EFTA01137794

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2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
Q. 
Was 
16 
17 underage? 
18 
19 
20 
21 
22 
23 
24 
25 
MR. SCAROLA: Move to strike. 
SPECIAL MASTER POZZUOLI: That, I will 
strike. Move forward. 
BY MR. EDWARDS: 
Q. 
Was Virginia lying when she says that 
Jeffrey Epstein also had sex with a girl named 
who is a Hollywood actress, from the time 
was 13 years old? 
MR. INDYKE: Same objections, same 
instruction. 
MR. SCOTT: Can you answer that? 
A. 
I've never heard that name. It's not 
familiar to me at all. 
BY MR. EDWARDS: 
lying when she says 
she traveled to Jeffrey Epstein's island when 
MR. INDYKE: Same objections, same 
instruction. 
BY MR. EDWARDS: 
Q. 
By "underage," I mean under the age of 18. 
A. 
I can only tell you I never saw her on the 
island. I was on the island when she was not there. 
I would love to know whole story she was 
on the island --
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1 
MR. SCOTT: There's no question pending. 
2 
BY MR. EDWARDS: 
3 
Q. 
The two-page flight log exhibit, if we 
4 look at January 22nd, 2001, and also 
5 December 14th, 2000, can you look at those, and 
6 I'll ask a question. 
7 
A. 
Sure. Give me the dates again. 
8 January 16? 
9 
Q. 
Where it has the departing airport code 
10 and --
11 
A. 
Yeah. 
12 
Q. 
-- where she's landing. 
13 
A. 
Right. 
14 
Q. 
TIST is the code for Virgin Islands, 
15 correct? 
16 
A. 
I have no idea. Been to the Virgin 
17 Islands once that I remember. 
18 
Q. 
You have been to Jeffrey Epstein's home on 
19 the Virgin Islands, haven't you? 
20 
MR. SCOTT: He's already answered that. 
21 
A. 
I was with my wife and my daughter and 
22 Professor --
23 
BY MR. EDWARDS: 
24 
Q. 
I don't mean to ask who you went with -- I 
25 didn't mean to ask --
EFTA01137835

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SPECIAL MASTER POZZUOLI: Hang on. Let 
2 
him finish his answer. I think this is 
3 
contextual. I'm okay with it. 
4 
A. 
And six months before 
5 ever met Jeffrey Epstein. So I was never on the 
6 island during the period of time that Jeffrey 
7 Epstein knew  
8 
SPECIAL MASTER POZZUOLI: Go ahead. 
9 
BY MR. EDWARDS: 
10 
Q. 
My question was, how did you get to the 
11 island? 
12 
A. 
Jeffrey Epstein sent a one-engine, small 
13 plane with a 70-year-old pilot for me, my wife and 
14 my daughter, and I regret to this day ever getting 
15 on that plane. Flew us from Guadalupe to the Virgin 
16 Islands, where I was picked up by a boat and taken 
17 to Jeffrey Epstein's island where we had dinner with 
18 Michael Porter and his wife and family and my wife 
19 and my daughter, and stayed, as far as we remember, 
20 for one night and left the next day. 
21 
Q. 
How did you get to Guadalupe? 
22 
A. 
Jeffrey Epstein flew us from Charleston, 
23 South Carolina, where we were visiting Caroline, my 
24 wife's mother, on an airplane that had a bathroom 
25 that had only a little curtain. That's all I 
EFTA01137836

Page 505 
1 
remember about it. 
2 
Q. 
What was the date of that trip that you're 
3 describing that you took Jeffrey Epstein's island? 
4 
MR. SCOTT: If you know. 
5 
A. 
It was six months or eight months before 
6 she ever met Jeffrey Epstein, so it would be 
7 Christmas, around Christmastime, around Christmas 
8 vacation of the year 1998, to my recollection. But 
9 I would have to check. 
10 
When it is she met Jeffrey Epstein in that 
11 summer, it was the winter before that. That's the 
12 only time I've ever been on the island, so her 
13 statement that she had sex with me on the island is 
14 totally, categorically made up. 
15 
BY MR. EDWARDS: 
16 
Q. 
My question is, where is the flight log of 
17 that trip that you just described? 
18 
A. 
Neither flight -- neither flight was on 
19 Jeffrey Epstein's airplane. The flight that we went 
20 from Charleston to Guadalupe, somebody owed Jeffrey 
21 Epstein several hours on an airplane, so Jeffrey 
22 borrowed his Learjet, it was a Learjet, borrowed his 
23 Learjet, two or three hours on the Learjet because 
24 it would have taken us ten hours to fly from 
25 Charleston to Atlanta, Atlanta to Puerto Rico and 
EFTA01137837

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1 
Miami, and Miami or Puerto Rico to Guadalupe. 
