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01 101 
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Q. In fact, I think you testified yesterday 
Li wit 2 
about your duty with respect to Miss Roberts along those 
x1.47 
3 
lines, correct? 
et ins 4 
A. 
That's right. 
01,11 40 
5 
Q. 
And so with respect to Professor Dershowites 
0111132 
6 
representation of Jeffrey Epstein, he would have been 
20 ,07 7 
acting unetNcally if he didn't attempt to negotiate the 
01 17 00 
8 
best resolution for his client that he could, consistent 
ot 0c, 9 
with the law; Is that correct? 
01 1701 10 
A. 
Right. Consistent with the law, yes. 
os Ins 11 
Q. 
And so you wouldn't --
0 009 12 
A. I'm sorry. Let me just -- consistent with 
01 1711 13 
the law and with the ethical obligations of attorneys. 
oi 1714 14 
Attorneys cannot make, for example, false 
ours 15 
representations when they are negotiating those kinds of 
et ir le 16 
things. 
01 1710 17 
Q. 
Right. The duty as a defense counsel, 
a rid 18 
Professor Dershowitz's duty was to attempt to obtain the 
01 1777 19 
best resolution he could for Jeffrey Epstein consistent 
with the law and legal ethics, correct? 
A. 
That's correct. 
Q. 
And, in fact, If he had not done that, he 
would have been acting unethically, correct? 
A. 
That's correct. 
Q. 
And would you agree that it would be 
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1 
MS. McCAWLEY: The location is fine. 
el wt. 2 
THE WITNESS: The location, once 
awed 
3 
personally -- once here In Florida, and then in 
01 1125 4 
my office in -- while in Salt Lake Oty. 
mini 5 
BY MR. SIMPSON: 
pin= 6 
Q. 
And are you able to place in time when you 
mo 7 
reviewed these portions of the police report, other than 
before December 30th of 2014/ 
al UM 
9 
A. 
Not precisely, no. 
Q. 
And do I understand correctly from your 
testimony yesterday that that police report ts one of 
the things you relied on to support making the 
allegations against Professor Dershowitz that are 
included in the joinder motion? 
A. 
That's right. 
Q. It's also true, is It not, that that police 
01 2001 17 
report includes an Interview with an adult woman who was 
012001 18 
retained to provide massages at Jeffrey Epstein's 
01x11 19 
residence for guests, among others; Isn't that correct? 
owl. 20 
A. 
I believe that's coned. 
01 20111 21 
Q. 
And based on that, is It your testimony that 
01 2020 22 
it's fair to presume that a reference that a guest got a 
012024 23 
massage is a code word for abusing a minor sexually? 
moil 24 
MR. SCAROLA: I'm sorry. Are you -- are you 
01 200 25 
isolating --
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inappropriate, totally inappropriate, to infer anything 
negative about an attorney because the attorney 
represented someone accused of heinous crimes? 
A. 
Just the fact of representation alone? 
CL 
Yes. 
A. 
Yeah, that's right. Sure, of course, 
everyone is entitled to a defense. 
Q. 
As -- before December 30th of 2014, had you 
reviewed the Palm Beach Police report? 
A. Portions of it, yes. 
O. 
Had you reviewed the entire report? 
A. 
I think I reviewed most of It, but I don't 
think I've gone through It page by page. 
Q. 
When did you do that? 
A. 
Well, let's see. Before December 30th, 2014, 
Brad and I filed the case in about July 2008, so it was 
Ginn 17 
about a six-year period of time, and I remember I'd been 
0%100 18 
to Florida a couple of times on this case, once in 2010 
0000 19 
and I think another a year or two later. And I 
01 10 07 20 
remember, at least on one of those times, reviewing the 
ri no, 21 
report here with -- I don't know If I can... 
• n is 22 
MS. McCAWLEY: Yeah. I wouldn't go into 
aria 
23 
anything. 
11111115 24 
THE WITNESS: To the -- right. So we just --
9I UM 25 
we just want to know --
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MR. SIMPSON: I don't -- I don't want a 
2 
speech, Mr. Scarola. If you object to the form, 
3 
object to the form, and I -- If It's not a proper 
4 
question --
5 
MR. SCAROLA: I want a clarification of the 
6 
question, please. Are you isolating ordy that 
7 
piece - 
012039 
B 
MR. SIMPSON: I -- the question --
MR. SCAROLA: -- of information? 
MR. SIMPSON: I'm -- I am asking a question 
that's perfectly clear. If you think it's 
objectionable, it won't -- it will stand. 
MR. SCAROLA: I'm going to object on the 
basis that it is vague and ambiguous. It Is 
unclear whether you're asking for him --
MR. SIMPSON: Please don't coach the witness. 
MR. SCAROLA: -- to isolate -- to isolate his 
focus to that single piece of evidence. 
MR. SIMPSON: I object on the coaching of the 
01 /I 01 20 
witness. 
at nol 21 
BY MR. SIMPSON: 
012102 22 
Q. 
My question Is: Is it reasonable, 
41 2103 23 
considering that the police report on Its face shows 
our it 24 
evidence -- let me back this up. Ask another question 
MI 10 25 
to you. 
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Are you aware that the police report reflects 
012171 2 
that the woman I referred to who was hired to give 
ei a 
3 
massages, told them that she never touched anyone 
e12126 4 
inappropriately? 
arts 5 
A. I think that there are — there is 
ei nu 6 information along those lines in the police report, yes. 
012114 7 
Q. 
Okay. And so do you acknowledge that the 
01211/ 8 police report, on Its face, reflects both reports of 
mail 9 
massages that Involved improper sexual contact -- 
012145 10 
contact and massages that were perfectly legitimate? 
012,00 11 
A. 
Yes, but not in the same proportion. 
012154 12 
Q. 
My question wasn't proportion. The 
the 
DI 21S1 13 
report on Its face, you understood, reflected that there 
anal 14 
were massages given at Mr. Epstein's residence that were 
012200 15 
perfectly legitimate? 
eine 16 
A. 
Some — Novas basically a few isolated 
017711 17 
examples from what I could see. 
1112714 18 
Q. 
So you would characterize what was said in 
the police report as "a few isolated examples'? 
012721 20 
A. 
Well, given the backdrop that they had - 
01222$ 21 
Q. 
No. My Question -- it's a yes or no 
aims 22 
Question. Is that how you would characterize it? 
022771 23 
MR. SCAROLA: Excuse me. The witness is not 
*inn 24 
confined to answering yes or no, if yes or no 
01071 25 
would be misleading. 
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person? 
elms 
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012140 
012140 
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012344 
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1 
A. That sounds accurate with the information I 
2 have, yes, she doesn't sound like she would fit his 
3 
type. 
4 
Q. 
And so do you agree with me then --
5 
A. 
And she's over the age of 18, which is 
6 
another reason why wouldn't fit his type, so... 
7 
Q. 
But you acknowledge that -- that this 
8 
woman -- that the police report reflects a woman over --
9 
well over the age of 18, being hired to give perfectly 
a as? 10 legitimate massages, correct? 
A. 
yeah. That was cover for the sex trafficking 
that was going on. 
Q. 
Okay. So you're now -- does the police 
report say "it was cover" --
A. 
That was — 
Q. -- "(or the sex trafficking"? 
A. 
That was my conclusion when I reviewed the 
materials. 
Q. 
Okay. So your Inclusion is that a 
fair-minded reader of the police report would come to 
that conclusion? 
A. December 30th of 2014, knowing what we know 
now, yes. 
Do you consider yourself a very suspicious 
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017233 1 BY MR. SIMPSON: 
CH 2233 
2 
Q. It's a different position than was taken 
ai 
3S 
3 
previously, but --
OM/ 
4 
A. Imam, I was just going to give one 
1117234 
5 
sentence, and the one sentence would be, in the context 
7241 6 of this whole police report where they had 24, 
0,7241 7 
approximately, minor girls who were -- who were being 
00 2241 8 
sexually abused, the references to legitimate massages I 
01 2261 9 
would view as Isolated. 
sins, 10 
Q. 
So you're coming to the conclusion, looking 
017261 11 at the police report, that they are isolated; is that 
0222H 12 right? 
tuns, 13 
A. 
Yes. 
012301 14 
Q. 
And do you think a fair-minded reader of the 
017304 15 
police report would reach that conclusion? 
012303 16 
A. 
Absolutely. 
01230/ 17 
Q. 
And were you aware that the police report, to 
012312 18 
give a bit more detail, reflected that a woman who was 
an 19 
described as having tattoos was hired to give 
012317 20 
deep-tissue Swedish massages. Do YOU recall that being 
012320 21 in the -- in the police report? 
011327 22 
A. Something along those lines, yes. 
012321 23 
Q. 
And she also -- that woman also told the 
017324 24 
police that the was not Jeffrey Epstein's type, that she 
tun,, 25 
wasn't thin, had tattoos, didn't fit his type? 
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o.24rs 1 
A. 
No. 
*Inn 2 
Q. 
Do you consider yourself a con ger/a -- having 
011421 3 
a conspiratorial view? 
012431 4 
A. 
Absolutely not. 
Q. Do you consider yourself a crusader? 
A. 
Well, crusader for justice, I would say, yes. 
Q. If -- let me put it this way: In your view, 
is evidence that a person, any person, any guest at 
Mr. Epstein's house had a massage, evidence that that 
person engaged in criminal sexual conduct, contact with 
minors, because of the fact of having a massage? 
011513 12 
A. 
You'd have to look at the context. 
eine 13 
Q. 
On its own, is it any evidence -- doesn't 
0125 if 14 it -- is it any evidence at all, in your view? 
012501 15 
A. It would be some evidence, yes. 
eina 16 
Q. 
Notwithstanding that the report, on Its face, 
011126 17 
reflects both legitimate and illegitimate massages? 
oi is* 18 
A. The report on its face, let's be clear, 
Ginn 19 reflects a lot of illegitimate sag 
massages and a 
°Inn 20 
sporadic or isolated, you know, legitimate massages. So 
Din as 21 the fact that somebody gets a massage in that context, 
01 2$42 22 I -- I think is — is — raises, you know, the concerns 
012541 23 
we have been talking about. 
es no 24 
Q. 
Did you, before December 30th of 2014, 
012403 25 
yourself personally, review what I think you referred to 
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coma 
1 
062612 
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address book of Mr. Epstein? 
no 
3 
A. 
Pieces of it, yes. 
unto 4 
Q. 
Did you review the entire document? 
et 241I 
5 
A. 
No. 
012621 6 
Q. 
Did I understand yesterday that you 
moon 7 
testified -- did I understand correctly yesterday, that 
012626 8 
you testified that the fact that names were circled 
to n33 9 
Indicated that those persons likely engaged in illegal 
01 70 31 10 
sexual contact with minors? 
012641 11 
A. 
My — my impression is the names that were 
017044 12 
circled were circled by Alfredo Rodriguez when he was 
oroon 13 
busted by the FBI for involvement, and he was asked to 
017661 14 identify those who would have information about the sex 
ones. 15 
trafficking organization. And my — based on all the 
crass 16 
evidence I have, I believe the names that were circled 
orno, 17 
were those who would have that kind of Information. 
osnre 18 
Q. 
So is it your testimony that if the name is 
017701 19 
circled, it indicates that they have information, or 
nu 20 
that they are criminals? 
012702 21 
A. 
That they would have information about the 
cilviz 22 
sex trafficking organization, and that would probably 
271$ 23 
mean that they were part of the organization. It may 
AV IS 24 
mean that they were witnesses to what the organization 
0127e 25 
was doing. 
In your testimony yesterday as the holy grail, an 
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AMA 
1 
Q. 
Would It be a reasonable Inference, or a 
000 2 
possible reasonable inference to draw, that 
01223. 3 
Mr. Rodriguez was trying to highlight people who would 
ed no 
4 be of Interest to the Press for purposes of selling the 
el a as 
5 
book? 
• 0. 
6 
A. No, because he was not talking to the Press. 
in no 
7 
He was talking to an FBI agent who had busted him for 
01 2110 
8 
criminal activity. And so I was assuming that what he 
012664 
9 
was trying to do, as many criminals do when they are 
012466 10 
apprehended, was give information to law enforcement 
or nor 11 agency that would be helpful so that they can catch 
0 ono 12 
other "bigger fishes" Is the phrase that's sometimes 
017IA) 13 
used, so that the little fish would 
would get off or 
012,0) 14 
get a cooperation deal from the law enforcement agency. 
012011 15 
He was talking -- let's be clear. He was 
tan,. 16 talking to somebody he understood was an FBI agent at 
or 017 17 
the time, and so that was the context of the 
000 18 conversation. 
017019 19 
Q. 
