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correct? 
2 
A. 
I do. 
3 
Q. 
And you know her through Jeffrey Epstein, 
4 
right? 
5 
MR. INDYKE: Same objection, same 
6 
instruction. 
7 
A. 
I wrote an article about her father's 
8 
death years ago, and I don't remember if I met her 
9 
independently. I do remember meeting her through 
10 
her -- I remember that the Lady Rothschild asked me 
11 
to meet Jeffrey Epstein, and when Jeffrey Epstein 
12 
came to meet me, he was with Ghislaine Maxwell. 
13 
BY MR. EDWARDS: 
14 
Q. 
And when was that? 
15 
A. 
The first time I Jeffrey Epstein, which 
16 
would have been in the summer of Leslie Wexner's 
17 
59th birthday. That's all I can tell you is the 
18 
summer of his 59th birthday because I then flew with 
19 
Jeffrey Epstein to Leslie Wexner's 59th birthday. I 
20 
was presented to Leslie Wexner. Leslie would like 
21 
to get as birthday gifts interesting people that his 
22 
friends had met during the year, and so I was 
23 
Jeffrey Epstein's intellectual gift to Leslie 
24 
Wexner. And it was that year that I met Jeffrey 
25 
Epstein. That's the best I can date it. 
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14 
15 
Q. 
I'm asking about your conversations with 
16 
Ghislaine Maxwell, who's in a separate litigation, 
17 
civil litigation for defamation. Have you 
18 
personally spoken with Ghislaine Maxwell since these 
19 
allegations? 
20 
A. 
If there's no objection, I will answer. 
21 
MR. INDYKE: There was an objection. Same 
22 
objection, same instruction. 
23 
BY MR. EDWARDS: 
24 
Q. 
Is there a joint defense agreement related 
25 
to the civil allegation -- actions regarding the 
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defamation actions that involve Ghislaine Maxwell 
2 
and yourself? 
3 
MR. INDYKE: Same objection. 
4 
SPECIAL MASTER POZZUOLI: What's the 
5 
basis -- can you explain to me what the basis 
6 
of the objection is -- and what was the 
7 
question? 
8 
MR. EDWARDS: Has Mr. Dershowitz spoken 
9 
with Ghislaine Maxwell since the allegations --
10 
since this defamation suit came about as well 
11 
as the defamation suit with Ghislaine Maxwell. 
12 
BY MR. EDWARDS: 
13 
Q. 
Let me ask it cleaner. Have you spoken 
14 
with Ghislaine Maxwell since January 2015? 
15 
MR. INDYKE: Same objection, same 
16 
instruction. 
17 
BY MR. EDWARDS: 
18 
Q. 
So that I'm clear, there is a joint 
19 
defense of the allegations regarding Ghislaine 
20 
Maxwell that's New York litigation and this 
21 
defamation case? 
22 
MR. INDYKE: There's a common interest 
23 
agreement in effect with respect to the 
24 
New York case and a common interest agreement 
25 
with respect to this case. 
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BY MR. EDWARDS: 
2 
Q. 
Okay. Was 
lying when she 
3 
says that she was taken by Ghislaine Maxwell and 
4 
MR. SCAROLA: Who negotiated the agreement 
5 
and when? 
6 
BY MR. EDWARDS: 
7 
Q. 
Is there a common interest agreement in 
8 
existence with respect to the allegations that have 
9 
arisen since January of 2015 or that you contend 
10 
covers that? 
11 
MR. INDYKE: Same objection, same 
12 
instruction. 
13 
BY MR. EDWARDS: 
14 
Q. 
If there is, who negotiated this 
15 
agreement? 
16 
MR. SCAROLA: Can we have a ruling on 
17 
propriety? 
18 
SPECIAL MASTER POZZUOLI: You haven't 
19 
pushed me, so I let you go. 