2 
So Jeffrey offered to use the credit he 
3 had with someone else on a Learjet to fly us to 
4 Guadalupe, and then used -- then rented -- it was 
5 $1,200, I remember seeing the bill, to fly the small 
6 airplane from Guadalupe. He was anxious for us to 
7 see his newly bought -- relatively newly bought 
8 island, and so we went there with my daughter and we 
9 dug around in the sand and we had dinner with the 
10 various professors and that. Then we left. 
11 
Q. 
So there are no flight manifests --
12 
A. 
I have no idea. 
13 
Q. 
-- for the trip that you just described? 
14 
A. 
I have no idea. There probably are, 
15 probably on the Learjet is probably the manifest. 
16 
Q. 
In fact, in the statements that the flight 
17 manifests will conclusively and demonstratively 
18 exonerate you --
19 
A. 
That's true. 
20 
Q. 
-- where can we get the full flight 
21 manifests so that we can review and make that 
22 determination for ourselves? Do you know? 
23 
A. 
I assume --
24 
MR. INDYKE: Objection. 
25 
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BY MR. EDWARDS: 
2 
Q. 
What we have here --
3 
MR. INDYKE: Attorney-client, work product 
4 
and common interests. 
5 
BY MR. EDWARDS: 
6 
Q. 
What we have here is only the fraction of 
7 flights where Dave Rogers was one of the pilots. 
8 Can you help us get the flight logs from Larry 
9 Visosky, Larry Morrison, any of the flight logs from 
10 the helicopters, et cetera? 
11 
A. 
I would love to. It would all show that I 
12 wasn't on the plane. 
13 
MR. INDYKE: Same objection, same 
14 
instruction. 
15 
A. 
I will do everything in my power --
16 
MR. SCOTT: You can make any request you 
17 
want to through counsel, and we'll take them 
18 
up. 
19 
A. 
But I will do everything in my power to 
20 get you every flight manifest. 
21 
SPECIAL MASTER POZZUOLI: Move forward. 
22 
MR. INDYKE: We do not waive any 
23 
objection. 
24 
MR. SCAROLA: And that request has been 
25 
made. 
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6 
7 
8 
9 
10 
11 
12 
13 
14 
15 underage? 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A. 
Is that a question? 
MR. SCOTT: No. Just Mr. Scarola 
MR. EDWARDS: Just that we made a request 
for production. 
BY MR. EDWARDS: 
Q. 
Was 
lying when she says that she 
was taken to Jeffrey Epstein's home in New York 
while underage? 
A. 
I have no idea. 
MR. INDYKE: Same objection, same 
instruction. 
BY MR. EDWARDS: 
Q. 
Was 
lying when she says she was 
taken to Jeffrey Epstein's ranch in New Mexico while 
MR. INDYKE: Same objection, same 
instruction. 
A. 
I can tell you this. She's lying when she 
said she met me at the ranch. So I cannot believe 
anything she says about the ranch. 
BY MR. EDWARDS: 
Q. 
Was she lying when she says Ghislaine 
Maxwell and Jeffrey Epstein used sex toys on her 
when she was underage? 
MR. INDYKE: Same objection, same 
EFTA01137840

Page 509 
1 
instruction. 
2 
BY MR. EDWARDS: 
3 
Q. 
Was she lying when she says Jeffrey 
4 Epstein and Ghislaine Maxwell made her dress up in 
5 outfits for them? 
6 
MR. INDYKE: Same objection, same 
7 
instruction. 
8 
A. 
Well, I can -- but I do have some material 
9 outside of the record on that. 
10 
BY MR. EDWARDS: 
11 
Q. 
Okay. 
12 
A. 
I know that Sigrid McCawley said that she 
13 said that Leslie Wexner made her dress up --
14 
MS. McCAWLEY: I am going to object to the 
15 
extent that you are trying to reveal 
16 
conversations that were part of a settlement 
17 
discussion which the judge has already sealed 
18 
the record on and there is a pending motion for 
19 
sanctions. And if you're going to start 
20 
revealing that information, we're going 
21 
directly to the Judge Lynch. 
22 
A. 
I am going to start revealing 
23 
SPECIAL MASTER POZZUOLI: No, I'm going to 
24 
stop you --
25 
THE WITNESS: Let me tell you why. 