Do you have any personal knowledge that it's 
Oi 2022 20 
in the context of talking to the FBI that Mr. Rodriguez 
012026 21 
circled those names? 
*In ts 22 
A. 
I have reviewed — I know I could refresh my 
oi 0X. 23 
recollection here, but there's an FBI 302, a report of 
ol n33 24 
interview of the circumstances surrounding 
el ?In 25 
Mr. Rodriguez's arrest and I believe I reviewed that 
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302. 
DI 10 31 2 
Q. 
Do you know whether the FBI, at any point, 
01704/ 
3 
contacted Professor Dershowitz to discuss any evidence 
010)53 4 
he might have after his name was circled on this 
011946 
5 
document? 
012,67 6 
A. 
I don't have personal knowledge of what the 
012646 7 
FBI did to follow up after that. 
01)001 8 
Q. 
Okay. One of the names that's circled in the 
013003 9 
book is Courtney Love. Do you know who she is? 
taxes 10 
• 3on 11 
O1x10 12 
611019 13 
01)011 14 
ones 15 
011014 16 
• 3027 17 
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01x30 19 
▪ )036 20 
▪ ve 21 
013043 22 
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225 
012120 
1 
But they would have information that the FBI, 
012/24 
2 
among other law enforcement agencies, should be 
012726 
3 
following up on, if they are trying to piece together 
*Inn 4 
what the sex trafficking organization was doing. 
inn 
5 
Q. 
Would you agree that a fair-minded person, 
012131 6 
with that background that you just described, would not 
000 7 
go to the conclusion that the fact that a name is 
012144 
8 
circled indicates that that person has engaged in 
• 2246 
9 
criminal conduct? 
012146 10 
A. 
They — what it would indicate is that they 
21s1 11 
had information relevant to criminal activity. Now, 
6121 54 12 
would they on the 
just the fact that a name was 
alms 13 
circled, standing alone, reach that conclusion? 
01n so 14 
well, that's a hypothetical question because 
el am 15 
obviously in this case, there's lots of other 
01bO 16 
information. 
01x07 17 
Q. 
Did you understand -- it is true, is it not, 
onto 18 
that Mr. Rodriguez was trying to sell that book? 
0.2.0. 19 
A. 
That's true. 
0124.0 20 
Q. 
And is it not also true that the people who 
012613 21 
are circled are famous people? 
01:26 io 22 
A. 
I'd have to refresh my recollection as to 
• an 23 
exactly who was circled, but I know that some famous 
mars 24 
people were circled and some famous people were not 
01x01 25 
cirded. 
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A. 
Not off the top of my head, no. 
Q. If I mention to you or If I represent that 
she's a famous actress, any reason to question that? 
A. 
No. 
Q. In your view, was Courtney Love involved in 
sex trafficking? 
A. 
I don't know. 
Q. 
In your view, was Courtney Love a witness to 
sex trafficking? 
A. If — is there a way — are you representing 
her name is circled? 
Q. 
Her name is circled on the book. In fact, we 
can show it --
A. 
Okay. Yeah. 
Q. It is circled on the book. 
A. 
Okay. Sure. Yeah, I mean, my — my 
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228 
understanding would be that if her — and this is --
could I ask a question about the circling 
or your 
representation? 
Is the circling the same type of circling 
that Is done for Mr. Dershowitz, for example? Is it the 
same, you know, handwriting, same ink, same — same 
appearance? You know, if It's consistent with the 
circling — are you representing k's consistent with 
the circling? 
Q. 
Mr. Cassell, we have a document produced in 
discovery that has various names circled. Looking at 
the document, I don't see any difference among the 
circles. Are you aware of any document --
MR. SCAROLA: Could we have a look -- could 
we see the document? 
MR. SIMPSON: Take a -- go off the record for 
one moment. 
THE WITNESS: We are going off the video 
record, 10:03. 
(Thereupon, a recess was taken.) 
THE VIDEOGRAPHER: We are back on the video 
record, 10:08 a.m. 
MR. SIMPSON: Okay. Back on the record. I'm 
going to ask the reporter to mark as Cassell 
Exhibit 5, a multi-page document. It's a copy of 
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of
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01930 
1 
2 
3 
4 
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all. 
Q. 
Take as long as you want to look at the 
document. 
A. 
Super. Thank you. 
etas, 
5 
Okay. Yeah. I think I'm — I'm oriented 
013154 
6 
now. But I haven't looked at the Love entry. 
613664 
7 
Q. 
My -- my first --
«MS7 
8 
A. 
I want to look at the Love — 
013111 
9 
Q. -- Question Is: Is this a copy of the 
wen 10 
address book that you referred to in your testimony? 
A
Hsu 11 
A. 
Yes.
Glues 12 
O. 
Okay. And if you would take a look at the --
01)1104 13 
I've marked the entries for Courtney Love. Take a look 
oi *11 14 
at that one. 
013013 15 
A. 
All right. I see it. 
0,1014 16 
O. 
Okay. And then if you look at the last 
01 30a 17 
entry, there's an entry for Professor Dershowitz that's 
O13021 18 
also circled. It should be on the flag. It's 
0/ 202619 
two-sided. 
Han 20 
A. 
Oh, yeah. 
1212021 21 
Q. 
Do you see that one? 
It 3030 22 
A. 
I see It 
0,3•11 23 
Q. 
And then also the other one I marked is 
moon 24 
Donald Trump. 
O1 2234: 25 
A. 
Yes. Got it. I see those entries circled. 
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1 
the address book we have been speaking about, and 
01 3610 
2 
ask that Doc -- Mr. Cassell to take a look at 
nnii 
3 
this, and I'm going to ask him about certain of 
013433 
4 
the entries. 
033703 
5 
(Cassell 's I.D. Exhibit No. 5 • copy of 
1113/10 
6 
address book was marked for identification.) 
013143 
7 
MR. SIMPSON: And I will note, I put a few 
013703 
8 
flags on here --
013103 
9 
THE WITNESS: Sure. 
012/03 10 
MR. SIMPSON: -- to direct your attention --
Horn 11 
THE WITNESS: Correct, yeah. 
MR. SIMPSON: -- which we can -- I'll note 
013710 13 
the pages for the record Just so we have them. 
01 3/ 16 14 
38, 76, and 85. 
013/24 15 
THE WITNESS: Okay. I Just -- I Just want to 
*inn 16 
take two minutes or so --
4131 as 17 
BY MR. SIMPSON: 
morn 18 
O. 
Yeah. Take -- take a moment to look at it. 
013120 19 
A. 
Okay. I want to make a few notes, if that's 
oust 20 
all right, just to get them in 1•-
01 3607 21 
Q. 
You're going to mark on the --
on 
22 
A. 
No, not on the exhibit. I'm just going to 
(nun 23 
make notes to refresh my recollection so we don't have 
Han 24 
to take time. I'm just — I'm just making notes of the 
011•13 25 
context here. This will just take another minute is 
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01 10 41 
1 
Q. 
So am I right 
I'm right, am I rot, that 
013060 
2 
among the others circled are: Courtney Love, Donald 
013261 
3 
Trump, and Alan Dershowitz, correct? 
013056 
4 
A. 
Correct, among the others, yes. 
alas, 
5 
0.. 
And they are all circled in the same way; are 
014001 
6 
they not? 
014040 
7 
A. 
Yeah. It's kind of a — a box is what I 
014004 
8 
would say. Some, yes. 
O14001 
9 
Q. 
Is there anything on the face of that 
014001 10 
document that leads you to conclude that the circling --
Hon 11 
the significance of the circling is any different for 
0140 is 12 
one person than another? 
014017 13 
A. 
No. 
0...0q 14 
Q. 
So based on the document, do you infer that 
Han 15 
Courtney Love was Involved in some kind of sexual abuse 
0.4030 16 
of minors? 
014030 17 
A. 
I would Infer that if I were running a 
014034 18 
criminal investigation through the FBI and I'm trying to 
014037 19 
find people who would have relevant Information, she 
014063 20 
would be one of the people I'd want to talk to. I mean, 
01400 21 
the names that are circled here, Glenn Maxwell, one of 
oi ion 22 
the identified traffickers, Epstein is circled, the 
*moo 23 
pilot -- one of the pilots is circled. So It's these 
01051 24 
people that all seemed to be connected are -- are all 
014055 25 
being marked here, and — and the number of people that 
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are circled is, I would say, you know, 5 to 10 percent 
2 
of the — of the names ball-parking in the dark. 
3 
Q. Do you know whether this address book was 
4 Jeffrey Epstein's address book or Glenn Maxwell's 
5 
address book? 
6 
A. I'm not certain exactly whose book it is. 
7 
actually thought it was Alfredo Rodriguez maintaining a 
8 
copy of records in case he was worried that Epstein 
9 
might try to have him killed at some point, and so this 
• rt 10 
was his insurance policy, I think he said, against that 
014121 11 happening. 
%OM 12 
MR. SIMPSON: Object to the nonresponsive 
014191 13 
portion of the answer. 
4131 14 
BY MR. SIMPSON: 
oirin 15 
Q. Is the answer to my question: You don't know 
016134 16 
whether it was Jeffrey Epstein's or Glenn Maxwell's 
014110 17 
address book? 
0141)0 18 
A. 
I don't know. And the reason I don't know 
014141 19 
that is because I actually believe it is neither --
*taw 20 
neither of their — that's -- is it one or the other? 
oloa 21 
Actually, I think it's a third possibility. I think 
this was Alfredo Rodriguez's Insurance policy against 
getting knocked off by Jeffrey Epstein. 
Q. 
So that's the view you have of the 
014201 25 
signifkance of this document? 
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.1•151 23 
rims,. 24 
024317 
014317 
O14324 
01 as 
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O1.334 
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014142 11 
014341 12 
014347 13 
(won 14 
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ot.i. 18 
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01 
12 20 
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O 4410 25 
234 
1 
BY MR. SIMPSON: 
2 
Q. 
But based on your testimony previously, you 
3 
would consider all of those facts to be evidence that he 
4 
may have been? 
5 
A. 
They are, you know, certainly things that I 
6 
would want to follow up on. 
7 
Q. And --
8 
A. If I were running an -- we were in the 
9 
context, I take it, of your question, you know, if 
somebody is running an investigation into the 
organization, so... 
Q. 
Did you, in the course of your representation 
of Miss Roberts or any of the other Jane Doe clients you 
have had who have had claims against W. Epstein, make 
any effort to find out whether Mr. Trump had abused any 
of them? 
MR. EDWARDS: I would just object to this 
being work-product privilege as it relates to 
other cases that I'm working on with Paul that 
Jack is not involved in. 
MR. SIMPSON: Okay. 
MR. EDWARDS: With respect to what we did 
during our Investigation on behalf of other 
clients. 
MR. SIMPSON: Okay. 
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233 
A. 
Yes. In part. I mean, there are other 
oi ow 2 
reasons it's significant, as we have been talking about, 
014210 3 
names are drded who appear to have relevant 
won 4 information on Jeffrey Epstein's criminal activities. 
014217 
5 
Q. 
Donald Trump was a friend of Jeffrey Epstein; 
mun 6 
is that not correct? 
014223 
7 
A. 
I really don't -- my understanding is, yes, 
014226 
8 
but I - I don't have a lot of Information about Trump. 
014221 9 
Q. It's true also, is it not, that Mr. Trump was 
014234 10 
a frequent visitor to Mr. Epstein's residence? 
00.235 11 
A. I - I know that he visited frequent. I -- I 
014141 12 
don't have a lot of information about Trump. 
ww.” 13 
Q. 
And his name is circled in this book; is it 
.1 427 14 
not? 
014743 15 
A. 
I believe it is. 
maim 16 
Q. 
Based on him -- assuming he's a frequent 
01012 17 
visitor to Mr. Epstein's home, and that he's a friend of 
MOM 18 
Mr. Epstein's, and that his name is circled in this 
el ow 19 
book, do you infer that he was engaged in criminal 
mum 20 
sexual abuse of minors? 
014,1 21 
MS. McCAWLEY: I'm going to object to the 
oi 4113 22 
extent that your answer would reveal anything 
4) is 23 
that my client has told you. 
01010 24 
THE WITNESS: No. 
O,41,7 25 
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ono) 25 
235 
MS. McCAWLEY: Right. And I object on that 
to the extent that it reveals an Ithn 
ou did on 
behalf 
MR. 
would know 
to object to this, but because I know of another 
case that we work on, that's protected by our 
work-product privilege, who I talked to and who I 
did not. 
THE WITNESS: I'd like to --
Wt. SCAROLA: In that case, I instruct you 
not to answer. 
THE WITNESS: All right. 
MR. SIMPSON: An right. You're here, 
Mr. Edwards, as a dient, not an attorney, 
correct? 
