr. Scuola. and Mr. Cassell were 
7 
and as it appears that this witness may be held 
8 
communicating to the press -- 
8 
over beyond today. I would ask the parties to 
9 
MR. EDWARDS: Object and move to strike as 
9 
discuss and see if you can agree among 
10 
nonresponsive. 
10 
yourselves how you wish. if you wish, to 
11 
SPECIAL MASTER POZZUOLI: I would agree 
11 
address those issues so that whether it's in 
12 
with that and grant the motion. Go ahead and 
12 
front of me or in front of Judge Lynch. so that 
13 
ask your next question. 
13 
in several weeks or whenever he's reset. should 
14 
BY MR. EDWARI)S: 
19 
there need to be a readdressing of questions 
15 
Q. Beyond the communication from Paul Cassell 
15 
that were not answered because of that issue. 
16 
to a producer, ask Alan Ikrshow itz these questions. 
16 
just as I'm not foretelling — don't take 
17
is it your understanding that Paul Cassell 
17 
anything in it. but just for purposes of 
18 
communicated anything further to that producer? 
18 
scheduling• we probably ought to try to deal 
19 
A. Yes. 
19 
with -- I would suggest that the parties try to 
20 
Q. Okay. What did the producer tell you that 
20 
deal with that issue between now and the next 
21 
Paul Cassell said to him beyond "ask Alan Dershowitz 
21 
time Mr. Dershowitz sits for deposition. 
22 
these questions"? 
22 
MR. SCAROLA: That absolutely makes sense. 
23 
A. Well. the producer certainly came to the 
23 
And we will be filing, after we have received 
24 
interview having been. it seemed to me, briefed by 
29 
the transcript an appropriate Motion to 
25 
Cassell and came with a conclusion that he had 
25 
Compel. and 1 think that it is best that the 
33 (Pages 773 to 776) 
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1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Court deal with that motion. 
SPECIAL MASTER POZZUOLI: fm --
MR. SCAROLA: I think it's beyond the 
scope of the responsibilities that have been 
agreed to be resolved by you. and that would be 
our request. 
SPECIAL MASTER POZZUOLI: Okay. I wanted 
to raise that just from the purposes of just an 
administrative standpoint. 
MR. SCAROLA: Yes. Thank you very much. 
(Recess was held from 11:54 a.m. until 1:04 p.m. 
after which the proceedings continued in Volume 6.) 
CERTIFICATE OF REPORTER 
STATE OF FLORIDA 
COUNTY OF BROWARD 
I. KIMBERLY FONTALVO. Registered 
Professional Reporter. do hereby certify that I 
was authorized to and did stenographically report 
the foregoing videotape continued deposition of 
ALAN M. DERSHOWITZ; pages 648 through 455: that a 
review of the transcript was requested: and that 
the transcript is a true record of my 
stenographic notes. 
I FURTHER CERTIFY that I am not a 
relative, employee, attorney, or counsel of any 
of the parties. nor am I a relative or employee 
of any of the parties' attorneys or counsel 
connected with the action, nor am I financially 
interested in the action. 
Dated this 14th day of January. 2016. 
KIMBERLY FONTALVO. RPR. 
778 
CERTIFICATE OF OATH 
STATE OF FLORIDA 
COUNTY OF BROWARD 
I. the undersigned authority. certify 
that ALAN M. DERSUOWITZ personally appeared 
before me and was duly sworn on the 13th day of 
January. 2016. 
Signed this 17th day of I 
2016. 
i lAdaT4kitim
KIMBERLY FONTAL E. RPR. CLR 
Notary Public. State of Florida 
My Commission No. IT 226848 
Expires: 7/12/2019 
January 14.2016 
COLE SCOTT& KISSANE PA 
Dadeland Centre II . Suite 1400 
9150 South Dadeland Roulet:nil 
MUMS. Honda 33156 
BY. TI MIAS EMERSON SCOTT. JR.ESQ. 
thorn/. stottecadeptcom 
Re: Bradley Edwards. et al.. v. Alan NE Ikrshowits 
Please take notice that on the 12th day of January. 
2016. you gate your deposition in the shoe came. 
At that time. you did not waive your signature 
The above -addres.sed attorney has ordered a copy of 
thus transom and will make anangemcnu with you 
to read their copy. Please execute the Eilaln 
Sheet. AbiCh cao be found at the back of the 
transcript. and have it returned to us fix 
distribution to all pante% 
If you doom read and sign the deposition within a 
reasonable amount of unit. the anginal which has 
alreadybeen forwartkd to the ordering attorney. may 
be filed with the Clerk of the Court. 
