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1 
MR. SCAROLA: Move to strike. 
2 
SPECIAL MASTER POZZUOLI: That, I will 
3 
strike. Move forward. 
4 
BY MR. EDWARDS: 
5 
Q. 
Was 
lying when she says that 
6 
Jeffrey Epstein also had sex with a girl named 
8 
9 
MR. INDYKE: Same objections, same 
10 
instruction. 
11 
MR. SCOTT: Can you answer that? 
12 
A. 
I've never heard that name. It's not 
13 
familiar to me at all. 
14 
BY MR. EDWARDS: 
15 
Q. 
Was 
lying when she says 
16 
she traveled to Jeffrey Epstein's island when 
17 
underage? 
18 
MR. INDYKE: Same objections, same 
19 
instruction. 
20 
BY MR. EDWARDS: 
21 
Q. 
By "underage," I mean under the age of 18. 
22 
A. 
I can only tell you I never saw her on the 
23 
island. I was on the island when she was not there. 
24 
I would love to know whole story she was 
25 
on the island --
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MR. SCOTT: There's no question pending. 
2 
BY MR. EDWARDS: 
3 
Q. 
The two-page flight log exhibit, if we 
4 
look at January 22nd, 2001, and also 
5 
December 14th, 2000, can you look at those, and 
6 
I'll ask a question. 
7 
A. 
Sure. Give me the dates again. 
8 
January 16? 
9 
Q. 
Where it has the departing airport code 
10 
and 
11 
A. 
Yeah. 
12 
Q. 
-- where she's landing. 
13 
A. 
Right. 
14 
Q. 
TIST is the code for Virgin Islands, 
15 
correct? 
16 
A. 
I have no idea. Been to the Virgin 
17 
Islands once that I remember. 
18 
Q. 
You have been to Jeffrey Epstein's home on 
19 
the Virgin Islands, haven't you? 
20 
MR. SCOTT: He's already answered that. 
21 
A. 
I was with my wife and my daughter and 
22 
Professor 
23 
BY MR. EDWARDS: 
24 
Q. 
I don't mean to ask who you went with -- I 
25 
didn't mean to ask --
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SPECIAL MASTER POZZUOLI: Hang on. Let 
2 
him finish his answer. I think this is 
3 
contextual. I'm okay with it. 
4 
A. 
And six months before 
5 
ever met Jeffrey Epstein. So I was never on the 
6 
island during the period of time that Jeffrey 
7 
Epstein knew 
8 
SPECIAL MASTER POZZUOLI: Go ahead. 
9 
BY MR. EDWARDS: 
10 
Q. 
My question was, how did you get to the 
11 
island? 
12 
A. 
Jeffrey Epstein sent a one-engine, small 
13 
plane with a 70-year-old pilot for me, my wife and 
14 
my daughter, and I regret to this day ever getting 
15 
on that plane. Flew us from Guadalupe to the Virgin 
16 
Islands, where I was picked up by a boat and taken 
17 
to Jeffrey Epstein's island where we had dinner with 
18 
Michael Porter and his wife and family and my wife 
19 
and my daughter, and stayed, as far as we remember, 
20 
for one night and left the next day. 
21 
Q. 
How did you get to Guadalupe? 
22 
A. 
Jeffrey Epstein flew us from Charleston, 
23 
South Carolina, where we were visiting Caroline, my 
24 
wife's mother, on an airplane that had a bathroom 
25 
that had only a little curtain. That's all I 
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remember about it. 
2 
Q. 
What was the date of that trip that you're 
3 
describing that you took Jeffrey Epstein's island? 
4 
MR. SCOTT: If you know. 
5 
A. 
It was six months or eight months before 
6 
she ever met Jeffrey Epstein, so it would be 
7 
Christmas, around Christmastime, around Christmas 
8 
vacation of the year 1998, to my recollection. But 
9 
I would have to check. 
10 
When it is she met Jeffrey Epstein in that 
11 
summer, it was the winter before that. That's the 
12 
only time I've ever been on the island, so her 
13 
statement that she had sex with me on the island is 
14 
totally, categorically made up. 