MR. EDWARDS: Yes. That's my primary role in 
being here, but I'm going to protect the 
privilege to the extent that it's not being 
protected by others who don't recognize that the 
privilege needs to be protected on other matters. 
MR. SIMPSON: Okay. 
BY MR. SIMPSON: 
Q. Mr. Cassell, as of December 30th of 2014, 
were you aware that Professor Dershowitz had visited 
Mr. Epstein's home and stayed as a guest for a week in 
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the company of his grandchildren, among other family 
or is le 
2 
members? 
olds 3 
A. I'm sorry. Which residence? Which Epstein 
010573 4 residence? 
014523 
5 
Q. 
Palm Beach. 
014525 6 
A. 
Can you — can you restate? 
0/4575 7 
Q. 
Yes. 
4. 
8 
A. 
I mean that's kind of a compound question. I 
014130 9 
mean... 
014130 10 
Q. 
Well, let me rephrase R. I will be dear. 
014531 11 
A. 
Yeah. 
men 12 
Q. 
Were you aware as of December 30th of 2014 
0146 X 13 let me back up a moment. 
01041 14 
A. Sure. 
01037 15 
Q. 
You indicated yesterday that part of the 
014540 16 
basis for your conduslon that this pleading -- It was 
014544 17 
appropriate to file this pleading accusing Professor 
01450 18 
Dershowitz of misconduct was that he was a guest at the 
corm 19 
Palm Beach house, correct? 
014656 20 
A. No. It was more than that. He was a 
01450 21 frequent guest, a frequent overnight guest. 
014001 22 
Q. 
My question is: As of December 30th, 2014, 
014001 23 
were you aware that Professor Dershowitz had spent a 
014.10 24 
week at the Palm Beach house with family members, 
014413 25 
Including his grandchildren? 
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01015 11 
01470 12 
Are -- during the period that Virginia 
mins 13 
Roberts contends she was sexually abused, which I 
014002 14 
understand to be middle of 1999 to middle of 2002 -- is 
eiwit 15 
that consistent with your understanding? 
oral. 16 
A. 
Approximately, yes. 
014412 17 
Q. -- how many times did Professor Dershowitz 
a au 18 
visit the Palm Beach mansion during that period? 
01441? 19 
A. 
My understanding is In the neighborhood of —
014:2, 20 
what was it? Three to five times a year, staying two to 
is a a 21 three nights at a time. 
01 an 22 
Q. 
And was that your understanding as of 
014120 23 December 30th of 2014? 
014032 24 
A. 
Yes. 
iz 25 
Q. 
what was the basis for your understanding, 
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scene of ongoing criminal abuse of minors, and who 
himself, has engaged in that criminal abuse, would bring 
his grandchildren to stay there for a week? 
A. It would depend on the circumstances. 
Q. 
When you say that Professor Dershowitz was a 
regular guest at the mansion, at the Palm Beach house, 
i llillse
e
it's correct ' 
' 
(erring to a 
period aRe 
R for Thailand? 
A. 
Q. 
Are you aware of any evidence -- let me back 
that up. 
014415 
014415 
114520 
010123 
w-a 
01_u 
014)5 
014415 
0/4637 9 
010.0 10 
c. es 40 11 
01041 12 
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01444 14 
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014044 16 
01400 17 
01 44 18 
01405/ 19 
/mica 20 
014054 21 
0454 22 
oss 23 
014013 24 
•147® 25 
237 
1 
A. No. 
2 
Q. 
Okay. Do you think it's reasonable -- would 
3 
it be reasonable to believe that someone who is 
4 
committing criminal sexual abuse of minors at a home 
5 
where such abuse, as you understand it, is a daily 
6 
occurrence would bring his grandchildren to stay for a 
7 
week? 
8 
A. It would depend on the circumstances. I 
mean, you know, so 
you know, it would depend on the 
circumstances. 
MR. SCAROLA: Are you representing that 
Jeffrey Epstein was there at the time? 
MR. SIMPSON: I'm not answering questions. 
I'm asking questions. 
MR. SCAROLA: Oh, okay. 
BY MR. SIMPSON: 
Q. 
So, in your view, you can -- let me -- let me 
rephrase that. 
You say it would depend on the 
circumstances --
A. 
Sure. Sure. 
Q. -- that's your answer? 
A. 
Yes. 
Q. 
Okay. So that you don't find it Incongruous 
that someone who knows that a particular home is the 
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1 
what pieces, what documents, or testimony? 
2 
A. 
Right. The Information, you know, I gave a 
3 
long presentation yesterday. So it was that 
4 Information. 
5 
Q. 
I want to focus now specifically -- I'm not 
6 
looking for a full answer on your entire views --
7 
A. 
Yeah, right. 
01053 8 
Q. -- on the case. 
014453 9 
A. 
I appreciate that 
01454 10 
Q. 
I just want to say, you've testified that you 
01415? 11 understood as of December 30th, 2014, that Professor 
01003 12 
Dershowit2 had -- was a visitor at the Palm Beach 
014004 13 mansion three to five times during this relevant period 
o1003 14 
of 1999 to -- middle of 1999 to the middle of 2002. 
01414 15 
What was the basis on December 30th of 2014, for just 
0143/0 16 
that fact? 
014071 17 
A. Right. I mean, I will take about a minute 
*ion 18 
here because there are a few things I want — 
n 19 
Q. 
Okay. And I want to make sure my question is 
01020 20 
dear. 
014171 21 
A. Sure. 
wow 22 
Q. I'm not asking you about any of your 
*34 23 
inferences about anything else. Just, what's the basis 
014144 24 
for your belief that he visited three to five times 
ei s 25 
during that two-year period? 
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et an 1 
MR. SCAROLA: Could I ask for a 
014040 2 
clarification? Are you looking only for direct 
Heti, 3 
evidence and you want to exclude the 
0101144 
4 
circumstantial evidence? Is that the way you 
otitis 5 
want to •' 
0100•I 6 
MR. SIMPSON: I'm asking. You can object to 
011•30 7 
the form. 
011046 8 
BY MR. SIMPSON: 
o14en 9 
Q. 
My question Is: What was -- what were you --
0. oil 10 
what did you have in mind as supporting your conclusion 
014037 11 or tenet that he -- that Professor Dershowltz visited 
014002 12 
three to five times during that relevant penod? 
013004 13 
MS. McCAWLEY: And I'm sum/. Can I just 
math 14 
place an objection on the record. I'm going to 
01,10/ 15 
object to the extent that -- so that you do not 
reveal attorney/client privileged communication, 
014012 17 
unless it's something that's already public that 
mai, 18 
she's revealed. 
013013 19 
THE WITNESS: Okay. Right. So I'm going to 
011017 20 
just exclude -- I take it your question isn't 
Huns 21 
asking about any communications. 
max 22 
BY MR. SIMPSON: 
011022 23 
Q. 
My question is asking about that, but I 
01024 24 
understand you're going to refuse to provide it. 
in an 25 
MS. McCAWLEY: Unless it's already public. 
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015123 
1 
context, in other words, information that was 
013123 2 
going to be disclosed, not for advice, but 
was 30 
3 
factual information that she intended to 
its, a 4 
disclose, that's no -- that's not privileged. 
oi stu 5 
But if it's something that she communicated to 
Hite 6 
you in confidence with respect to getting legal 
4,.a 7 
advice, then that would be privileged. 
01301 8 
THE WITNESS: Right. Okay. So Juan Alessi ' s 
0131.43 9 
deposition, Alfredo Rodriguez's deposition, and 
Hilo 10 
then considerable circumstantial evidence which 
we don't have to rehash here involving the dose 
0131 9.11 12 
personal association between Epstein and 
01330313 
Dershowltz. 
01 SICO 14 
I mean, again, we can rehash all of that, but 
013103 15 
those were -- those are -- that's kind of a 
016201 16 
quick -- because I know you want to get to a lot 
earn 17 
of questions -- that's a quick sort of highlight 
met. 18 
film, if you will. 
013200 19 
BY MR. SIMPSON: 
owl, 20 
Q. 
Mr. Cassell, isn't it true that Mr. Rodriguez 
al ft.. 21 
was not hired until several years after the Summer 
011219 22 
A. 
2004. 
011220 23 
Q. 
Let me ask it again. 
011221 24 
-- until well after 2002? 
et um 25 
A. 
Yeah, about 2004. 
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013020 
013010 
4 
241 
1 
THE WITNESS: Okay. So as Of December 30th, 
015014 
2 
' 
communications from 
013033 
3 
pt to extent that they have 
013031 5 
already been made public. That is, if she has 
Haze 6 
given express permission to make disclosures, 
01000 7 
these were not confidential communications, but 
8 
communications intended to be communicated to 
third parties, tit 
" 
dude 
information fro 
response to the 
ad. 
THE WITNESS: Okay. 
BY MR. SIMPSON: 
$006 
41110a 
9 
el as: 10 
tun. 11 
a.m. 12 
01 SI CO 13 
013%30 14 
013101 15 
• 6,03 16 
ones 17 
013106 18 
01.3106 19 
• si co 20 
0141.0 21 
Q. 
A. 
Q. 
A. 
Q. 
A. 
Q. 
As of December --
Right 
-- 30th, 2014 --
Right. 
-- correct? So --
Yeah, that's right. 
any public statements by her after 
December 30th, 2014 would not be included in the answer. 
• 
22 
A. 
Okay. 
as SI 14 23 
MS. McCAWLEY: But let me be dear. Let me 
etsin 24 
be clear about my objection. To the extent that 
el sill 25 
she revealed something to you in a nonprivileged 
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*Intl 
11 
016214 12 
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*I sis 16 
mow 17 
243 
Q. 
And Mr. Rodriguez would have no personal 
knowledge of how often Professor Dershowitz visited 
during a period two years or three years before he was 
hired; isn't that true? 
A. 
So, look, this is — this is why I was trying 
to speed up the answer to the question. We have a sex 
trafficking organization that is running a common scheme 
and plan that is continuing on until it was interrupted 
by law enforcement about 2005 and 2006. 
So what the -- the criminal organization is 
doing in 2004, unless I have some significant evidence 
that it's different than what was going on in 2002, 
2001, 2000, 1999, I think It's reasonable to conclude 
that the same sort of criminal activities are going on 
later. 
So if — if you want — if you want me to get 
into the — the full scope of the criminal organization, 
013101 18 
we can get into it. But the fact that somebody in 2004 
el fa 13 19 
sees this going on, leads me to conclude that It's 
0153* 20 probably the same thing going on in the absence of other 
015319 21 information in 2001. 
Q. 
So from Mr. Rodriguez's testimony about what 
was going on, so to speak -- and my question related, 
what was going on the number of times that Professor 
Dershowitz visited. That's the topic. 
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asset 
1 
A. 
Right. 
Ou53 3? 
2 
Q. 
That because he visited, according to 
01 1340 
3 
Mr. Rodriguez, several times a year in 2004, 2005, he 
011341 4 
must have visited several times a year in 2000 -- 19- '-
MOM 
5 
middle of 1999 to the middle of 2002. 
et 0316 
6 
A. 
I didn't say must have. I said that that's 
te nu 7 
going to be evidence of the common scheme and plan, and 
el On 
8 
then, in the absence of, you know, some falling out 
O15402 
9 
between people or somebody becoming, you know, more 
Hues 10 
associated or Less associated with a criminal 
044407 11 
organization. I mean, if you want to get into the 
Hum 12 
circumstantial evidence, in 2003, there's an ankle on 
oi 5415 13 
which, you know, Dershowitz identifies himself — 
testis 14 
Q. 
Let me interrupt you because I'm asking --
Hens 15 
A. 
Okay. 
oleos 16 
Q. 
— about 
my only question is evidence of 
OISMS 17 
how -- not anything, whether engaged In conduct or 
ei s4 n 18 
didn't engage in conduct, Just how many times he came 
el Si 26 19 
during this period. 
tin 
20 
A. 
Right. 
elan 21 
MR. SCAROIA: Excuse me, counsel. That's the 
el an 
22 
reason why I asked you to clarify whether you 
MS4 30 23 
want to limit this to direct evidence or whether 
es use 24 
you want all of the evidence including 
11,54 35 25 
circumstantial evidence, because as we both know, 
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Hesse 1 
MR. SIMPSON: Really, objecting to the form 
011123 
2 
of the question preserves all of any problems 
re 6120 
3 
there may be with the question. 
011627 4 
MR. SCAROIA: No, sir. 
015617 5 
MR. SIMPSON: We don't need a speech. 
01 5627 6 
MR. SCAROLA: It doesn't. It doesn't. 
011637 
7 
BY MR. SIMPSON: 
015533 
8 
Q. 