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1 
Because I didn't get that from Sigrid or from 
2 
David Boise. I got it from Leslie Wexner's 
3 
lawyer in a totally nonprivileged 
4 
communication. 
5 
SPECIAL MASTER POZZUOLI: Let me stop you. 
6 
I don't believe it's responsive to the question 
7 
that's pending, so let's move forward. 
8 
BY MR. EDWARDS: 
9 
Q. 
My question was, was she lying -- was 
10 
lying when she says Jeffrey Epstein 
11 and Ghislaine Maxwell made her dress up in outfits 
12 for them? 
13 
A. 
I can only say that that allegation has 
14 been made regarding Leslie Wexner as well. 
15 
Q. 
It has nothing to do with my question. 
16 
MR. SCAROLA: Move to strike. 
17 
A. 
Leslie Wexner's lawyer regards that as a 
18 full statement and, therefore, I can only assume 
19 that it's a false statement when made about someone 
20 else. I think that's relevant. 
21 
SPECIAL MASTER POZZUOLI: So with respect 
22 
to the --
23 
MR. EDWARDS: I'm moving to strike the 
24 
nonresponsive portion of that answer. 
25 
THE WITNESS: He opened the door. 
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1 
SPECIAL MASTER POZZUOLI: I do believe it 
2 
was nonresponsive in its entirety. Move 
3 
forward. Go ahead. 
4 
BY MR. EDWARDS: 
5 
Q. 
Do you know Jean-Luc Brunel? 
6 
A. 
No. 
7 
Q. 
Have you ever met him? 
8 
MR. INDYKE: Same objection, same 
9 
instruction. 
10 
A. 
I have no memory of ever meeting a man by 
11 that name. 
12 
BY MR. EDWARDS: 
13 
Q. 
Do you know what his role was in Jeffrey 
14 Epstein's life? 
15 
A. 
No. 
16 
MR. INDYKE: Same objection, same 
17 
instruction. Mr. Dershowitz, if you would let 
18 
me make my objections before you respond. 
19 
THE WITNESS: Right. 
20 
BY MR. EDWARDS: 
21 
Q. 
Was 
lying when she said 
22 Jeffrey Epstein socialized with Bill Clinton during 
23 the relevant time period? 
24 
MR. INDYKE: Same objection, same 
25 
instructions. 
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1 
A. 
My information is that 
2 was lying when she said that she saw Bill Clinton on 
3 Jeffrey Epstein's island. That's all I can comment 
4 about with that. And she's lying about that. And 
5 she's lying about how Bill Clinton got to the 
6 island. 
7 
MR. EDWARDS: I move to strike the 
8 
Nonresponsive portion of the answer. 
9 
SPECIAL MASTER POZZUOLI: No, it's 
10 
relevant to what you asked. Move forward. I'm 
11 
not going to strike it. 
12 
BY MR. EDWARDS: 
13 
Q. 
I'm going to go back to the question until 
14 I get an answer, though. 
15 
SPECIAL MASTER POZZUOLI: Go ahead. 
16 
BY MR. EDWARDS: 
17 
Q. 
That is, when 
said that 
18 during the relevant time period, which we defined as 
19 1999 through 2002 --
20 
A. 
Let's be clear. Around August of both of 
21 those years, right? 
22 
Q. 
I think August of '99 through October of 
23 2002. 
24 
A. 
September, I think it is. 
25 
Q. 
Okay. Was she lying -- was 
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1 
lying when she said Jeffrey Epstein 
2 socialized with Bill Clinton during that time 
3 period? 
4 
A. 
I don't know. 
5 
MR. INDYKE: Same objection, same 
6 
instruction. 
7 
BY MR. EDWARDS: 
8 
Q. 
And you have no nonprivileged information 
9 that would provide you the answer to that? 
10 
A. 
I have nonprivileged information that 
11 provides me that they socialized together at some 
12 point. I don't know whether it was within that 
13 timeframe at all. I know they went to Africa 
14 together on a mission of goodwill, but I don't know 
15 the date of that. So I can't tell you whether it 
16 was in the period or outside the period. You may 
17 know that; I don't. 
18 
Q. 
Well, if Jeffrey Epstein and Bill Clinton 
19 associated, but only at some time period either 
20 before or after the relevant time period, it would 
21 immediately disprove her statement that Bill Clinton 
22 and Jeffrey Epstein socialized during that time 
23 period? 
24 
A. 
I don't understand that question. 
25 
Q. 
No? 
