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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL 
CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA 
CASE NO.: CACE 15-000072 
BRADLEY J. EDWARDS and PAUL G. 
CASSELL, 
Plaintiffs, 
VS. 
ALAN M. DERSHOWITZ, 
Defendant. 
VIDEOTAPE CONTINUED DEPOSITION OF 
ALAN M. DERSHOWITZ 
VOLUME 5 
Pages 648 through 781 
Wednesday, January 13, 2016 
9:04 a.m. - 11:59 a.m. 
Tripp Scott 
110 Southeast 6th Street 
Fort Lauderdale, Florida 
Stenographically Reported By: 
Kimberly Fontalvo, RPR, CLR 
Realtime Systems Administrator 
EFTA01138026

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1 
APPEARANCES: 
2 
On behalf of Plaintiffs: 
3 
SEARCY, DENNEY, SCAROLA 
4 
BARNHART & SHIPLEY, P.A. 
2139 Palm Beach Lakes Boulevard 
5 
West Palm Beach, Florida 33402-3626 
BY: JACK SCAROLA, ESQ. 
6 
7 
8 
On behalf of Defendant: 
9 
COLE, SCOTT & KISSANE, P.A. 
Dadeland Centre II - Suite 1400 
10 
9150 South Dadeland Boulevard 
Miami, Florida 33156 
11 
BY: THOMAS EMERSON SCOTT, JR., ESQ. 
12 
BY: STEVEN SAFRA, ESQ. 
(Via phone) 
13 
--and 
14 
SWEDER & ROSS, LLP 
131 Oliver Street 
15 
Boston, MA 02110 
BY: KENNETH A. SWEDER, ESQ. 
16 
17 
--and--
18 
WILEY, REIN 
17769 K Street NW 
19 
Washington, DC 20006 
BY: RICHARD A. SIMPSON, ESQ. 
20 
21 
22 
23 
24 
25 
EFTA01138027

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1 
APPEARANCES (Continued): 
2 
3 
On behalf of Jeffrey Epstein: 
4 
DARREN K. INDYKE, PLLC 
575 Lexington Ave., 4th Fl. 
5 
New York, New York 
BY: DARREN K. INDYKE, ESQ. (Via phone) 
6 
7 
On behalf of 
8 
BOIES, SCHILLER & FLEXNER, LLP 
401 E. Las Olas Blvd., Ste. 1200 
9 
Fort Lauderdale, Florida 33301 
BY: SIGRID STONE MCCAWLEY, ESQ. 
10 
11 
12 
ALSO PRESENT: 
13 
Edward J. Pozzuoli, Special Master 
14 
Sean D. Reyes, Utah Attorney General Office 
15 
Marcy Martinez, Videographer 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
EFTA01138028