Mr. Cassel, is it your testimony that, from 
01 56 3/ 
9 
Mr. Rodriguez's testimony about how often he says 
men 10 
Professor Dershowitz visited in a 2004/2005 time frame, 
mess 11 
it's fair to draw an inference about how often he 
• sses 12 
visited in an earlier -- three-year earlier time frame? 
oissse 13 
A. 
In the circumstances of this case, 
ei este 14 
absolutely. 
*ISSN 15 
Q. 
And would it be fair to infer from the number 
el wee 16 ci times that Donald Trump visited three years later, 
how often he visited at an earlier period? 
01540218 
A. 
I did not Investigate the circumstances 
04 le 12 19 
involving Trump. He wasn't somebody that was coming up. 
Q. 
Were you aware on December 30th of 2014 that 
0156 21 21 
Donald Trump was quoted In Vanity Fair as saying: "I've 
012630 22 
known Jeff" -- referring to Epstein -- oh, I'm sorry. 
01 S6 34 23 
it was a New Yorker Magazine, not Vanity Fair. That he 
Glue 24 
was quoted as saying: "I've known Jeff- -- referring to 
0.565 25 
Epstein -- "for 15 years. Terrific guy. And he's a lot 
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0154 
7 
015413 8 
011414 
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0154$2 10 
Os MSS 11 
re mar 12 
01$462 13 
on's/ 14 
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056502 18 
tosser 19 
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mssor 21 
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Ois is 24 
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245 
circumstantial evidence is good evidence. A 
well-connected chain of circumstance can be --
MR. SIMPSON: We really don't need a speech. 
MR. SCAROLA: -- a well-connected --
MR. SIMPSON: We really don't --
MR. SCAROLA: -- chain of circumstance may be 
as compelling proof as direct evidence of a given 
fact. That's the law. 
If you don't want --
MR. SIMPSON: Really, sir. 
MR. SCAROLA: -- the circumstantial 
evidence --
MR. SIMPSON: Mr. Scarola --
MR. SCAROLA: -- tell us that. 
MR. SIMPSON: -- please don't make speeches, 
and please don't coach the witness. 
MR. SCAROLA: lust tell us that. I'm not 
coaching the witness. I'm asking you -- you're 
asking ambiguous questions. 
MR. SIMPSON: There's nothing ambiguous --
MR. SCAROLA: If you want only direct 
evidence, we will give you only direct evidence. 
If you want a full and complete answer, it's 
got to include circumstantial evidence, so don't 
cut him off when he's giving you that. 
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1 
of fun to be with." It even said that: lie likes 
es Ho 2 
beautiful women as much as I do, and many el them are on 
M.353 3 
the younger side. No doubt about it, Jeffrey enjoys the 
015056 4 
social -- social life"? Were you aware of that on 
men 5 
December 30th, 2014? 
M3014 6 
A. 
Possibly. I mean that sounds vaguely 
el S7 01 
7 
familiar. Trump has just not been somebody that — that 
eines 8 I've paid much attention to In this case. 
ei de? 9 
Q. 
Based on that statement, and the facts we 
rims 
10 
discussed earlier about Mr. Trump visiting and being a 
011711 11 friend, and the other circumstances we discussed, are 
you suspicious about whether he engaged in sexual 
011721 13 
misconduct with minors? 
noon 14 
MS. McCAWLEY: I'm going to object to the 
en? 30 15 
extent that you can't reveal anything that my 
of szei 16 
client has informed you of. 
011733 17 
THE WITNESS: Right. If we set aside that 
mum 18 
information, I'm not -- I'm not suspicious, no, 
Hun 19 
not given the information I have. 
Hos 20 
BY MR. SIMPSON: 
• s? 0 21 
Q. 
Okay. So notwithstanding that his name is 
• sin 22 
circled in the address book, he was a good friend, he 
01 17 4/ 23 
visited often, and he was quoted as saying that Jeff was 
co 
54 24 
a terrific guy who liked young women almost as much as 
ei sin 25 
Trump did, you're not even suspicious? 
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el Hei 
1 
A. 
Not 
you know, let's break that down in a 
.us 
2 
couple pieces. 
414100 3 
The fact that his name is circled, if I were 
01 UN 
4 running an FBI investigation, I'd go send somebody to 
a u io 5 
see what he knew about it, but no, it would take a lot 
OIL If 
6 more for me to become suspicious that somebody is 
el fit 
7 
involved in — in sexual activity like that. 
MP IS 8 
O. 
Okay. So you would agree with me then, that 
01162. 9 
the fact that a person often visited the mansion, the 
in saw 10 
person -- the fact that a person was a friend of 
• sari 11 
Mr. Epstein for 15 years, the fact that the person had 
ol is 3? 12 
stated publicly that: 'Mr. Epstein liked young women 
0114 Nf 13 
almost as much as I do myself,' and the fact that the 
1111.40 14 
name is circled in the address book is not sufficient to 
• pin 15 
raise a suspicion that that person engaged in sexual 
nue 16 
misconduct? 
01340 17 
A. 
So... 
Hues 18 
O. 
Yes or no. It's a yes or no question. 
• swi 19 
A. It requires — 
ems: 20 
MR. SCAROLA: You're not required to answer 
01 Sig 21 
yes or no, if a yes or no response alone would be 
m son 22 
misleading. 
es sate 23 
THE WITNESS: The problem is the word 
m can 24 
-suspicion' I'm not particularly suspicious on 
*ism 25 
those facts, but it -- you know, what do you mean 
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nun I 
and energy In that, right. 
020112 2 
Q. 
And you referred to your pro bono case. What 
020216 3 is your best estimate of how much money you have made 
021021 4 
representing victims of Jeffrey Epstein? 
noon 5 
A. In which case are we talking about now? 
0202 24 
6 
a My -- any case representing a victim of 
ewe 20 7 
Jeffrey Epstein. 
WON 
8 
A. 
I need to confer with 
010U 
9 
MS. McCAWLEY: Yeah. I'm going to object. 
(awn 10 
BY MR. SIMPSON: 
4/0034 11 
Q. 
And that -- that's a fact -- that's not a 
moon 12 
privileged question. That's a factual question. 
021037 13 
A. 
Factual. Well, there are — there are — 
num 14 
Q. lust how much money? You don't have to tell 
OM 4i 15 
me who the clients are. Just how much money? 
02C044 16 
A. okay I need to 
020044 17 
MR. SIMPSON: There's a question pending. I 
moon 18 
object to a break. There's no possible 
02004.19 
privilege. 
wows 20 
MR. SCAROIA: He has a privilege -- he has a 
taw so 21 
privilege question. He wants to consuk with 
020311 22 
counsel. 
nom 23 
MR. SIMPSON: Well, really? My question is 
020263 24 
how much money, and that's privileged? 
moon 25 
MR. SCAROIA: It may be. I don't know. We 
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*Ism 1 
by 'suspicion"? If I -- if I were running an FBI 
Cri Wag 
2 
investigation and somebody circled a name as --
num 3 
as saying, look, this fellow may have some 
0164C41 4 
information, I'd go follow up on that. 
• Hu, 5 
If you say that's suspicion, then the answer 
tin la 6 
would be, yes. But I -- you know, based on that 
015111 7 
information alone, no. I mean that -- that 
01w,. 8 
wouldn't -- wouldn't be enough for me to, you 
05422 9 
know, invest time and energy into that particular 
011026 10 
possibility. 
O11424 11 
BY MR. SIMPSON: 
016/21 12 
Q. 
Okay. So none of those facts are sufficient 
9•31 13 
even to justify spending time and energy, correct? 
01 
>4 14 
A. 
Unless -- if I'm running — this is — again, 
m ow 15 
what do you mean by "suspicion"? Time and energy in the 
014442 16 
context of somebody who is running a pro bono case with 
015444 17 
limited resources to try to figure out what the sex 
01 44.2 18 
trafficking ring's going to do, I'm not going to chase 
ewe, 19 
after that rabbit. It seems farfetched. 
wows 20 
I'm going to focus my efforts on the people 
awe 21 
who appear to be more directly involved. 
in wig 22 
Q. 
Okay. So based on the facts that I gave you 
taws 23 
a moment ago, you think ifs farfetched that Donald 
020001 24 
Trump was engaged in abusing minors? 
wow 25 
A. If that's all I had, I would not invest time 
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noon 3 
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m 4 
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• 
0) 10 
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need to talk. 
THE WITNESS: That's why I need to --
MR. SCOTT: There's no federal law or state 
law that supports that financial information and 
fees is privileged. 
MS. McCAWLEY: We can argue about that 
because that's in my motion, so we can argue 
about that. 
MR. SIMPSON: well, can - can --
MR. SCOTT: That one, I know all about. 
MR. SCAROLA: You're objecting to our taking 
a break --
MR. SIMPSON: I am objecting --
MR. SCAROIA: -- while this question is 
pending? 
MR. SIMPSON: That's correct. 
MR. SCAROIA: It is ow position that the 
witness has a legal question about privilege. We 
are going to take a break. We are going to talk 
about it. It may turn out that it's not a 
problem at all. I don't know. 
THE VIDEOGRAPHER: We are going off the video 
record, 10:38. 
MR. SIMPSON: With my note, we are taking a 
break over my objection. 
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an 1. 1 
THE VIDEOGRAPHER: 10:38. 
sans, 1 
counsel of record in three cases and you were involved 
ran u 2 
(Thereupon, a recess was taken.) 
nun 2 in another case -- at least one other case in which you 
nu to 3 
THE VIDEOGRAPHER: We are back on the video 
nuns 3 
did not appear --
cis 42 4 
record, 10:49 a.m. 
nun 4 
A. That's right. 
02100 5 
BY MR. SIMPSON: 
it,.,. 5 
Q. -- as counsel of record; is that correct? 
w,... 6 
an a 7 
Q. 
Back on the record. My question, 
Mr. Cassell, was: What is your best estimate of how 
021900 6 
*risco 7 
A. 
That's — that's my recollection right now, 
yeah. 
wine 8 
much money you have made representing victims of Jeffrey 
021003 8 
Q. 
All right. How many of those cases have been 
023131 9 
Epstein? 
num 9 
resolved at this point? 
omen 10 
A. In which case are we talking about? 
silos 10 
A. All. All — of the four, I recall all four 
02/66. 11 
Q. In -- in any case. Combined total. 
nun 11 have been resolved. 
02'1101 12 
A. Okay. With regard to the CVRA case, that's 
021101 12 
Q. Okay. Without telling me the amount, did you 
02170. 13 
pro bono, no money there. With regard to the other 
02 /t 12 13 
receive -- all four were settled; Is that right? 
st OW 14 
cases, I'd like to answer your question, but due to 
sits 14 
A. Correct. 
02 7710 15 confidentiality obligations that have been imposed upon em's 15 
Q. Without telling me the amount, Is It correct 
021713 16 
me by Jeffrey Epstein, in the course of negotiating 
021031 16 
that in all four of those cases, you received a legal 
to out 17 
those cases, I'm not permitted to answer that question. 
021227 17 
fee? 
s,,.,, 18 
MR. SCAROLA: We are certainly willing to 
4202s 18 
A. I think that starts to call for a question I 
et on 19 
respond appropriately to a court order in that 
020331 19 need to consult with my attorney about. 
non 20 
regard, but it requires a court order to release 
021030 20 
Q. Simply the question of whether in each of 
0217 20 21 
us from the contractual confidentiality 
aun 21 them you received a fee? 
021733 22 
obligations that we are under. 
0111100 22 
A. I just want to... 
027713 23 
BY MR. SIMPSON: 
nu* 23 
THE WITNESS: Is -- is there any problem --
02023 24 
Q. Is it your testimony, Mr. Cassell, that there 
tuna 24 
MR. SCAROLA: You can respond to that. You 
0217m 25 
are confidentiality agreements with Mr. Epstein that 
al is u 25 
can answer yes or no to that question. 
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ma. I 
preclude you from giving the total amount paid without 
02711M 
1 
THE WITNESS: Yes, I received something. 
021751 2 
breaking it down Into particular cases? 
isitsn 2 
BY MR. SIMPSON: 
021233 
3 
A. I'm sorry. I didn't understand. 
031041 3 
Q. 
Okay. Was the fee -- and if it's different 
WO 30 
4 
Q. Oh, maybe that wasn't dear. Let me do it 
021050 4 
for the -- the cases, tell me, but was it a contingent 
02 17 54 
5 
this way so we avoid -- 
win. 5 
fee or some kind of hourly fee? 
nun 6 
A. Yeah. 
02,.50 6 
MR. SCAROLA: That -- that does get into 
mum 7 
Q. -- the confidentiality Issues. 
02 1161 7 
attorney/client privileged matters. The terms --
stun 8 
In how many cases have you been counsel for a 
022002 8 
MR. SIMPSON: You're instructing him not to 
mum 9 
person suing Mr. Epstein alleging that she was a victim? 