20 
MR. SCAROLA: Can we have a ruling as to 
21 
whether we get to know whether Mr. Dershowitz 
22 
is a party to a common interest agreement with 
23 
Ghislaine Maxwell? 
24 
SPECIAL MASTER POZZUOLI: Counsel 
25 
MS. McCAWLEY: Also, just this is Sigrid 
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McCawley, if any of the individuals on the 
2 
phone are representing Ghislaine Maxwell, my 
3 
understanding is the person on the phone is 
4 
representing Jeffrey Epstein, not Ghislaine 
5 
Maxwell. That needs to be clarified. 
6 
MR. INDYKE: Correct. Correct. 
7 
SPECIAL MASTER POZZUOLI: The answer is 
8 
correct? 
9 
MR. INDYKE: With respect to Mr. Epstein, 
10 
I can tell you there's a common interest 
11 
agreement with respect to this matter and a 
12 
common interest agreement with respect to the 
13 
Ghislaine Maxwell suit in New York. 
14 
SPECIAL MASTER POZZUOLI: Is 
15 
Mr. Dershowitz party to that? 
16 
MR. INDYKE: Mr. Dershowitz is party to a 
17 
common interest agreement with Jeffrey in this 
18 
case. And I believe -- I'd have to check, but 
19 
I believe that that would extend 
20 
MR. SCAROLA: We want an answer from the 
21 
witness as to whether the witness is a party to 
22 
a common interest agreement with Ghislaine 
23 
Maxwell. 
24 
SPECIAL MASTER POZZUOLI: Then ask the 
25 
question, because I haven't seen the question 
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asked yet. 
2 
BY MR. EDWARDS: 
3 
Q. 
Are you a party to a common interest 
4 
agreement with Ghislaine Maxwell? 
5 
A. 
If there's no objection, I'll answer it. 
6 
MR. INDYKE: I apologize. I thought we 
7 
were still operating under the original set of 
8 
objections. So I will repeat it. Same 
9 
objection, same instruction. 
10 
SPECIAL MASTER POZZUOLI: With respect to 
11 
that question, you can answer 
12 
A. 
My understanding is that I am still 
13 
Jeffrey Epstein's lawyer. Jeffrey Epstein, I 
14 
understand, has a common interest or joint defense 
15 
agreement with Ghislaine Maxwell, so I have -- my 
16 
understanding is that I am bound by a common 
17 
agreement. 
18 
BY MR. EDWARDS: 
19 
Q. 
Is this the same common interest agreement 
20 
that we were talking about from 2005, or is this a 
21 
separate common interest agreement that has been 
22 
signed as a consequence of the lawsuits that have 
23 
been filed since January 2015? 
24 
MR. INDYKE: If this is a new question, 
25 
I'll assert the same objection and the same 
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instruction. 
2 
SPECIAL MASTER POZZUOLI: And I'm going to 
3 
overrule the objection. And you can answer 
4 
that. 
5 
A. 
My understanding is that it's a 
6 
combination; that is, it reflects the previous 
7 
agreement and that there is a new agreement that 
8 
supplemented the previous agreement. 
9 
BY MR. EDWARDS: 
10 
Q. 
When you say it's your understanding, is 
11 
this understanding in writing; meaning, is there a 
12 
written common interest agreement that has been put 
13 
in place since January of 2015? 
14 
A. 
I don't know. 
15 
MR. INDYKE: Same objection, same 
16 
instruction. 
17 
MR. SCOTT: Can we take a recess when we 
18 
get a chance? 
19 
SPECIAL MASTER POZZUOLI: Yes, but I'm 
20 
going to instruct you --
21 
A. 
I don't know. I don't know the answer to 
22 
that, whether there's additional writing or not. 
23 
BY MR. EDWARDS: 
24 
Q. 
Last question, then we take a break. Have 
25 
you signed any such agreement 
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MR. INDYKE: Same objection, same 
2 
instruction. 
3 
BY MR. EDWARDS: 
4 
Q. 