If you wish to waive your signature now. please sign 
your name in the blot at the bottom of this Icon 
and return to the address listed below. 
Very truly run. 
KIMBERLY IONTALVO. RPR. CLR 
Phipps Reporting. Inc. 
1551 Forum Place 
Bulldog/200k Suite E 
West Palm Beach. Honda 33401 
I do hereby waive my signature. 
ALAN M. DERSIIDWITZ 
780 
34 (Pages 777 to 780) 
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781 
ERRATA SHEET 
DO NOT WRITE ON IRANSCRIIT - EATER CHANGES HERE 
In Re: BRADLEY EDWARDS. ET AL. V. ALAN M. 
DERSHONITZ 
Case No.: 
ALAN M. DERSHOWI12 
January 12.2016 
PAGE LINE 
CHANGE 
REASON 
Under tenable of rebury. I declare that I haw 
read the foregoing doeurrent and that the Lun 
Mated all dare Mit 
Uwe 
ALAN M. DERSHOWITZ 
35 (Page 781) 
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BBC (11) 
677:1 684:10,21 
652:13 653:20 
683:5 697:20 
688:4,5,9 
767:10,19 768:8 
685:8 686:1,12 
659:22 661:11 
708:8 710:2,10 
695:1 699:7,15 
768:17,25 
687:17 692:2 
662:11 665:22 
722:4,8 727:14 
708:15 709:25 
769:8,21 771:1 
698:5 706:4 
666:2,21 
741:9 757:8,12 
710:3,3,6 
771:17 773:3 
712:10 713:2,6 
667:15 668:18 
775:16,21,22 
713:22 718:6 
773:23 
721:15 733:11 
669:16 670:5 
776:1 
732:21 734:16 
Beach (3) 
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670:22 671:16 
briefed (1) 
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649:4,5 780:20 
754:2 755:5 
672:18 673:4 
774:24 
744:16,21 
beautifully (1) 
776:25 
673:24 674:2 
bring (1) 
751:14 763:5 
693:20 
better (1) 
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716:3 
765:17,18,19 
becoming (1) 
699:24 
676:21,23 
Brittany (1) 
766:8,13 773:4 
718:2 
beyond (15) 
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652:14 
calling (2) 
beginning (3) 
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680:25 681:16 
broke (1) 
686:25 719:21 
655:15 742:8 
681:20 687:9 
682:6 683:12 
681:5 
calls (9) 
775:15 
757:15 771:17 
684:18 685:1 
brought (1) 
654:3,16,23 
behalf (14) 
773:7,13 
685:16,19,22 
696:2 
655:20 667:12 
649:2,8 650:3,7 
774:15,21 
686:5,21 687:9 BROWARD (3) 
671:4 696:15 
652:12,15,18 
775:5,8,12 
689:2 691:8 
648:1 778:5 
721:13 732:6 
652:22 654:22 
776:8 777:3 
694:8,19 
779:4 
capable (2) 
657:7,10,11 
big (1) 
695:11,21 
Building (1) 
754:5 755:9 
712:5 756:18 
753:6 
697:12 698:14 
780:19 
capacity (1) 
beings (1) 
BlackBerry (1) 
698:23 700:7 
bunch (1) 
653:12 
676:3 
770:2 
701:5 703:17 
667:12 
card (2) 
belief (8) 
blank (1) 
705:9,15 
burdened (1) 
679:2 688:16 
655:13 675:20 
780:15 
706:13 707:8 
699:23 
careful (2) 
676:1,21,23 
blow (1) 
707:18 708:12 
687:3 699:16 
C 
680:25 689:7 
694:3 
709:3,9 710:20 
case (33) 
CACE (1) 
750:25 
Blvd (1) 
710:24 711:1,3 
648:2 654:13 
believable (1) 
650:8 
712:15 713:11 
648:2 
656:9 665:11 
773:25 
body (1) 
714:15 716:6 
calendar (2) 
668:14 671:6,8 
believe (17) 
771:15 
716:20 717:4 
695:3,6 
672:14 675:5 
668:14 684:3 
Boies (3) 
717:18 718:14 
call (21) 
697:1,1,3,9 
693:3 713:20 
650:8 652:20 
718:19,19 
654:10 658:16 
700:23 708:14 
741:11 753:17 
727:4 
719:9,9 720:3 
669:15 673:8 
709:11,23 
753:20 754:1.5 bono (2) 
720:4,5.1/.16 
681:5,5,5,7,12 
710:5.19 