027001 9 
answer? 
C0 III 12 10 
A. Counsel of record? 
ones 10 
MR. SCAROLA: -- the terms of the 
an,. 11 
Q. Put it this way. How -- well, start with 
022004 11 
representation are attorney/client privilege. I 
ic 417 12 
that, counsel of record. 
R22003 12 
instruct him not to answer. 
Nun 13 
A. I believe three. 
072001 13 
MR. SIMPSON: All right. 
a wit 14 
Q. Okay. And in addition to those three, have 
mom 14 
BY MR. SIMPSON: 
020120 15 
you assisted other counsel in sonic way without becoming 
022010 15 
Q. In addition to these four cases that have 
02 31 20 16 
counsel of record In cases by women suing Mr. Epstein 
02201) 16 
been resolved, are you representing any other clients 
0211.30 17 
alleging that they had been abused? 
02201. 17 
who are alleging, in a case seeking monetary damages, 
0214M 18 
A. I believe there's one other case in addition 
022023 18 
that they were abused by Jeffrey Epstein? 
a... 19 to the counsel of record case. 
02202. 19 
A. I —
a.° 20 
Q. 
And without telling me -- 
onsis 20 
MS. McCAWLEY: I'm going to object to the 
a,... 21 
A. I'd -- I'd have to go double-check my record. 
anon 21 
any Information related to 
a,.. 22 
This is an approximate best recollection. 
022031 22 
could be deemed privileged 
02... 23 
Q. 
All right. 
0230$ 23 
or con en a . 
nun 24 
A. It's about four. 
ones 24 
THE WITNESS: So what's the... 
wits 25 
Q. To the best of your recollection, you were 
Os 25 
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BY MR. SIMPSON: 
022030 
2 
Q. 
I'm -- I'm trying to close a loop here. 
022040 
3 
A. 
Yeah. 
=2040 4 
Q. 
I'm asking whether you were involved in any 
02204 
5 
other cases in which claims have been made against 
022047
6 
Jeffrey Epstein for damages that are still active; they 
122032 
7 
have not been resolved? 
022013 8 
A. 
So we are talking civil cases, unresolved 
02010 9 civil cases against Jeffrey Epstein right now? 
erne 10 
02102 11 
ten= 12 
02,53 13 
mice 14 
022104 15 
V12101 16 
0202 22 17 
0211 4 18 
mills 19 
0221 4 20 
02 >In 21 
OW 20 22 
=:1 21 23 
021121 24 
072121 25 
Q. 
Unresolved cases seeking money from Jeffrey 
Epstein. 
MR. SCAROLA: And to the extent that that 
question calls for matters that are of public 
record, then, obviously, you can respond. 
THE WITNESS: Right. Yeah. None. 
BY MR. SIMPSON: 
Q. 
Are there -- and I'm not asking for the name. 
Are there any not of public record that --
A. 
What would be a "not"? 
Q. 
Well, if you had made a claim that's riot In 
suit, for example. 
A. 
Oh, against Jeffrey Epstein? 
Q. 
Yes. 
A. 
Yeah. No, I don't -- I don't think there's 
anything. Yeah, no — no claims against Epstein, right 
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ante 9 
258 
A. 
Yeah. That hasn't been something that I have 
focused on, no. I mean... 
Q. It is 
it is correct, is it not, that you 
anticipate that if you are successful in setting aside 
the nonprosecution agreement that the names of 
additional victims will become known; didn't you testify 
to that yesterday? 
A. 
i - I'm not — I must be confused here. 
don't remember. 
tenor 10 
O. 
Well, wait -- I don't want to -- you know, 
012301 11 let me ask the question -- 
ants 12 
A. 
Yeah. 
con* 13 
Q. -- rather than my recollection. 
New 14 
A. 
Yeah, yeah. That's what I'm not... 
own 15 
Q. 
My question is: Do you anticipate that if 
rants 16 
you're successful in setting aside the nonprosecution 
cams 17 
agreement, that the names of additional victims will 
022323 18 
become known? 
°inn 19 
A. 
Additional Epstein victims at this point? 
022121 20 
Q. 
Yes. 
072124 21 
A. 
Again, it's pretty speculative. The — 
023330 22 
the Issue — you know, the case, you know, the events 
Num 23 
were roughly a decade ago. I mean, we are always hoping 
0233 SO 24 
that there might be somebody additional that would come 
canto 25 
forward, but that hasn't been the focus of the 
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1 
Q. 
And •• and It's true, is it not, that if 
2 
you're successful in the CVRA case, In setting aside the 
3 
nonprosecution agreement, you expect to get other 
4 
clients who will have claims against Jeffrey Epstein? 
5 
A. If we — in civil daims? 
6 
Q. 
Claims for damages, claims for money from 
7 
Jeffrey Epstein. 
8 
A. 
That -- I mean, that starts to — if the 
9 
nonprosecution agreement Is set aside? 
02214 10 
Q. 
Yes, if you're successful. 
022119 11 
A. 
I haven't really — that sounds pretty 
ono, 12 
speculative. I haven't really thought about the 
oznot 13 
dvIl — the focus of the CVRA case is criminal. I 
one 14 
haven't thought about, you know, whether, civil claims 
ti 15 
could somehow arise out of that. I mean, we are talking 
en,. 16 
about, you know, events that took place long ago. There 
canto 17 
would be statute of limitations issues, you know. 
012220 18 
Whether they are viable civil claims at this point has 
022124 19 
not been something that I have, you know, given much 
o2n2s 20 
thought to. 
arms 21 
Q. 
So is it your testimony then that you have 
an 7. 22 
not thought about the question of whether success in the 
ov 2333 23 
CVRA case may or result In you obtaining additional 
owe 24 
clients with claims for money damages against Jeffrey 
can., 25 
Epstein? 
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1 
litigation. 
012343 2 
Q. 
Whether --
OW 0 
3 
A. 
And you always hope that there are — yeah, I 
022340 4 
mean, any time you file a case, ah, I hope some more, 
022310 5 
you know, witnesses will come forward to support that 
022352 6 
case, but that hasn't been the focus, trying to secure 
onus 7 
additional -- additional witnesses. That Is a 
072351 8 
possibility, though. I mean, I think in fairness to 
022400 9 
your question, that is a possibility that, you know, 
022402 10 if — if the case attracts attention and — and 
022406 11 somebody, you know, says, you know, gosh, now that I — 
essa 12 
I -- I -- you know, I moved away to escape Epstein and 
022410 13 
now it's safe for me to come back, or 
or now I 
027413 14 
realize I have a daim, that's always a possibility. 
022415 15 
I certainly wouldn't want to suggest that, 
0224 I/ 16 
you know, we are ruling that possibility out 
02144 17 
Q. 
And for the same reason that additional 
witnesses might become available -- known, additional 
022427 19 
clients might become known, correct? 
rasa 20 
A. 
That is a theoretical possibility, yes. 
mix 21 
Q. In these four cases that you mentioned, the 
022434 22 
three that were, which you were counsel of record and 
rain 23 
one in which you were not, did you meet at any time In 
0224 44 24 
person with the clients? And if It's different as to 
0224 to 25 
some than others, tell me that, but --
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A. 
Q. 
A. 
Q. 
260 
Yes. 
In all four, you met with the clients? 
In three of the four. 
And were those three the three in which you 
were counsel of record? 
A. 
Yes. 
Q. 
As of December --
A. 
I believe I was counsel of record on all 
three of those. I would have to double-check. I know I 
was counsel of record in the federal case. The two of 
them are state casts, I believe, that it was pro hac in 
the state cases. 
Q. 
Okay. I won't ask you the names, but In the 
four cases, what are the Initials of your clients? 
A. 
Okay. So the — the --
Q. 
Put It this way: How are they identified in 
the caption that you filed? 
A. 
Well, also the three that were filed, one 
was — one was the initials S.R. I referred to 
Miss S.R. yesterday. That was the Jane Doe case in 
Federal Court in front of Judge Marra. 
There were two state claims. I'll --
identify the clients as E.W. and L.M. 
Q. 
And then the fourth one? 
A. 
The fourth one, I believe 
the initial M. 
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oar. 1 
firing on December 30th d 2014, was the first time that 
earn 2 
you had ever, yes, ever on behalf 
oar it 3 
any other client, accused Professor 
r 
z or 
017725 4 
Prince Andrew of sexual abuse in a public filing? 
ears 5 
A. If you're talking about direct allegation, 
si 6 
that's correct. 
• 
31 
7 
Q. 
Had you ever pudic -- well, at no other time 
0227 26 8 
that -- you expected when you filed the pleating on 
ono 9 
December 30th, 2014, that it would be -- be something of 
an* 10 
public record that would generate publicity, correct? 
orna 11 
A. 
Public record, the focus was not generating 
tenni 12 
publicity. Of course, when you file an allegation like 
W2714 13 that, there certainly would have been — we would 
mass 14 
anticipate there would have been publidty, absolutely. 
02 27 SO 15 
Q. 
And before December 30th of 2014, to the best 
• n 01 16 
of your knowledge, neither you, nor anyone else, had 
022100 17 
told Professor Dershowitz that there were allegations 
012112 18 
that he personally had engaged in sexual misconduct? 
rano 19 
A. 
Urn... 
02210 20 
MS. McCAWLEY: I'm going to object to that 
022620 21 
date if that reveals anything that would be 
fano 22 
privileged between something that would have been 
maa 23 
communicated by the client. 
wan 24 
MR. SIMPSON: No. These are communications 
022627 25 
to Professor Dershowitz. 
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titan 1 
MR. SCAROLA: Yes. And that could very well 
men 
2 
include attorney/diem privileged 
021033 3 
communications. 
ten 4 
MR. SIMPSON: let me -- 
ask my question. 
man 5 
By MR. SIMPSON: 
121136 6 
Q. 
My question is: Did you ever advise 
rata 7 
Professor Dershowitz that there were allegations that he 
022850 8 
had engaged, himself, in sexual misconduct with minors? 
anise 9 
A. 
Not me personally, no. 
02 26S? 10 
Q. 
Are you aware of any e-mail, letter, other 
1122104 11 communication from anybody that went to Professor 
Dershowitz that told Professor Dershowitz that he had 
awn 13 
been accused of engaging in misconduct himself? 
man 14 
A. 
Well, there-- I mean, I'm aware that there 
0200 15 
was a deposition request In 2009. There was a 
02»n 16 
deposition request in 2011. That was accompanied by an 
• n 17 
exchange of correspondence that said, for example, 
07019 18 
numerous witnesses have placed you in the presence of 
07011 19 
Jeffrey Epstein and underaged girls. It didn't then go 
ten 20 
on to say, and you were committing sexual abuse of them, 
ea re 21 but it said numerous witnesses had — had done that. 
o2no 22 
And I think a reasonable inference would be 
022113 23 
that, you know, you're verily sure that a witness and 
co NO 24 
then that also raises the possibility of — well, I 
022141 25 mean, I think Professor Dershowitz mentioned yesterday, 
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1 
and I believe the last Initial was B., but I may be 
022514 
2 
wrong about the B. First initial M. 
wino 3 
Q. 
At the -- okay. At the time that you filed 
022104 
4 
the Joinder motion --
02x05 5 
A. 
Yes. 
022605 6 
Q. -- In the federal case, so December 30th of 
mew 7 
022115 8 
terse 9 
terse 10 
rams 11 
cams 12 
012612 13 
0224 
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ern 
15 
012641 16 
072646 17 
nano 18 
012614 19 
07260 20 
anis 21 
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022702 23 
612705 24 
022107 25 
2014, you knew that naming Prince Andrew would generate 
substantial publicity, correct? 
A. 
I knew it would attract a lot of attention. 
Yeah, I mean, "substantial" we could debate, but, sure, 
I knew that that was going to -- you know, once you 
start exposing the extent of this criminal activity, 
obviously, there were going to be a lot of people 
interested, yes. 
Q. 
And you also knew that naming Professor 
DershowItz would attract publicity? 
A. 
Well, when you say "naming," one of the 
things you've got to understand is the names were 
already In the case, both Prince Andrew and Alan 
Dershowitz. We had pending discovery requests for 
information about both of them. So when you say "naming 
them," you know, they were already named in the case. 
Now, would the additional allegations have 
attracted additional attention? Sure. 
Q. 
Mr. Cassell, it's true, is it not, that the 
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that if you're in the presence of a convicted sex 
offender, or a sex offender and sex abuse is going on, 
you would have obligations, for example, at a minimum to 
report that, and it raises the possibility of other 
criminal activity as well. 