15 
BY MR. EDWARDS: 
16 
Q. 
My question is, where is the flight log of 
17 
that trip that you just described? 
18 
A. 
Neither flight -- neither flight was on 
19 
Jeffrey Epstein's airplane. The flight that we went 
20 
from Charleston to Guadalupe, somebody owed Jeffrey 
21 
Epstein several hours on an airplane, so Jeffrey 
22 
borrowed his Learjet, it was a Learjet, borrowed his 
23 
Learjet, two or three hours on the Learjet because 
24 
it would have taken us ten hours to fly from 
25 
Charleston to Atlanta, Atlanta to Puerto Rico and 
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1 
2 
3 
4 
5 
6 
Miami, and Miami or Puerto Rico to Guadalupe. 
So Jeffrey offered to use the credit he 
had with someone else on a Learjet to fly us to 
Guadalupe, and then used -- then rented -- it was 
$1,200, I remember seeing the bill, to fly the small 
airplane from Guadalupe. He was anxious for us to 
7 
see his newly bought -- relatively newly bought 
8 
island, and so we went there with my daughter and we 
9 
dug around in the sand and we had dinner with the 
10 
various professors and that. Then we left. 
11 
Q. 
So there are no flight manifests --
12 
A. 
I have no idea. 
13 
Q. 
-- for the trip that you just described? 
14 
A. 
I have no idea. There probably are, 
15 
probably on the Learjet is probably the manifest. 
16 
Q. 
In fact, in the statements that the flight 
17 
manifests will conclusively and demonstratively 
18 
exonerate you --
19 
A. 
That's true. 
20 
Q. 
-- where can we get the full flight 
21 
manifests so that we can review and make that 
22 
determination for ourselves? Do you know? 
23 
A. 
I assume --
24 
MR. INDYKE: Objection. 
25 
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BY MR. EDWARDS: 
2 
Q. 
What we have here --
3 
MR. INDYKE: Attorney-client, work product 
4 
and common interests. 
5 
BY MR. EDWARDS: 
6 
Q. 
What we have here is only the fraction of 
7 
flights where Dave Rogers was one of the pilots. 
8 
Can you help us get the flight logs from Larry 
9 
Visosky, Larry Morrison, any of the flight logs from 
10 
the helicopters, et cetera? 
11 
A. 
I would love to. It would all show that I 
12 
wasn't on the plane. 
13 
MR. INDYKE: Same objection, same 
14 
instruction. 
15 
A. 
I will do everything in my power 
16 
MR. SCOTT: You can make any request you 
17 
want to through counsel, and we'll take them 
18 
up. 
19 
A. 
But I will do everything in my power to 
20 
get you every flight manifest. 
21 
SPECIAL MASTER POZZUOLI: Move forward. 
22 
MR. INDYKE: We do not waive any 
23 
objection. 
24 
MR. SCAROLA: And that request has been 
25 
made. 
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A. 
Is that a question? 
2 
MR. SCOTT: No. Just Mr. Scarola 
3 
MR. EDWARDS: Just that we made a request 
4 
for production. 
5 
BY MR. EDWARDS: 
6 
Q. 
Was 
lying when she says that she 
7 
was taken to Jeffrey Epstein's home in New York 
8 
while underage? 
9 
A. 
I have no idea. 
10 
MR. INDYKE: Same objection, same 
11 
instruction. 
12 
BY MR. EDWARDS: 
13 
Q. 
Was 
lying when she says she was 
14 
taken to Jeffrey Epstein's ranch in New Mexico while 
15 
underage? 
16 
MR. INDYKE: Same objection, same 
17 
instruction. 
18 
A. 
I can tell you this. She's lying when she 
19 
said she met me at the ranch. So I cannot believe 
20 
anything she says about the ranch. 
21 
BY MR. EDWARDS: 
22 
Q. 
Was she lying when she says Ghislaine 
23 
Maxwell and Jeffrey Epstein used sex toys on her 
24 
when she was underage? 
25 
MR. INDYKE: Same objection, same 
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1 
instruction. 
2 
BY MR. EDWARDS: 
3 
Q. 