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711:17,18,19 
714:6 715:16 
723:3,20 725:5 
734:5 745:21 
748:24 770:9 
772:1 781:4 
cases (8) 
656:12 675:20 
686:6 694:9 
753:15,16,20 
754:1,4 755:3 
755:8,22,25 
756:7,11 757:2 
757:5 758:3,5 
759:11 761:19 
763:1,19 764:6 
764:19 765:2,9 
765:18,22 
certainty (1) 
756:2 
Certificate (4) 
651:7,7 778:1 
779:1 
certify (3) 
778:8 779:7,14 
cetera (1) 
665:4 
711:18 
claim (4) 
688:10 753:21 
754:6 755:10 
claimed (1) 
713:11 
claiming (5) 
657:3 735:10 
736:3 737:17 
747:16 
client's (1) 
660:20 
clients (3) 
657:9 664:14 
665:6 
clippings (1) 
677:11 
close (3) 
695:16 698:9 
766:1,8,8,11 
chairman (1) 
767:12 
684:18 686:10 
732:24 733:17 
766:18 767:7 
672:4 
clarification (2) 
701:13 
Cassell (151) 
767:11,11,22 
challenge (1) 
726:11 738:18 
closed (1) 
648:4 652:6,14 
768:13,23 
693:22 
class (4) 
723:10 
653:20 654:17 
769:22,23 
challenging (1) 
654:18 763:2,7 
CLR (4) 
656:3 657:4 
770:3,6,7 
733:7 
764:8 
648:20 778:15 
658:11 659:22 
771:4,8,9,11 
change (4) 
classes (1) 
779:22 780:18 
660:15,19 
771:16,20,24 
665:7 750:7,17 
744:14 
coerce (1) 
661:10 662:11 
772:20 773:5,8 
781:7 
clean (1) 
715:8 
663:6,9 665:22 
773:8,13,19,22 CHANGES (1) 
746:10 
coerced (1) 
666:3 676:2,24 
774:2,2,7,15 
781:2 
cleaner (1) 
715:7 
679:24 694:6 
774:17,21,25 
character (3) 
691:7 
Cohen (3) 
694:20 720:6 
775:3,8,12 
753:15,24 755:1 clear (23) 
724:3 726:17,19 
720:13,17,19 
Cassell's (7) 
characterizati... 
655:5 660:21,23 COLE (2) 
720:20,25 
748:10 752:25 
664:5 
698:12 704:11 
649:9 780:2 
721:3,5 728:17 
753:1,4,24 
charge (1) 
715:11 722:18 
colleague (2) 
728:21,23 
755:1 763:7 
714:8 
725:4 730:6 
652:20 744:14 
729:6,19,21,24 catch (1) 
charges (1) 
739:1,17 
combination (1) 
730:25 731:10 
727:8 
722:2 
740:19 746:15 
747:25 
731:19 732:4,7 categorically (2) check (8) 
746:20 751:5,9 combined (1) 
732:23 733:6 
767:16,22 
669:12 688:14 
756:12,15 
749:9 
733:10,17 
category (2) 
688:16 718:10 
759:18 760:4 
come (5) 
734:13,17,20 
732:22 734:18 
742:14 744:22 
760:23 763:4 
656:20 661:5 
734:23 735:6 
cause (1) 
761:20 762:5 
768:19 
727:6,15 741:9 
735:11 736:4 
780:7 
checking (1) 
clearer (3) 
coming (2) 
737:18 739:25 
Centre (2) 
721:11 
660:24,24 
718:9 770:19 
740:24 741:18 
649:9 780:2 
Chicago (1) 
746:17 
comment (4) 
741:22 742:6 
certain (3) 
733:24 
clearly (6) 
672:22 721:24 
742:22 743:3 
668:16 728:16 
CIRCUIT (2) 
655:10 660:13 
756:20,21 
743:16,20 
733:19 
648:1,1 
672:13 709:24 
comments (1) 
744:4,15,20 
certainly (14) 
circulated (2) 
719:1 746:19 
666:16 
745:3,11,12,24 
655:11 684:22 
747:10 749:8 
Clerk (1) 
commission (3) 
746:13 747:15 
688:22 701:11 
circumstances... 780:13 
768:2,6 778:16 
747:19 748:15 
702:20 703:3 
705:12 747:2 
client (12) 
committee (1) 
749:23 750:1 
710:6 713:17 
748:21 
664:9,21,25 
672:5 
750:10,24 
715:20 754:9 
City (1) 
665:7,8 669:25 common (11) 
751:6,22,23,25 
755:13 765:5 
712:5 
670:21 738:9 
664:8,11,12 
752:43.16.17 
771:25 774:23 
civil (1) 
740:15 741:4.5 
666:24 704:18 
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706:8,19 707:6 
729:11 735:24 
741:23 
conceivably (1) 
679:2 
concern (2) 
confidentialit... 