Q. 
Is it your testimony, Mr. Cassell, that 
telling a person that multiple people have identified 
you as a witness to some activity is fair notice that 
you, yourself, are acoised of engaging in criminal 
misconduct? 
A. 
So -- so you, I think, recharacterized the 
letter that went to Mr. Dershowitz in 2011. The letter, 
as I recall, doesn't say he is a witness. It says, if I 
recall -- we can double-check the language — but I 
believe the language says: Numerous witnesses have 
placed you In the presence of Jeffrey Epstein, underaged 
girls, and Epstein. Then, you know, so at that point, 
given what we know in this case, given that at that 
point in 2011, there had been an ongoing set of 
allegations against Mr. Epstein, I - I think your 
question doesn't — doesn't take into account this 
surrounding context. 
Not to mention the fact there had been a 2009 
deposition request and a 2013 document request. 
Q. 
Okay. I think you accurately characterized 
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266 
MR. SIMPSON: I'm sorry. You were right, 
yes. 
MR. SCAROLA: Can you Just Mow it to him? 
MR. SIMPSON: 
read it, and then if he 
wants to look at it, that will be fine. 
MR. SCAROLA: Thank you. 
BY MR. SIMPSON: 
Q. 
This is a letter from Mr. Scarola to 
Mr. Dershowltz dated August 23rd, 2011. The second 
sentence says -- well, I'm going to read the whole 
thing. 
023224 12 
MR. SCAROLA: Yeah, thank you. 
13 
BY MR. SIMPSON: 
14 
Q. 
'We do nor --
15 
MR. SCAROLA: It's short, so it would be 
16 
helpful if you just read the whole thing. 
17 
BY MR. SIMPSON: 
18 
Q. 
Yeah. 
02 3231 19 
we do not intend to inquire about any 
renii 20 
privileged communications or attorney work 
con 
21 
product. We do, however, have reason to believe 
023337 22 
that you have personally observed Jeffrey Epstein 
013241 23 
in the presence of underaged females, and we 
an4 4 24 
would like the opportunity to question you under 
011247 25 
oath about those observations. Thank you for 
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cew 
1 
the communication about the deposition request that 
023.39 2 
multiple persons have placed you in the presence --
023,23 3 
A. 
Right. 
are 33 4 
Q. 
-- of minors 
07.1173 
5 
A. Right 
022124 6 
Q. 
-- correct? 
023127 7 
A. 
I believe that's my recollection. Numerous 
ems 39 8 
witnesses have placed you in the presence of sex 
0211 u 
9 
offend — at that point, convicted sex offender Jeffrey 
an Is 10 
Epstein, who was convicted of sexually abusing underaged 
021131 11 
girls, and underaged girls, and those are the subjects 
on, a 12 
we would like to question you about. 
cano 13 
And rather than getting a response that says, 
013146 14 
well, let me dear that all up, the response that's 
0131.• 15 
received was, something along the lines of, give me more 
ens, 16 information and — and, quote: I'll decide whether I 
0231 si 17 
want to cooperate, close quote, or something along those 
0231sT 18 
lines. 
02 31 sr 19 
Q. 
Mr. Cassell, let me -- Pm going to read to 
03.31 51 20 
02 MI 21 
A. 
Good. 
0231 Se 22 
Q. 
-- from the letter Itself --
rev se 23 
A. 
Okay. 
Rum 24 
Q. 
-- and tell me if It's consistent with your 
02/203 25 
recollection. 
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02)231 1 
your anticipated cooperation. Signed, Jack 
num 2 
Scarola.-
ORM 3 
If you would like to --
0202M 4 
A. 
Sure. 
one 
5 
Q. -- take a look at the letter to refresh 
ass? 6 
yourself, you're welcome to. 
www 7 
A. 
Great. Thanks. Okay. 
<QUM 8 
Q. 
Now, first, you're aware, are you not, that 
cent. 
9 
Professor DershovAtz answered that letter and said the 
nun 10 
assertion that he had observed Mr. Epstein in the 
0233-11 11 
presence of underage --
cent: 12 
MR, SCAROLA: Females. 
0233.02 13 
BY MR. SIMPSON: 
02 33» 14 
0213 24 15 
021124 16 
wsits 17 
02 3)11 18 
be great. 
caw u 19 
Q. 
And "I have never -- this is a letter from 
023302 20 
Mr. Dershowitz to Mr. Scarola, August 29th, 2011. 
02 3334 21 
"Dear Mr. Scarola, I have never personally 
079 41 22 
observed Jeffrey Epstein in the presence of 
40 33 43 23 
underaged females. I do not believe you have any 
awes 24 
reasonable basis for believing that t have. If 
0213 43 25 
you have -- if you claim to have reason to 
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A. 
Q. 
A. 
-- females was not true? 
Something along those lines, yeah. 
Yeah. And I will read it from that letter --
Okay. That would be good. Yeah, that would 
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believe, please provide me with any such reason. 
I am certain I can demonstrate to you that it Is 
false.' 
Is that consistent with your recollection of 
the response? 
A. 
That sounds about right, yeah. 
Q. 
So Mr. Dershowitz did not ignore the letter; 
he responded to it, correct? 
A. 
I think that's right 
Q. 
And go back to the first letter. 
023410 11 
A. But, now, if we are — If we're talking 
0234 11 12 
about — yeah, there's that one letter and now there's a 
coin 13 
response letter, right. 
tax 14 14 
Q. 
My question to you Is: Does the statement to 
02 14 /I 15 
a person that "we have reason tO believe that you have 
on. 70 16 
personally observed another person In the presence of 
mm m 17 
underage females and we would like to ask you about your 
nu 36 18 
observations," put the recipient on notice that you, 
an 41 19 
yourself, are accused of criminal conduct in abusing 
Lem is 20 
minors? 
023446 21 
A. 
Well, it puts you on notice that you're a 
0234 49 22 
potential, obviously, witness to this and then therefore 
0234» 23 
you could have potential Involvement. 
ri ms 24 
Let me give you a ample illustration. It'll 
0134n 25 
take about 20 seconds. If somebody says —
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ensin 
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1 
In the context of this case, to say, you have 
2 
been observed in the -- in -- by numerous 
3 
witnesses in the presence of a convicted sex 
4 
offender and underage girls, and we would like to 
5 
talk to you about those observations, I think 
6 
that puts you on notice that you're in -- In --
7 
in jeopardy of -- of criminal activity, 
8 
particularly when you combine that with the fact 
9 
that there Is a duty to report child abuse In 
many states in this country, including the State 
of Florida. 
And so that if those observations were such 
that they would give rise to a reasonable 
Inference that sex abuse was -- of children was 
going on and you'd be obligated to report it, as 
I think Mr. DershovAtz conceded yesterday, yes, 
yOu -- I think that puts you on notice that --
that those kinds of things are being alleged. 
BY MR. SIMPSON: 
Q. 
So, first, the letter Itself, the letter from 
Mr. Scarola simply says, you were -- you were personally 
-- you personally observed Jeffrey Epstein in the 
presence of underaged females, correct? 
A. 
Correct. 
Q. It does not say, you witnessed abuse of any 
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14 
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1 
Q. 
Welt, let me back up. My first Question, 
2 
though, if you can answer the Question. 
3 
MR. SCAROLA: No. I'm sorry. The witness is 
4 
entitled to complete his response. If you 
5 
don't -- if you believe it to be unresponsive, 
6 
you can move to strike it, but he's entitled to 
7 
complete it. 
8 
MR. SIMPSON: He --
HR. SCAROLA: So go ahead and complete your 
response. 
MR. SIMPSON: Can we have a -- you can give 
an explanation, but a yes or no with an 
explanation. 
MR. SCAROLA: You already got that. Could we 
now have the completion of the response? 
THE WITNESS: Here's the simple illustration 
I think makes it pretty clear: If somebody says, 
we have observed you in the presence of a kilo of 
cocaine, we would like to question you about the 
presence -- about your observations of this, that 
doesn't directly state that you are a drug user 
or a drug dealer, but it certainly puts you on 
notice that you're associated with that criminal 
activity and somebody is going to Question you 
about it. 
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1 
minor; we have reason to believe you observed abuse of 
02 3631 
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minors? 
023630 
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A. If those words do not appear there, but come 
nun 4 on, we — we know -- we know in the context of this 
02 n.. 
5 
case, when somebody is asking to take a deposition about 
no 
6 
your observation of young girls, they weren't talking 
02 x30 7 
about preparations for birthday parties. They were 
02037 8 
talking about sexual abuse of children. 
02306 9 
And that was what Mr. Dershowltx was going to 
mew 10 
be asked about. And he did not -- he did not take that 
02 x02 11 opportunity to try to clear the record; Instead, we are, 
013305 12 
you know, here today, because among other reasons, he —
he -- he wasn't deposed then. 
Q. 
I want 
I want to comment. I'm Just a 
little bit non -- nonplussed, so I want to come back to 
this again. 
0131 21 17 
A. 
Well, I'm -- I have to tell you, I'm a little 
023:23 18 bit nonplussed that somebody would say that letter 
02 37 24 19 
doesn't put you on notice that you're potentially 
02 37, 20 
involved In criminal activity. I mean, come on. 
023/30 21 
Q. 
I -- my question wasn't potentially involved 
ken= 22 
in criminal activity. We disagree about whether it does 
onyx 23 
that. 
013117 24 
A. 
Okay. I think It does. 
0217 n 25 
Q. 
I suspect you -- that's how you read it? 
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1 
A. 
I think it puts you on notice in the context 
ea 370 
2 
of a country which has required people to report the 
C2 n4, 
3 
sexual abuse of children, and somebody wants to talk to 
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you about your observations of a convicted sex offender 
OW C2 
5 
with underage girls, that that's going to be one of the 
subjects that's going to be discussed, yes. 
Q. 
My question was -- my Initial question was: 
Does -- do the statements in this letter put the reader 
on notice that you, personally, are accused of abusing 
oraii. 10 
minors yourself, not that you have In some knowledge or 
0224 0 11 
evidence that someone else did it, but that you, 
022 
12 
yourself, did it; Is that a way to give fair notice? 
°nem 13 
A. 
Well, in fair notice in what context? You 
Gin 
14 
know, is he on notice that a lawsuit is going to be 
02,1 3' 15 
filed the next day? 
023832 16 
Simply from that piece of -- that letter 
:emu 17 
alone, they are on notice, you know 
I mean, I think 
CO MP 18 
that puts you on notice that there are serious 
ea a 4! 19 
allegations afoot and it would be in your best interest 
02 MO 20 
if you hadn't done anything, to show up, attend a 
CC Ma, 21 
deposition, let all the facts come out so that everybody 
02 3.0 22 
can know them. 
COM./ 23 
Q. 
Would you agree that accusing someone of 
02 ao 5. 24 
themselves abusing a minor is different than accusing 
CC CO 0) 25 
someone of having knowledge that somebody else did it? 
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his criminal associates were doing. And he thought that 
024005 
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Mr. Dershowitz would have information and was trying to 
02401 3 
collect that. 
4 
Now, whether the — the -- the tentades of 
024010 
5 
the organization would extend so that they wrapped 
04043 6 
around Mr. Dershowitz himself, I guess was the subject 
Orate 7 
that — that Mr. Scarola, I am assuming, was hoping to 
NNW 8 
explore. But Mr. Dershowitz prevented that opportunity. 
024022 
9 
Q. 
And Mr. Dershowitz, you knew, had been 
woe 10 
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Mr. Epstein's attorney, correct? 
A. 
Correct. 
Q. 
And you knew, just as we have seen here today 
with multiple assertions of privilege, that he could not 
testify about anything he learned as an attorney' 
A. 
He could testify, and the letter itself says, 
we are not going to ask you about any communications; we 
are going to ask you about observations of sex abuse by 
a convicted sex offender, and your personal knowledge of 
that. That would not have erased in the — and 
Mr. Scoreless a very good attorney, and I'm sure all of 
his questions that we saw the last couple of days would 
have been very narrowly focused on observations about 
what this criminal organization was doing. 
Q. 
And so to the bottom line Is that your view, 
your sworn testimony, this letter of August 23rd, 2011, 
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A. 
Yes. 
Q. 
And to accuse someone of abusing a minor Is a 
serious, serious accusation of criminal conduct, 
personal criminal conduct, not just failing to report 
somebody else, but you, yourself, are abusing people? 
A. 
Oh, yeah. 
MR. SCAROLA: Are you suggesting that that's 
not criminal conduct? 
MR. SIMPSON: I'm -- I'm 
my question 
stands. 
BY MR. SIMPSON: 
Q. 