Was she lying when she says Jeffrey 
4 
Epstein and Ghislaine Maxwell made her dress up in 
5 
outfits for them? 
6 
MR. INDYKE: Same objection, same 
7 
instruction. 
8 
A. 
Well, I can 
but I do have some material 
9 
outside of the record on that. 
10 
BY MR. EDWARDS: 
11 
Q. 
Okay. 
12 
A. 
I know that Sigrid McCawley said that she 
13 
said that Leslie Wexner made her dress up --
14 
MS. McCAWLEY: I am going to object to the 
15 
extent that you are trying to reveal 
16 
conversations that were part of a settlement 
17 
discussion which the judge has already sealed 
18 
the record on and there is a pending motion for 
19 
sanctions. And if you're going to start 
20 
revealing that information, we're going 
21 
directly to the Judge Lynch. 
22 
A. 
I am going to start revealing --
23 
SPECIAL MASTER POZZUOLI: No, I'm going to 
24 
stop you --
25 
THE WITNESS: Let me tell you why. 
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Because I didn't get that from Sigrid or from 
2 
David Boise. I got it from Leslie Wexner's 
3 
lawyer in a totally nonprivileged 
4 
communication. 
5 
SPECIAL MASTER POZZUOLI: Let me stop you. 
6 
I don't believe it's responsive to the question 
7 
that's pending, so let's move forward. 
8 
BY MR. EDWARDS: 
9 
Q. 
My question was, was she lying -- was 
10 
lying when she says Jeffrey Epstein 
11 
and Ghislaine Maxwell made her dress up in outfits 
12 
for them? 
13 
A. 
I can only say that that allegation has 
14 
been made regarding Leslie Wexner as well. 
15 
Q. 
It has nothing to do with my question. 
16 
MR. SCAROLA: Move to strike. 
17 
A. 
Leslie Wexner's lawyer regards that as a 
18 
full statement and, therefore, I can only assume 
19 
that it's a false statement when made about someone 
20 
else. I think that's relevant. 
21 
SPECIAL MASTER POZZUOLI: So with respect 
22 
to the --
23 
MR. EDWARDS: I'm moving to strike the 
24 
nonresponsive portion of that answer. 
25 
THE WITNESS: He opened the door. 
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1 
SPECIAL MASTER POZZUOLI: I do believe it 
2 
was nonresponsive in its entirety. Move 
3 
forward. Go ahead. 
4 
BY MR. EDWARDS: 
5 
Q. 
Do you know Jean-Luc Brunel? 
6 
A. 
No. 
7 
Q. 
Have you ever met him? 
8 
MR. INDYKE: Same objection, same 
9 
instruction. 
10 
A. 
I have no memory of ever meeting a man by 
11 
that name. 
12 
BY MR. EDWARDS: 
13 
Q. 
Do you know what his role was in Jeffrey 
14 
Epstein's life? 
15 
A. 
No. 
16 
MR. INDYKE: Same objection, same 
17 
instruction. Mr. Dershowitz, if you would let 
18 
me make my objections before you respond. 
19 
THE WITNESS: Right. 
20 
BY MR. EDWARDS: 
21 
Q. 
Was 
lying when she said 
22 
Jeffrey Epstein socialized with Bill Clinton during 
23 
the relevant time period? 
24 
MR. INDYKE: Same objection, same 
25 
instructions. 
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1 
A. 
My information is that 
2 
was lying when she said that she saw Bill Clinton on 
3 
Jeffrey Epstein's island. That's all I can comment 
4 
about with that. And she's lying about that. And 
5 
she's lying about how Bill Clinton got to the 
6 
island. 
7 
MR. EDWARDS: I move to strike the 
8 
Nonresponsive portion of the answer. 
9 
SPECIAL MASTER POZZUOLI: No, it's 
10 
relevant to what you asked. Move forward. I'm 
11 
not going to strike it. 
12 
BY MR. EDWARDS: 
13 
Q. 
I'm going to go back to the question until 
14 
I get an answer, though. 
15 
SPECIAL MASTER POZZUOLI: Go ahead. 