722:16 723:19 
724:20 725:6 
730:21 746:20 
762:3 
continued (6) 
conveyed (1) 
747:14 
convicted (1) 
communicate ... 
654:21 767:21 
725:18 
648:10 650:1 
715:24 
765:9 
concerning (1) 
confirmed (1) 
652:1 658:8 
conviction (8) 
communicate... 
732:17 
655:9 
777:12 779:9 
713:16 714:2,3 
688:22 696:23 
concisely (1) 
confused (1) 
continuing (6) 
714:5,8,11,13 
765:8 771:17 
737:25 
714:3 
660:6 685:3,10 
714:22 
774:18 
conclude (3) 
connected (1) 
685:25 695:23 
convinced (1) 
communicatin... 686:3 689:1 
779:18 
695:24 
656:23 
772:10 774:8 
767:14 
connection (1) 
continuum (3) 
coordination (1) 
communicatio... concluded (2) 
724:22 
664:23 665:5,14 
657:1 
680:24 687:18 
698:23 767:20 
consequence (2) contribute (4) 
copy (2) 
735:11 736:4 
conclusion (27) 
674:24 704:1 
745:25 746:3 
780:8,9 
737:18 742:13 
661:6 680:19 
consider (1) 
763:14,17 
correct (9) 
742:22 759:23 
682:11 684:23 
726:12 
contributed (8) 
673:9 715:18 
761:14 774:15 
686:20 689:7 
consideration ... 680:20 684: I I 
727:11 728:18 
communicatio... 
695:14,20 
716:1 
689:7 746:7,11 
731:20 735:1 
667:2 674:7,12 
696:4 698:13 
consistent (8) 
750:8,24 
738:19 748:20 
735:3,5,7,10 
698:16,18 
660:8 704:25 
755:20 
769:21 
736:3 737:17 
709:16 711:8 
705:23 724:12 
contrived (7) 
correction (1) 
738:8 742:5,23 
711:11 714:20 
738:24 739:13 
694:13,21 720:9 
739:6 
742:24 743:2 
716:21,24 
742:3 752:8 
720:18 721:6 
Correctly (1) 
746:6 759:10 
717:8 731:1 
constantly (1) 
746:13 748:3 
676:11 
759:21 775:8 
734:24 735:6 
658:19 
contriving (1) 
corroborated ... 
775:12 
742:4 753:7,10 constitutionall... 748:7 
716:11 
community (1) 
773:21 774:25 
747:1 
controversial... counsel (11) 
695:18 
conclusions (1) 
consult (2) 
763:15 
712:1 723:23 
Compel (1) 
763:14 
740:6 741:12 
conversation (... 
724:18,24 
776:25 
conclusively (1) 
contact (7) 
668:25 677:2,4 
725:4 726:9,23 
complained (1) 
655:13 
655:2 713:9,14 
686:13,24 
740:7 741:12 
713:3 
concocted (2) 
718:18 719:8 
687:2 698:6 
779:15,17 
Complaint (5) 
661:1 747:20 
720:3,18 
708:11 720:23 
counsel's (1) 
661:20 664:10 
conduct (1) 
contend (1) 
730:15 744:12 
727:7 
670:21 672:21 
721:17 
723:9 
749:25 750:1 
countersuit (1) 
715:7 
conferring (4) 
contends (1) 
751:21 752:2 
701:17 
complaints (2) 
700:20 703:17 
709:22 
753:2,4 755:20 COUNTY (3) 
664:9 712:4 
705:8,14 
content (3) 
773:18,22 
648:1 778:5 
complete (3) 
confession (2) 
674:12 704:2 
conversations ... 
779:4 
671:14 677:16 
732:24 733:17 
771:18 
677:6 698:17 
couple (2) 
713:6 
confessions (3) 
contents (2) 
701:12 734:22 
722:5 727:19 
completely (2) 
732:8,18 752:21 
704:20 736:13 
753:11 754:10 
course (12) 
687:14 756:23 
confidence (5) 
context (13) 
755:14 756:16 
655:1 658:8 
complicated (2) 
746:11 751:1 
655:24 692:9,11 
773:19 
672:9,20 
675:24 765:12 
757:1 758:4,14 
692:12,25 
convey (4) 
674:19 687:2 
compound (1) 
confidential (2) 
693:15 696:18 
753:19,23 
689:4 707:25 
689:6 
722:24 723:24 
713:6 730:5.8 
754:25 771:25 
712:25 715:19 
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