-- since January 2015? 
5 
A. 
Since January? Not to my recollection. 
6 
MR. EDWARDS: We can take a break. 
7 
VIDEOGRAPHER: Going off the record. The 
8 
time is approximately 2:09 p.m. 
9 
(Recess was held from 2:09 p.m. until 2:26 p.m.) 
10 
VIDEOGRAPHER: Going back on the record. 
11 
Time is approximately 2:26 p.m. 
12 
13 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
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says that she was paid to have sex with Prince 
13 
Andrew? 
14 
A. 
I have no idea. 
15 
Q. 
You have met Prince Andrew, right? 
16 
A. 
I have. 
17 
Q. 
He sat in the back of your classrooms? 
18 
MR. SCOTT: Objection, asked and answered 
19 
twice. 
20 
A. 
Once, yes. 
21 
BY MR. EDWARDS: 
22 
Q. 
I think we went to Jeffrey Epstein sitting 
23 
in your classrooms, but now I'm talking about Prince 
24 
Andrew sat in your classroom as well, right? 
25 
A. 
Yes, once. 
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MR. SCOTT: I thought we went through 
2 
Andrew before; maybe I'm wrong. 
3 
BY MR. EDWARDS: 
4 
Q. 
Have you, since the -- since January of 
5 
2015, have you contacted Prince Andrew? 
6 
A. 
No. I got a Christmas card from him. 
7 
Q. 
Have you spoke with him about the 
8 
allegations that were alleged against Prince Andrew? 
9 
A. 
Not to him, but to -- not to him. 
10 
Q. 
Have you spoke to some representative of 
11 
his, of Prince Andrew? 
12 
A. 
I need to know whether --
13 
MR. INDYKE: Guy, sorry, I was just cut 
14 
off for some reason. 
15 
SPECIAL MASTER POZZUOLI: Hold on a 
16 
second. Go ahead and restate your question 
17 
so -- Darren, can you hear now? 
18 
MR. INDYKE: Yes, I can. 
19 
BY MR. EDWARDS: 
20 
Q. 
My question is, have you spoken with 
21 
Prince Andrew or any representative of or for Prince 
22 
Andrew since January of 2015? 
23 
MR. SCOTT: If any of that involved work 
24 
product on our part, I am instructing you not 
25 
to answer. 
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MR. INDYKE: Same objection, same 
2 
instruction on my end as well. 
3 
BY MR. EDWARDS: 
4 
Q. 
Whether or not you have spoken with him 
5 
would not be protected. 
6 
A. 
I have not spoken to him. 
7 
MR. SCOTT: That, I don't have a problem 
8 
with. 
9 
BY MR. EDWARDS: 
10 
Q. 
Have you spoken with any representative of 
11 
Prince Andrew since January of 2015? 
12 
A. 
Is there any objection? I don't think I 
13 
have, but I think my lawyers have. But I don't 
14 
think I have. 
15 
MR. SCOTT: Don't go into any work 
16 
product. 
17 
A. 
I don't think I have. 
18 
BY MR. EDWARDS: 
19 
Q. 
Do you know that some representative of 
20 
yours has spoken with some representative of Prince 
21 
Andrew since January of 2015? 
22 
A. 
I think so, yes. 
23 
Q. 
Is Prince Andrew a party to any joint 
24 
defense agreement? 
25 
A. 
Not that I am --
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MR. INDYKE: Same objection, same 
2 
instruction. 
3 
A. 
I'm not aware of any. 
4 
BY MR. EDWARDS: 
5 
Q. 
Okay. Do you know which representative 
6 
which of your representatives communicated with 
7 
which of Prince Andrew's representatives? 
8 
A. 
No. I do remember being told, though, 
9 
that there was a call from Prince Andrew's people to 
10 
one of my lawyers, but that's all I know. 
11 
Q. 