16 
BY MR. EDWARDS: 
17 
Q. 
That is, when 
said that 
18 
during the relevant time period, which we defined as 
19 
1999 through 2002 --
20 
A. 
Let's be clear. Around August of both of 
21 
those years, right? 
22 
Q. 
I think August of '99 through October of 
23 
2002. 
24 
A. 
September, I think it is. 
25 
Q. 
Okay. Was she lying -- was 
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lying when she said Jeffrey Epstein 
2 
socialized with Bill Clinton during that time 
3 
period? 
4 
A. 
I don't know. 
5 
MR. INDYKE: Same objection, same 
6 
instruction. 
7 
BY MR. EDWARDS: 
8 
Q. 
And you have no nonprivileged information 
9 
that would provide you the answer to that? 
10 
A. 
I have nonprivileged information that 
11 
provides me that they socialized together at some 
12 
point. I don't know whether it was within that 
13 
timeframe at all. I know they went to Africa 
14 
together on a mission of goodwill, but I don't know 
15 
the date of that. So I can't tell you whether it 
16 
was 
17 
know 
18 
19 
20 
21 
immediately disprove her statement that Bill Clinton 
22 
and Jeffrey Epstein socialized during that time 
23 
period? 
24 
A. 
I don't understand that question. 
25 
Q. 
No? 
in the period or outside the period. You may 
that; I don't. 
Q. 
Well, if Jeffrey Epstein and Bill Clinton 
associated, but only at some time period either 
before or after the relevant time period, it would 
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SPECIAL MASTER POZZUOLI: I don't 
2 
understand the question either. If you can 
3 
rephrase the question, that would be helpful. 
4 
MR. EDWARDS: Sure. 
5 
BY MR. EDWARDS: 
6 
Q. 
If you -- do you know from nonprivileged 
7 
information whether Jeffrey Epstein and Bill Clinton 
8 
ever socialized? 
9 
A. 
Yes. 
10 
Q. 
Do you know the beginning -- when their 
11 
relationship began? 
12 
MR. INDYKE: Objection. Same objection, 
13 
same instruction. 
14 
SPECIAL MASTER POZZUOLI: Again, under 
15 
nonprivileged. 
16 
MR. EDWARDS: Under nonprivileged 
17 
information. 
18 
MR. SCOTT: Do you have any nonprivileged 
19 
information about that? 
20 
A. 
I remember having dinner at the home of 
21 
Caroline Kennedy and Ed Schlossberg with President 
22 
Clinton, and he basically asked me how Jeffrey was 
23 
doing, and led me to believe that he had some 
24 
relationship with Jeffrey. I don't remember whether 
25 
that dinner -- when that dinner was. I can probably 
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1 
find out. But that would be nonprivileged. 
2 
BY MR. EDWARDS: 
3 
Q. 
Was he still President at the time that 
4 
conversation was taking place? 
5 
A. 
I don't remember. 
6 
Q. 
Have you ever been, yourself, together 
7 
with Jeffrey Epstein and Bill Clinton? 
8 
A. 
No. 
9 
Q. 
Have you ever talked to Jeffrey Epstein 
10 
about Bill Clinton? 
11 
MR. INDYKE: Objection. Same objection, 
12 
same instruction. 
13 
SPECIAL MASTER POZZUOLI: Nonprivileged. 
14 
MR. EDWARDS: Yeah, nonprivileged. 
15 
A. 
It's hard to sort out the privileged and 
16 
the nonprivileged. 
17 
SPECIAL MASTER POZZUOLI: So based upon 
18 
the objection, I would ask that you -- unless 
19 
it's obvious, then no, until we sort that out. 
20 
A. 
I shouldn't answer that probably. 
21 
SPECIAL MASTER POZZUOLI: I'm going to 
22 
grant his objection at this point, again, as a 
23 
continuum because I want to make sure that we 
24 
preserve this issue for later on. 
25 
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1 
BY MR. EDWARDS: 
2 
Q. 
In a previous -- previously in this 
3 
deposition, you indicated your representation of 
4 
Jeffrey Epstein on this subject matter began in 
5 
2005, right? 