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1 
SPECIAL MASTER POZZUOLI: I don't 
2 
understand the question either. If you can 
3 
rephrase the question, that would be helpful. 
4 
MR. EDWARDS: Sure. 
5 
BY MR. EDWARDS: 
6 
Q. 
If you -- do you know from nonprivileged 
7 information whether Jeffrey Epstein and Bill Clinton 
8 ever socialized? 
9 
A. 
Yes. 
10 
Q. 
Do you know the beginning -- when their 
11 relationship began? 
12 
MR. INDYKE: Objection. Same objection, 
13 
same instruction. 
14 
SPECIAL MASTER POZZUOLI: Again, under 
15 
nonprivileged. 
16 
MR. EDWARDS: Under nonprivileged 
17 
information. 
18 
MR. SCOTT: Do you have any nonprivileged 
19 
information about that? 
20 
A. 
I remember having dinner at the home of 
21 Caroline Kennedy and Ed Schlossberg with President 
22 Clinton, and he basically asked me how Jeffrey was 
23 doing, and led me to believe that he had some 
24 relationship with Jeffrey. I don't remember whether 
25 that dinner -- when that dinner was. I can probably 
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1 
find out. But that would be nonprivileged. 
2 
BY MR. EDWARDS: 
3 
Q. 
Was he still President at the time that 
4 conversation was taking place? 
5 
A. 
I don't remember. 
6 
Q. 
Have you ever been, yourself, together 
7 with Jeffrey Epstein and Bill Clinton? 
8 
A 
No 
9 
Q. 
Have you ever talked to Jeffrey Epstein 
10 about Bill Clinton? 
11 
MR. INDYKE: Objection. Same objection, 
12 
same instruction. 
13 
SPECIAL MASTER POZZUOLI: Nonprivileged. 
14 
MR. EDWARDS: Yeah, nonprivileged. 
15 
A. 
It's hard to sort out the privileged and 
16 the nonprivileged. 
17 
SPECIAL MASTER POZZUOLI: So based upon 
18 
the objection, I would ask that you -- unless 
19 
it's obvious, then no, until we sort that out. 
20 
A. 
I shouldn't answer that probably. 
21 
SPECIAL MASTER POZZUOLI: I'm going to 
22 
grant his objection at this point, again, as a 
23 
continuum because I want to make sure that we 
24 
preserve this issue for later on. 
25 
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1 
BY MR. EDWARDS: 
2 
Q. 
In a previous -- previously in this 
3 deposition, you indicated your representation of 
4 Jeffrey Epstein on this subject matter began in 
5 2005, right? 
6 
A. 
It began, I think I said, when the first 
7 allegations were. I don't have an exact date in 
8 mind. 
9 
Q. 
The relevant time period for 
10 
as we've defined, is 1999 through 2002. 
11 
A. 
That's correct, yes. 
12 
Q 
So I'm asking if you know from Jeffrey 
13 Epstein, in a time period prior to your 
14 representation, whether he was socializing with Bill 
15 Clinton. 
16 
MR. INDYKE: Same objection, same 
17 
instruction. 
18 
A. 
Yes, yes. 
19 
MR. SCOTT: As long as it's a 
20 
nonprivileged situation. 
21 
A. 
He was. 
22 
BY MR. EDWARDS: 
23 
Q. 
He was? 
24 
A. 
He was. 
25 
Q. 
So prior 
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1 
A. 
During the whole period of time up through 
2 2005, you're saying? Yes. 
3 
Q. 
Right. 
4 
A. 
Yes, I think this dinner occurred before 
5 2005, so I would -- yes. 
6 
Q. 
So what did Jeffrey Epstein tell you about 
7 his relationship with Bill Clinton? 
8 
MR. INDYKE: Same objection, same 
9 
instruction. 
10 
BY MR. EDWARDS: 
11 
Q. 
Prior to 2005, obviously. 
12 
A. 
That they knew each other and that they 
13 were doing some charitable work together. 
14 
Q. 
Had Bill Clinton ever been to Jeffrey 
15 Epstein's home? 
16 
A. 
I'm not aware. 
17 
MR. INDYKE: Same objection, same 
18 
instruction. 
19 
BY MR. EDWARDS: 
20 
Q. 
What kind of charitable work was Jeffrey 
21 Epstein --
22 
A. 
I can tell you Donald Trump has been to 
23 Jeffrey Epstein's home, and I've seen him there. 
24 
Q. 
Okay. What question do you think that 
25 you're answering? 
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1 
A. 
Well, you're asking about general things 
2 people --
3 
SPECIAL MASTER POZZUOLI: Let's move 
4 
forward. 