So when I'm asking you whether 
■ 
is lying about having sex with Prince Andrew 
13 
when she was under the age of 18, do you know the 
14 
answer to that question from --
15 
MR. INDYKE: Same objection, same 
16 
instruction. 
17 
A. 
Same answer. If it's based on her own 
18 
statement, I have no reason to believe it. If 
19 
there's other objective evidence, I'm not aware of 
20 
it. 
21 
I have no 
22 
reason to believe she would be telling the truth. 
23 
But I don't have any personal knowledge of that. 
24 
BY MR. EDWARDS: 
25 
Q. 
What information do you have from Prince 
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2 
3 
4 
Andrew's representative on that subject? 
MR. SCOTT: Don't answer that question. 
MR. INDYKE: Same objection, same 
instruction. 
5 
A. 
I can say publicly --
6 
MR. SCOTT: Don't answer that. You've 
7 
been told. 
8 
A. 
Okay, I'm sorry. 
9 
BY MR. EDWARDS: 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
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2 
3 
Q. 
Ghislaine Maxwell has been friends and 
4 
acquaintances of Prince Andrew for a very long time. 
5 
You know that, right? 
6 
MR. INDYKE: Same objection, same 
7 
instruction. 
8 
BY MR. EDWARDS: 
9 
Q. 
Is that privileged, the answer to that 
10 
question, Ghislaine Maxwell's relationship with 
11 
Prince Andrew? Let me ask it this ■ 
--
12 
MR. INDYKE: To the extent that 
13 
Mr. Dershowitz obtained that information in 
14 
connection with his representation of Jeffrey 
15 
Epstein, of course it is. 
16 
BY MR. EDWARDS: 
17 
Q. 
I have a better ■ 
to go about this, 
18 
then. Ghislaine Maxwell and 
you met her well 
19 
before 2005, didn't you? 
20 
A. 
I did, yes. 
21 
Q. 
And Prince Andrew you met before 2005 as 
22 
well, correct? 
23 
A. 
I think it was before 2005, yeah. 
24 
Q. 
And prior to 2005, you understood that 
25 
Ghislaine Maxwell and Prince Andrew were social 
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acquaintances, didn't you? 
2 
MR. INDYKE: Same objection, same 
3 
instruction. 
4 
SPECIAL MASTER POZZUOLI: That deals with 
5 
if you have any nonprivileged. 
6 
A. 
I do. 
7 
SPECIAL MASTER POZZUOLI: Then I would 
8 
overrule the objection to that extent. 
9 
A. 
I've seen them together at a party on 
10 
Martha's Vineyard given by Lady Rothschild. 
11 
BY MR. EDWARDS: 
12 
Q. 
And back at that time, prior to your 
13 
representation of Jeffrey Epstein, did he tell you 
14 
that he had been introduced to Prince Andrew through 
15 
Ghislaine Maxwell? 
16 
MR. INDYKE: Same objection, same 
17 
instruction. As Mr. Dershowitz previously 
18 
responded to the question about representation, 
19 
he said it was -- maybe he did not represent 
20 
Mr. Epstein in this case, but he represented 
21 
him in other cases. 
22 
SPECIAL MASTER POZZUOLI: I will overrule 
23 
the objection to the extent that you have 
24 
nonprivileged information that you can base the 
25 
answer. 
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A. 
Yes. And in a letter that Prince Andrew 
2 
wrote to me thanking me for inviting him to my class 
3 
and having the dinner for him at Harvard Law School, 
4 
he made a reference to Jeffrey Epstein. 
5 
BY MR. EDWARDS: 
6 
Q. 
And when was -- when did Prince Andrew 
7 
write a letter to you? 
8 
A. 
When he came to my class at Harvard Law 
9 
School, just a thank-you note. 
10 
Q. 
What was the approximate date of that 
11 
letter? 
12 
A. 
I don't know. 
13 
Q. 
What was the approximate year of the 
14 
letter? 
15 
A. 
I don't know. 