6 
A. 
It began, I think I said, when the first 
7 
allegations were. I don't have an exact date in 
8 
mind. 
9 
Q. 
The relevant time period for 
as we've defined, is 1999 through 2002. 
11 
A. 
That's correct, yes. 
12 
Q. 
So I'm asking if you know from Jeffrey 
13 
Epstein, in a time period prior to your 
14 
representation, whether he was socializing with Bill 
15 
Clinton. 
16 
MR. INDYKE: Same objection, same 
17 
instruction. 
18 
A. 
Yes, yes. 
19 
MR. SCOTT: As long as it's a 
20 
nonprivileged situation. 
21 
A. 
He was. 
22 
BY MR. EDWARDS: 
23 
Q. 
He was? 
24 
A. 
He was. 
25 
Q. 
So prior --
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1 
A. 
During the whole period of time up through 
2 
2005, you're saying? Yes. 
3 
Q. 
Right. 
4 
A. 
Yes, I think this dinner occurred before 
5 
2005, so I would -- yes. 
6 
Q. 
So what did Jeffrey Epstein tell you about 
7 
his relationship with Bill Clinton? 
8 
MR. INDYKE: Same objection, same 
9 
instruction. 
10 
BY MR. EDWARDS: 
11 
Q. 
Prior to 2005, obviously. 
12 
A. 
That they knew each other and that they 
13 
were doing some charitable work together. 
14 
Q. 
Had Bill Clinton ever been to Jeffrey 
15 
Epstein's home? 
16 
A. 
I'm not aware. 
17 
MR. INDYKE: Same objection, same 
18 
instruction. 
19 
BY MR. EDWARDS: 
20 
Q. 
What kind of charitable work was Jeffrey 
21 
Epstein --
22 
A. 
I can tell you Donald Trump has been to 
23 
Jeffrey Epstein's home, and I've seen him there. 
24 
Q. 
Okay. What question do you think that 
25 
you're answering? 
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1 
A. 
Well, you're asking about general things 
2 
people --
3 
SPECIAL MASTER POZZUOLI: Let's move 
4 
forward. 
5 
A. 
-- so I mean, I gave you an example of one 
6 
who has been there. 
7 
BY MR. EDWARDS: 
8 
Q. 
Okay. I'm specifically talking about 
9 
when -- we started with was 
lying when she 
10 
said that Jeffrey Epstein socialized with Bill 
11 
Clinton during the relevant time period. And now 
12 
I'm drilling it. 
13 
A. 
I don't know the answer to that. 
14 
Q. 
Okay. Did you understand -- did Bill 
15 
Clinton travel with Jeffrey Epstein? 
16 
A. 
My understanding from newspaper --
17 
MR. INDYKE: Same objection, same 
18 
instruction. 
19 
20 
21 
22 
23 
24 
25 
MR. SCOTT: Can we take a break in a few 
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1 
minutes? I would like -- in the afternoon, he 
2 
gets a little tired, so I would like to, every 
3 
hour or so, take -- an hour and ten minutes, 
4 
take a couple-minute break. 
5 
SPECIAL MASTER POZZUOLI: You tell me when 
6 
is a good --
7 
MR. EDWARDS: Maybe 15 minutes and we'll 
8 
switch topics, and we can take a break. Good, 
9 
Tom? 
10 
MR. SCOTT: Yes. 
11 
MR. EDWARDS: Okay. 
12 
BY MR. EDWARDS: 
13 
Q. 
Was 
lying when she says 
14 
she was introduced to Prince Andrew through Jeffrey 
15 
Epstein? 
16 
MR. INDYKE: Same objection, same 
17 
instruction. 
18 
SPECIAL MASTER POZZUOLI: Under 
19 
non-privileged information. 
20 
A. 
I have seen a photograph of Prince Andrew 
21 
and 
and Ghislaine Maxwell. I have 
22 
myself met Prince Andrew. He came to my class at 
23 
Harvard Law School and there was a dinner for him, 
24 
and he asked about Jeffrey Epstein. We discussed 
25 
Jeffrey Epstein. 
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