5 
A. 
-- so I mean, I gave you an example of one 
6 who has been there. 
7 
BY MR. EDWARDS: 
8 
Q. 
Okay. I'm specifically talking about 
9 when -- we started with was Virginia lying when she 
10 said that Jeffrey Epstein socialized with Bill 
11 Clinton during the relevant time period. And now 
12 I'm drilling it. 
13 
A. 
I don't know the answer to that. 
14 
Q. 
Okay. Did you understand -- did Bill 
15 Clinton travel with Jeffrey Epstein? 
16 
A. 
My understanding from newspaper --
17 
MR. INDYKE: Same objection, same 
18 
instruction. 
19 
A. 
My understanding from newspaper accounts 
20 is that they went to Africa together with some other 
21 famous people, and I think maybe went to Asia 
22 together as well. So the answer is yes, I am aware 
23 through nonprivileged sources that they traveled 
24 together, yes. 
25 
MR. SCOTT: Can we take a break in a few 
EFTA01137850

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8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
Page 519 
1 
minutes? I would like -- in the afternoon, he 
2 
gets a little tired, so I would like to, every 
3 
hour or so, take -- an hour and ten minutes, 
4 
take a couple-minute break. 
5 
SPECIAL MASTER POZZUOLI: You tell me when 
6 
is a good --
MR. EDWARDS: Maybe 15 minutes and we'll 
switch topics, and we can take a break. Good, 
Tom? 
MR. SCOTT: Yes. 
MR. EDWARDS: Okay. 
BY MR. EDWARDS: 
Q. 
Was 
lying when she says 
she was introduced to Prince Andrew through Jeffrey 
Epstein? 
and 
MR. INDYKE: Same objection, same 
instruction. 
SPECIAL MASTER POZZUOLI: Under 
non-privileged information. 
A. 
I have seen a photograph of Prince Andrew 
and Ghislaine Maxwell. I have 
22 myself met Prince Andrew. He came to my class at 
23 Harvard Law School and there was a dinner for him, 
24 and he asked about Jeffrey Epstein. We discussed 
25 Jeffrey Epstein. 
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1 
BY MR. EDWARDS: 
2 
Q. 
I don't know if this was -- I believe it 
3 was attached to the deposition last time. 
4 
A. 
That's the photograph. 
5 
MR. SCOTT: I think it was. 
6 
MR. SCAROLA: It was. 
7 
MR. EDWARDS: I think it was, too. 
8 
MR. SCOTT: It was. 
9 
BY MR. EDWARDS: 
10 
Q. 
So you're familiar with this photograph? 
11 
A. 
Yes, and I'm also familiar there's no 
12 comparable photograph with me in it. 
13 
Q. 
Okay. 
14 
MR. SCAROLA: That's not responsive. 
15 
SPECIAL MASTER POZZUOLI: Move forward. 
16 
MR. SCAROLA: Move to strike. 
17 
BY MR. EDWARDS: 
18 
Q. 
And in this photograph, this is Prince 
19 Andrew over here on the left? 
20 
A. 
That's true, yeah. 
21 
Q. 
And this is 
in the 
22 middle? 
23 
A. 
I've never seen -- I've never met 
24 Ms. Roberts, never seen her. 
25 
Q. 
So are you saying that she is lying when 
EFTA01137852

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1 
she says that's her? 
2 
A. 
No, I just don't -- I've never seen her. 
3 
MR. SCOTT: Objection, argumentative. 
4 
A. 
Those are photographs -- I've seen 
5 photographs --
6 
SPECIAL MASTER POZZUOLI: Hang on one 
7 
second. Reask 
rephrase the question. 
8 
BY MR. EDWARDS: 
9 
Q. 
And who is this over here on the --
10 
SPECIAL MASTER POZZUOLI: No, rephrase the 
11 
question, the previous question about who the 
12 
young lady is next to Prince Andrew. 
13 
BY MR. EDWARDS: 
14 
Q. 
Sure. Do you know who this lady is in the 
15 middle of this photograph? 
16 
A. 
On the basis of newspaper accounts, it is 
17 reported that she is 
I wouldn't 
18 be able -- if you had shown me that picture a year 
19 and 16 days ago, I would not have been able to tell 
20 you that that's 
because I didn't 
21 know who she was. 
22 
Q. 
And who is the other person that's in this 
23 photograph? 
24 
A. 
Ghislaine Maxwell. 
25 
Q. 
And that's somebody else that you know, 
EFTA01137853