What is the answer to that? 
A. It Is a very serious charge, I agree. That's 
why we are all here today. 
O. 
Okay. And -- and if you wanted to put 
someone on fair notice that they are accused themselves 
of being a sex offender, a criminal who has abused 
children, wouldn't you tell them that? 
A. 
That's a speculative question because that 
letter was designed to try to collect information about 
an international sex trafficking organization. And so 
as to -- you know, I'm not going to speculate as to why 
Mr. Scarola wrote it that way. But my sense, based on 
the public record Is, that he was trying to get as much 
information as he could about what Jeffrey Epstein and 
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ants 1 
put Mr. Dershowitz, Professor Dershowitz, on fair notice 
024121 2 
that he was being accused of being a sex offender 
amiss 3 
himself? 
054320 4 
A. 
We — we have gone over this. I think it put 
now 5 
him on fair notice that there were serious questions 
024431 6 
being raised about what he knew about this criminal 
0241421 7 
organization, what the potential criminal responsibility 
NON 
8 
he had for failure to report sexual abuse of a child, as 
fen 
9 
well as other possibilities. 
OMEN 10 
MR. SIMPSON: I'm going to move to stoke as 
02410311 
nonresponsive. 
aura 12 
BY MR. SIMPSON: 
024124 13 
Q. 
My question Is a very narrow one, whether 
sure 14 
this letter, in your opinion, under oath, fairly put 
non 15 
Mr. -- Professor Dershowitz on notice that he himself 
024112 16 
was accused of abusing minors. 
ono 17 
A. 
Again, that's a vague question. I've tried 
moo 18 
to give the best answer I can. That was certainly a 
wool 19 
potential area of questioning. I think that puts him on 
woe 20 
notice that it would have been in his best interest to 
nag 21 appear to answer those questions. 
021214 22 
MR. SIMPSON: I'm going to object to the 
024214 23 
answer again as nonresponsive. 
024216 24 or MR. SIMPSON: 
nu,. 
25 
0. It's a really simple question. 
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Does that letter put Mr. Dershowitz on fair 
notice that he's accused of being a sex offender 
himself? 
MR. SCAROLA: Objection. Repetitious. To 
the extent that you can improve upon the answer, 
you can improve upon the answer. If you can't, 
all you need to do Is say that. 
THE WITNESS: I -- and I'll try to --
02e» 9 
obviously, I want to be responsive --
ten 10 
BY MR. SIMPSON: 
0261.34 11 
O. Let -- let me ask --
moo 12 
A. -- to your question. 
taun 13 
Q. I'll ask you a different question. 
itt2 .1 14 
A. 
I don't think that's a yes or no question 
nun 15 
because of -- of you're including vague terms like fair 
024245 16 
notice and 
and those sorts of things. So -- but go 
rear, 17 
ahead and ask your questions and I'll — I mean, go 
02420 18 
ahead. 
024201 19 
Q. 
You're a former federal Judge? 
024255 20 
A. 
Right. 
man 21 
Q. 
A former Supreme Court law -- law clerk? 
ray Si 22 
A. 
Yes. 
cross 23 
Q. 
Professor at a law school? 
ono 24 
A. 
Yes. 
024201 25 
Q. 
Reading as -- reading the language of this 
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having abused minors? Can you answer that: Yes or no? 
A. 
No. I think a yes-or-no answer would be 
misleading, given the context of this case. 
Q. 
You referred in your earlier testimony to --
strike that for a moment. 
You referred in your earlier testimony to an 
article that appeared today regarding 
Professor Dershowitz's deposition testimony, correct? 
A. 
I don't think so. 
O. 
Okay. Are you aware that -- well, perhaps It 
was Miss McCawley who referred to it. 
Do you recall there being a reference this 
morning to an article being published about 
Professor Dershowitz's testimony? 
MS. McCAWLEY: Oh, I'm sorry. It was me. I 
objected to the extent -- only to the extent it 
revealed something public that had been stated In 
public. 
BY MR. SIMPSON: 
O. 
Okay. And I -- you recall that? 
A. 
Yeah, I recall the objection. I think 
there's an article that came out yesterday or a 
communication. I -- I — you know, I can't remember 
the -- exactly where I -- I know that I received a 
communication, either through publication or in some 
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other way from the -- from the -- you know, I became 
aware that there was a statement that the -- what's the 
name of the outfit? It's the Business Investor — 
MR. SCAROLA: Daily Business Review. 
THE WITNESS: Daily Business Review that was 
stating that David Boles was saying that the 
representations made by Mr. Dershowitz were 
false. 
MR. SCAROLA: I did just coach the witness. 
I apologize. 
THE WITNESS: Yeah. And, I'm sorry, just for 
the name of that, so... 
BY MR. SIMPSON: 
Q. 
And you -- In your earlier testimony, you 
referred to it -- you didn't recall the name, but you 
referred to it as a reputable --
A. 
That's right. 
Q. -- publication? 
A. 
That's right. That's the one we are talking 
about, right. 
Q. Right. And in that article it states: 
"McCawley," referring to our colleague, 
"later issued a statement on Boles's behalf 
saying, because the discussions that Mr. Boles 
had with Mr. Dershowitz were expressly privileged 
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1 
letter, in your opinion, does the language itself put 
024114 
2 
the recipient on notice that the recipient is accused of 
104273 
3 
abusing minors himself? 
074121 4 
A. It puts him on notice that that is going to 
MO 24 
5 
be a potential subject of inquiry at the -- at the --
won 6 
the deposition. 
02 411. 7 
Q. So your answer then is, yes, it puts the - 
02 4222 
8 
the -- the person on notice; that's your reading? 
02040 9 
A. 
You're — I think you're putting words in my 
024142 10 
mouth. You're 
you're trying to ask, you know, a 
02404 11 question that on the one hand, you're suggesting is 
couit 12 
narrow, and on the other hand is broad. It -- I mean, 
4,o.» 13 
this is probably the simplest way to answer that 
02010 14 
question. 
eon 15 
If I had gotten that letter, I would have 
024352 16 
said, schedule the deposition in the next 24 hours, and 
024166 17 
come on down here now, and I will be available for a 
0543 50 18 
week. That's what I would have said if I had gotten 
024401 19 
that letter. 
02440 20 
MR. SIMPSON: Move to strike as 
024403 21 
nonresponsive. 
024402 22 
BY MR. SIMPSON: 
inns 23 
Q. Is it your testimony you can't answer yes or 
owe 24 
no whether that letter, on its face, puts the recipient 
0244 12 25 
on notice that the recipient is accused himself of 
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settlement discussions, Mr. Boles will not, at 
least at this time, describe what was actually 
said. However, Mr. Boles does state that 
Mr. Dershowitz's description of what was said Is 
not true." 
A. 
Q. 
A. 
That's the one. 
You read that? 
Yeah. I -- I learned of it -- yeah, I don't 
remember whether I read or how I got it, but yeah, 
that's the one. 
Q. 
In light of that statement by Mr. Boles, 
would you agree that any privilege has been waived? 
A. 
I would not. 
Q. 
A. 
That's -- that's a newspaper article. 
Q. 
It's a pub -- it's a quote. Let me clarity. 
That's a statement -- quoting a statement issued by 
Ms. McCawley and quoting Mr. Boles as saying, 
Mr. Dershowitz's description of what was said is not 
true, so that's a public statement by Mr. Boles saying 
that Mr. Dershowitz's testimony is not true; is that a 
waiver in your view? 
A. 
No. And that would require — I'm with --
I'm just putting you on notice, talking about notice, if 
you want me to, I could give you the law professor 
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MR. SCAROLA: Why don't you start over again? 
At om 
2 
MR. SIMPSON: No. I Just want --
02 40 
3 
MS. McCAWLEY: We disagree with 
wale 
4 
your characterization of that as a waiver. It 
074410 
5 
was a statement that was issued in order to stop 
424612 
6 
the waivers that Mr. Dershowitz was trying to 
074:1 
7 
engage in, and we -- we don't agree that's a 
61026 
8 
waiver and we will not allow any testimony 
014617 
9 
regarding those communications. 
014424 10 
MR. SIMPSON: Okay. I disagree with the 
ervi3, 11 
position and the characterization, but I just 
02.443) 12 
wanted to clarify on the record, I didn't have to 
nun 13 
ask those questions again. 
ream 14 
MR. SCAROLA: Sure. 
024434 15 
MS. McCAWLEY: I understand. 
02402 16 
MR. SIMPSON: And, obviously, our position is 
0244D 17 
that if it hadn't already been -- if it hadn't 
already been waived -- either it wasn't 
02400 19 
privileged or hadn't been waived, it's now 
024447 20 
waived. 
02444? 21 
THE WITNESS: And my -- Just --
0241 
22 
MR. SIMPSON: I don't have a question. 
ram Li 23 
THE WITNESS: I know, but I -- but I think 
roue 24 
now in light of, since the record has these 
02463 25 
characters, I just want to put one sentence into 
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1 
answer as to why that's not a waiver. Off the top of my 
2 
head, I can start talking about that. 
3 
O. 
No. I don't -- I don't need that. 
4 
A. 
Right. That's why I just wanted to let you 
5 
know, so... 
6 
Q. 
But I really wanted to clarify -- and what I 
7 
wanted to clarify was --
8 
A. 
I do not -- let me just be clear, so the 
record is clear: I absolutely do not believe that's a 
waiver and I could give you an extended answer, but I 
know time is drawing short --
Q. 
All right. 
Q. 
But you -- what I want to clarify is that, 
024100 15 
notwithstanding that statement, you will continue to 
014602 16 
answer all my questions about the substance of 
*zoo 17 
discussions with Mr. Boles; you're continuing not to 
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answer, you're continuing •-
014410 19 
MS. McCAWLEY: Yes 
20 
MR. SCAROLA: You Just said you --
0240 
21 
MS. McCAWLEY: -. I believe --
024 II 22 
MR. SCAROLA: -- continue to answer. 
man 
23 
MS. McCAWLEY: I'm sorry. 
41244111 24 
MR. SIMPSON: I'm sorry. 
man 
25 
MS. McCAWLEY: Continue not to answer. 
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the record, which Is: It doesn't seem to me that 
2 
an attorney can inject into a deposition 
3 
confidential settlement proceedings, have 
4 
somebody deny that, and then say, aha, they're no 
5 
longer confidential settlement proceedings, so 
6 
that's --
7 
MR. SIMPSON: There's no question pending. I 
8 
move to strike the comments. 
9 
THE WITNESS: Right. I just didn't want your 
comments to -- to reflect back on my earlier 
answer. 
BY MR. SIMPSON: 
Q. 
I want to go back, Mr. Cassell, get back to 
yesterday's exhibits. I'm going to hand you what was 
marked yesterday as Cassell Exhibit Number 2, which is 
the joinder motion, and when you have that in front of 
you --
A. 
Got it. 
Q. 
Do you have that in front of you? 
A. 
I do. 
Q. 
All right. Would you -- find my copy of 
02490 22 
it -- if you would turn to page -- bottom of page 3, 
02400 23 
part of -- top of page 4; do you have that? 
024062 24 
A. 
Got it. 
014663 25 
Q. 
All right. I'm going to read it. Tell me If 
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I've read it correctly. 
A. 
Okay. 
Q. -Epstein also sexually trafficked the 
then-minor Jane Doe" -- and that' 
correct? 
A. 
Yes. 
Q. -- "making her available for sex to 
politically-connected and financially-powerful people. 
Epstein's purposes in lending Jane Doe, along with other 
young girls, to such powerful people were to ingratiate 
himself with them for business, personal, political, and 
financial gain, as well as to obtain potential blackmail 
information." 
Did I read that correctly? 
You did. 
What did you mean by 'obtain potential 
A. 
Q. 
blackmail information'? 
A. 
Okay. Let me just double-check. 
Once the criminal organization had put the 
bait out, so to speak, to various people, and they took 
the bait that -- you know, I'm -- I'm speaking 
colloquially here. These are 
these are young girls 
who are being sexually abused. Once the criminal 
organization had gotten people to sexually abuse 
these 
these young girls, at that point, they had 
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information that they could use to blackmail those 
people and -- and then get favors in exchange. 
And that's Epstein at the head of the 
organization would be the one who would benefit most 
directly from the black -- the blackmail information. 
Q. 
And by "blackmail information," do you mean 
that Mr. Epstein then had information that he could 
threaten to disclose if the other person didn't do what 
Epstein asked them to do? 
A. 
Precisely. 
Q. 
As of December 30th, 2014, if Miss Roberts 
had access to publicity, she had exactly the same 
ability to blackmail people; Isn't that Due? 
A. 