16 
Q. 
Do you still have the letter? 
17 
A. 
I'll check. 
18 
Q. 
Is there any reason why you haven't 
19 
personally contacted Prince Andrew to discuss these 
20 
allegations? 
21 
MR. SCOTT: Objection, hypothetical, 
22 
speculation. 
23 
A. 
Not easy to reach the Queen, not easy to 
24 
reach the Prince. I don't know who I would call. 
25 
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BY MR. EDWARDS: 
2 
Q. 
Couldn't you just call Ghislaine Maxwell, 
3 
though? It's not that easy for many people. 
4 
Couldn't you call Ghislaine? 
5 
MR. INDYKE: Objection. 
6 
MR. SCOTT: Argumentative. 
7 
BY MR. EDWARDS: 
8 
Q. 
Do you know the circumstances -- as you 
9 
sit here, the circumstances that led to this 
10 
photograph being taken in London? 
11 
A. 
No. 
12 
MR. INDYKE: Same objection, same 
13 
instruction. 
14 
BY MR. EDWARDS: 
15 
Q. 
Have you ever seen photographs or the 
16 
copies of photographs of young naked teenage girls 
17 
that were taken from within the closet of Jeffrey 
18 
Epstein's home in Palm Beach? 
19 
A. 
Absolutely not. 
20 
MR. INDYKE: Same objection, same 
21 
instruction. 
22 
BY MR. EDWARDS: 
23 
Q. 
Have you ever attempted to get those 
24 
photographs from the law enforcement 
25 
MR. SCOTT: Let the lawyer make his 
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objection before you respond, Professor 
2 
Dershowitz. 
3 
MR. INDYKE: Finish your question, please. 
4 
BY MR. EDWARDS: 
5 
Q. 
Have you ever attempted to obtain those 
6 
photographs taken through the search warrant of 
7 
Jeffrey Epstein's home from law enforcement? 
8 
MR. INDYKE: Same objection, same 
9 
instruction. 
10 
MR. EDWARDS: He's being instructed not to 
11 
answer whether he's ever attempted to obtain 
12 
the photographs? 
13 
MR. INDYKE: If it was done in connection 
14 
with his representation of Mr. Epstein, it's 
15 
work product. 
16 
BY MR. EDWARDS: 
17 
Q. 
But I'm asking about communication that 
18 
you had with law enforcement. Are you claiming that 
19 
the communication you had with law enforcement is 
20 
protected by privilege? 
21 
MR. SCOTT: He's not claiming anything. 
22 
He's being instructed by a lawyer. 
23 
MR. EDWARDS: Okay. Well, I want to 
24 
understand what the record is --
25 
MR. SCOTT: Then ask the lawyer, not my 
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client. 
2 
MR. EDWARDS: Darren, is that you? 
3 
MR. INDYKE: That is me, yes. 
4 
MR. EDWARDS: Are you saying that 
5 
Mr. Dershowitz or any of Jeffrey Epstein's 
6 
legal team, that their communication with law 
7 
enforcement is privileged? 
8 
MR. INDYKE: Whether or not such 
9 
communication exists and if they've never been 
10 
used, yes. 
11 
BY MR. EDWARDS: 
12 
Q. 
Do you know whether the photographs of 
13 
young, naked teenage girls that were taken within 
14 
Jeffrey Epstein's home contain photographs of 
15 
while she was a young girl? 
16 
MR. INDYKE: Same objection, same 
17 
instruction. 
18 
A. 
Of course not. I've never seen those 
19 
photographs. But here I can answer nowhere, if I 
20 
ever was with Jeffrey Epstein in any of his homes, 
21 
did I ever see a naked photograph of anybody except 
22 
for a Rodin model, which was a sepia print in the 
23 
entranceway, kind of a classic Rodin model print, 
24 
but I've never, ever seen any photograph of any 
25 
naked, underage, inappropriate -- my grandchildren 
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