Absolutely not. A billionaire has far more 
resources than a victim of child sex abuse, particularly 
one that has been forced into hiding in Australia to 
escape the criminal organization. 
So for you to suggest tha 
had the same ability to blackmail s 
Epstein Is, I think, preposterous. 
Q. 
As of -- Miss -- Miss Roberts had the same 
ability as Jeffrey Epstein to reveal publicly the names 
of the people who she says sexually abused her, as did 
Mr. Epstein; isn't that true? 
A. 
You're talking about physical ability to 
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OR 02 7 
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Interview or not? 
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A. 
I wasn't sure. That's right. 
an 12 
Q. 
And after December 30th, 2014, the references 
cent. 13 
to Prince Andrew and Professor Dershowitz generated 
ten 14 international publicity; isn't that true? 
02 SW 15 
A. 
Okay. Which -- yes, I mean, In a general 
co 51 11 16 
sense, I could ask which allegations, but these 
null 17 
allegations did generate publicity, certainly. 
coos 18 
Q. 
Yes. The allegations in your Joinder motion 
025314 19 
and Professor Dershowitz had abused 
02 25. 20 
en known as Jane Doe Number 3, 
cone 21 
genera e a res orm of publicity; did it not? 
earn 22 
A. It generated a lot of publicity, yes. 
COM 12 23 
Q. 
And within days of that, you were -- you were 
020 35 24 
participating in attempting to arrange an interview with 
come 25 
ABC News; isn't that true? 
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speak words. They both have the same physical ability 
to speak the English language, yes. 
Q. 
And, in fact, before, at least three years 
before December 30th, 2014, she had the ability to be 
quoted in an article, more than one article, in the 
Daily Mail in London about her experiences, correct? 
A. 
That's correct. 
Q. 
And am I correct that as of December 30th, 
2014, you didn't know whether she was paid for that 
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A. 
That — within days of — the chronology is 
important here: The allegations were filed in this 
pleading on December 30th. Several days after that, 
Mr. Dershowitz then took to the airwaves to denounce, 
not only Brad and me, but -- but particularly of concern 
to me wa 
s victim of sex 
traffickin 
And, at that point, as one of — as one of 
her attorneys, I was looking for a way to respond to 
that media assault on her by Mr. Dershowitz. 
MR. SIMPSON: Move to strike as 
nonresponsive. 
BY MR. SIMPSON: 
Q. Did -- within 24 hours of this pleading being 
filed, there was publicity about the allegations against 
Prince Andrew and Mr. Dershowitz -- Professor 
Dershowitz; isn't that correct? 
A. 
I don't know the exact time frame, but 
that — you know, roughly that time frame sounds about 
right. 
0. If Mr. -- if Professor Dershowitz had never 
said anything, wouldn't you expect that these 
allegations as to Prince Andrew, in particular, and 
Professor Dershowitz would get substantial publicity? 
A. 
There was — there was --
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MR. SCAROLA: Excuse me. To the extent the 
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Prince Andrew had sexually abused 
ow o 2 
question calls for speculation, I object. 
MK 11 2 
correct? 
muss 3 
oust 4 
MR. SIMPSON: No. I'm asking for his state 
of mind when he filed this document. 
02x,3 3 
026421 4 
A. 
That was one of the allegations in here, 
sure. 
0254M 
5 
THE WITNESS: There's no doubt that -- 
023331 5 
Q. 
And the allegations that Professor Dershowltz 
sass w 6 
MR. SCAROLA: So the question is: At the 
men 6 
had sexually abuse? 
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time of the filing -- 
0234 31 7 
A. 
That's right. It was in a — what we were —
germ 8 
MR. SIMPSON: Please -- please don't coach 
one n 8 
what we were starting to document and allege here was 
gesso 9 
the witness. 
4266n 9 
that terrible things that Epstein's criminal 
asses 10 
MR. SCAROLA: No, I'm not coaching him. I 
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organization had done. 
armor 11 
just want to understand the question. You're 
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Q. 
Let me refer you to page 6 — 
nom 12 
asking what his state of mind was at the time of 
02610 12 
A. 
Okay. 
now 13 
filing? 
0224 47 13 
Q. -- of your filing. It's the first full 
osit. 14 
MR. SIMPSON: Did he -- did he anticipate -- 
or son 14 
paragraph. 
osso 15 
MR. SCAROLA: Because the other question was: 
071644 15 
A. 
Yep. 
QM 11 16 
What do you -- what's your position today. 
roma 16 
Q. I'm going to read it. "Epstein also 
ens" 17 
MR. SIMPSON: Mr. Scarola, really. 
0236Si 17 
trafficked Jane Doe Number 3 for sexual purposes to many 
nn,. 18 
MR. SCAROLA: That's -- that's a different 
02 SG S6 18 
other powerful men." 
awls 19 
question. So I just want to know which one 
ivory 19 
A. 
Okay. 
ens" 20 
you're asking. 
or Hp 20 
Q. 
"Including numerous prominent American 
au.. 21 
aim, 22 
Do you want to know his state of mind then, 
or his state of mind today? 
023700 21 
02 tie 22 
politicians, powerful business executives, foreign 
presidents, a well-known prime minister, and other world 
woo 23 
MR. SIMPSON: I will take that as an 
cv sr I* 23 
leaders. lane -- Epstein required lane Doe Number 3 to 
nine 24 
objection to the form of the question. 
02 4/.,s 24 
describe the events that she had with these men so that 
now 25 
a u w 25 
he could potentially blackmail them? 
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BY MR. SIMPSON: 
non. I 
Did I read that correctly? 
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Q. 
As of -- 
win' 2 
A. 
You dld. 
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MR. SCAROLA: It's a request for a 
ram 3 
O. 
With respect to blackmail, the ability to 
arra 4 
clarification of an ambiguous question. 
non 4 
blackmail, is that the same potential we talked about a 
ossn 5 
MR. SIMPSON: It's coaching the witness. 
arum 5 
moment ago in your testimony? 
awn 6 
BY MR. SIMPSON: 
021722 6 
A. Sure. 
nom 7 
Q. 
As of -- 
423732 7 
Q. 
And you're referring there to --
nom 8 
A. 
Yeah, I don't need any coaching. I mean... 
021734 
8 
A. 
Roughly, yeah. I mean, if there's something 
as ism 9 
Q. 
Let me ask the question. 
wow 9 
that you want darified, go ahead and darify it. 
auss 10 
our 11 
As of December 30th -- that's true -- as 
of — 
425737 10 
on 11 
Q. 
I just -- I just wanted to make sure I 
understand corr ctl that when ou refer that -- to 
02.64» 12 
A. Right -- 
woo 12 
Epstein requirl 
scribe these 
nun 13 
Q. 
-- we agree that's coaching. 
42574/ 13 
events so that he could potentially blackmail them, what 
atm» 14 
A. -- but that wasn't coaching. That wasn't 
no 14 
you had in mind was, Epstein wanted to know what 
0314 41 15 coaching, so the suggestion that it's coaching is — is 
OW 12 15 
these men so that he had the 
*MO 16 
not fair. 
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a 
y o 
rea en o istlose It If they didn't do 
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Q. 
Okay. We disagree. 
woo 17 
what he wanted them to do? 
wow 18 
As of December 30th, 2014, did you anticipate 
woo 18 
A. 
That was — that was part of It, yes. 
471612 19 
that naming Prince Andrew in a public filing as having 
ono 19 
Q. 
And isn't it true you could have 
one a 20 
abuse 
otid generate substantial 
423104 20 
accomplished -- in terms of furthering 
023402 21 publicity? 
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gal interests, you could have accomplished 
new 22 
A. "Substantial" is a debatable word, but 
02 SS 10 22 
same thing by saying Epstein also 
Note 23 
certainly, it's going to generate publicity, yes. 
023414 23 
trafficked -- trafficked Jane Doe Number 3 for sexual 
nal° 24 Publicity about the allegations. 
nun 24 
purposes to other well-known men, period? 
emu 25 
Q. 
YeS. And -- and the allegations are that 
cosia 25 
A. 
No, I don't think so. 
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Q. 
Okay. You felt that it furthered her legal 
MN 30 
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interests to specify American politicians, powerful 
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business executives, foreign presidents, a well-known 
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prime minister and other world leaders; that was your --
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you — you believe that furthered her legal Interest? 
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A. 
Yes. 
duo 
7 
Q. 
Old you also anticipate that that would 
town 8 
titillate the PreSS, so to speak, that there would be a 
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lot of speculation on who these people are? 
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A. 
That wasn't the — that wasn't the focus 
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of the — those comments, no. 
nu 
12 
O. 
You said it wasn't the focus. Did you 
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realize it would happen? 
sun 
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A. 
Sure. I mean, this was a case that had 
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been already — this litigation 
had been going on at 
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that point for seven years and lots of people were 
resew 17 
following IL This is — this case is one of the most 
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egregious examples of a violation of Crime Victims' 
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Rights in the history of this country. 
4050%3 20 
And so against that context, yes, there were 
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going to be people interested in every word that was 
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going Into this pleading. Whether we had gone more 
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broadly or more narrowly than what we did, people were 
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going to be interested in this. 
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Q. 
And as of December 30th of 2014, Miss Roberts 
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break. I appreciate that. 
Q. 
Okay. 
MR. SCAROLA: Could you just read back the 
last question for me? I just want to orient 
myself as to where we are. Thank you. 
(Thereupon, a portion of the record vas read 
by the reporter.) 
MR. SCAROLA: Yeah, I didn't I think the 
answer was --
THE WITNESS: I guess I was mid-sentence, so 
think I will just stick with the same word, 
preposterous. And one •- one thing that occurred 
to me during the break, in the context of this 
case, is that there had been allegations that 
Epstein was part of the -• the sex trafficking 
organization, had video cameras mounted 
throughout many of his -- his mansions. And so, 
whereas a young woman could say, or a young gal 
could say, look, I was a victim of sex abuse, 
people would attack her; people wouldn't believe 
her, that unless she had, you know, corroborating 
evidence, people would say, well, look, it didn't 
happen. 
And so Epstein had managed to collect 
apparently a lot of videotapes and other kinds of 
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had the same ability to disclose who these individuals 
2 
were publidy, as did Jeffrey Epstein, correct, because 
3 
she had personal knowledge of who they were? 
4 
A. 
She had the ability to speak the words, but, 
0 26t.17 
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again, I think it's preposterous to say that a victim of 
costa 6 
sex trafficking has the same power as the sex trafficker 
on 
7 
to disdose information. 
roses. 
8 
For exampleauld 
be 
ream 9 
attacked, and I think as we were talking about 
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yesterday, we have seen evidence of the kind of attack 
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that powerful people can mount against the victims of 
wow 12 
sex trafficking. 
So to say that the young women in sex 
030004 13 
trafficking 
schemes have the same power as their 
0)0007 14 
traffickers to do this — I'm sorry. I'm going to have 
moil 15 
to take a break. 
w es u 16 
THE VIDEODRAPHER: We are going off the video 
0)0314 17 
record, 11:32 a.m. 
0101 I4 18 
(Thereupon, a recess was taken.) 
03 04 •4 19 
THE VIDEOGRAPHER: We are back on the video 
n enc. 20 
record, 11:36 a.m. 
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BY MR. SIMPSON: 
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Q. 
Had you finished your answer, Mr. Cassell? 
A. 
I think I had. 
Q. 
Okay. 
Thank you. Thank you for letting me take a 
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information that would have been -- given him the 
2 
ability to make the blackmail kinds of charges 
3 
that the girls that he was trafficking would --
4 
would not have had the ability to do. 
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BY MR. SIMPSON: 
6 
O. 
Mr. Cassell, didn't you testify yesterday 
7 
that any videotapes from Mr. Epstein's house had been 
8 
destroyed? 
030120 9 
A. 
I — when I used the word "destroyed," I 
town 10 
probably should have been more precise. They had been 
own 11 
concealed from law enforcement, is what! meant 
That 
town 12 
when Palm Beach Police Department went up to the Epstein 
030137 13 
mansion, they found surveillance cameras and other 
030541 14 
cameras. I can't remember exactly where the cameras 
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were, but they found surveillance cameras, and when they 
tour 16 
looked for the tapes associated with those cameras, I 
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used the word "destroyed"; 
and as I say, I probably 
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should have said they were missing. And so they were 
ono 19 
never able to locate those -- those missing videotapes. 
wens 20 
Q. 
So as of December 30th of 2014, to your 
01.701 21 knowledge, there were no videotapes available? 
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A. 
There were no videotapes available to law 
030203 23 
enforcement or to Brad and his pro bono crime victim 
030103 24 
attorneys to help document our case. We were trying to 
000712 25 
get those and we are continuing to try to get those, 
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