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1 
INDEX 
2 
3 
Examination 
Page 
4 
5 
VOLUME 5 (Pages 648 - 781) 
6 
7 
Certificate of Oath 
778 
Certificate of Reporter 
779 
8 
Read and Sign Letter to Witness 
780 
Errata Sheet (forwarded upon execution) 
781 
9 
10 
PLAINTIFF EXHIBITS 
11 
12 
No. 
Page 
13 
25 Transcript from Don Lemon Interview 
689 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
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1 
Thereupon, the proceedings continued at 9:04 a.m. 
2 
VIDEOGRAPHER: Are now on the video 
3 
record. This is the 13th day of January, 2016. 
4 
The time is 9:04 a.m. This is the videotaped 
5 
deposition of Alan Dershowitz in the matter of 
6 
Bradley Edwards and Paul Cassell versus Alan 
7 
Dershowitz. 
8 
My name is Marcy Martinez. I am the 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
colleague Meredith Schultz from Boies, Schiller 
21 
& Flexner. 
22 
MR. INDYKE: On behalf of Jeffrey Epstein, 
23 
Darren Indyke. 
24 
SPECIAL MASTER POZZUOLI: Ed Pozzuoli as 
25 
the special master. 
videographer representing Above & Beyond 
Reprographics. Will the attorneys please 
announce their appearances for the record. 
MR. EDWARDS: Sure. On behalf of the 
plaintiff today Brad Edwards, Jack Scarola, 
Brittany Henderson and Paul Cassell. 
MR. SIMPSON: On behalf of the defendant 
and the witness, Richard Simpson, and Thomas 
Scott will be joining. He just walked in. 
MS. McCAWLEY: On behalf of nonparty 
, Sigrid McCawley and my 
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1 
MR. SIMPSON: Is there anyone else on the 
2 
phone? 
3 
MR. MAISEL: Yeah, this is Nicholas 
4 
Maisel. 
5 
THE COURT REPORTER: Would you raise your 
6 
right hand, please? 
7 
Do you swear or affirm that the testimony 
8 
you are about to give will be the truth, the 
9 
whole truth, and nothing but the truth? 
10 
THE WITNESS: I do. 
11 
MR. SCAROLA: Nick, would you announce the 
12 
capacity in which you're appearing, please. 
13 
MR. MAISEL: Special research assistant 
14 
for Alan Dershowitz. 
15 
MR. SCAROLA: Thank you. 
16 
MR. EDWARDS: Are we ready? 
17 
SPECIAL MASTER POZZUOLI: Go ahead. 
18 
19 
20 
21 
22 
23 
24 
25 
BY MR. EDWARDS: 
Q. 
Mr. Dershowitz, in January of 2015, when 
you made the statements that Paul Cassell and Brad 
Edwards participated in the fabricating of the 
allegations that were made against you, what 
information or evidence did you have in your 
possession at that time to support those statements? 
MR. SIMPSON: Object to the form as overly 
EFTA01138031

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1 
general. You may answer. 
2 
A. 
As soon as the allegations were made 
3 
against me, I received a series of phone calls and 
4 
people approached me at various events and they 
5 
warned me about the reputation of Bradley Edwards. 
6 
They told me that he had, in their view, 
7 
participated in a major fraud with a man named 
8 
Rothstein, that he should be in jail for the 
9 
Rothstein events. 
10 
I received a phone call saying that he had 
11 
fabricated evidence when he was a prosecutor and 
12 
that he had knowingly failed to investigate police 
13 
fabrication of evidence in a case. Generally was 
14 
warned about the terrible reputation that 
15 
Mr. Edwards had. 
16 
I also received phone calls telling me 
17 
that Mr. Cassell was a zealot, that he had used me 
18 
in class as a whipping -- as a kind of an object of 
19 
hate and painted me as a liberal supporter of the 
20 
exclusionary rule and opponent of the death penalty, 
21 
and that he had no concern for the truth when it 
22 
came to his zealotry on behalf of alleged victims. 
23 
The calls were just -- the people who told 
24 
me this were just -- there were so many of them that 
25 
it was amazing to me. 
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1 
And I knew, of course, that I had never 
2 
met -- had no contact with 
I knew 
3 
that she was lying. I read her deposition, and as 
4 
an experienced lawyer with 50 years of experience, 
5 
it was absolutely clear to me that no lay person 
6 
with her lack of education could have written that 
7 
deposition. 
a 
I sought the advice of friends and others 
9 
10 
11 
12 
13 
14 
15 
16 
this was part of an extortion plot in order to 
17 
obtain money. I later learned many, many, many 
18 
facts. 
19 
MR. EDWARDS: I object and move to strike 
20 
as nonresponsive and that the question calls 
21 
22 
2015. I would ask for a ruling on that. 
23 
A. 
I'm providing that, but I'm giving the 
24 
context. 
25 
SPECIAL MASTER POZZUOLI: Denied. Move 
with experience who confirmed the view that that 
affidavit clearly had to have been written by 
lawyers and certainly drafted by lawyers; the level 
of detail, the structure of the sentences, all of 
which led me conclusively to the belief that the 
lawyers had written this affidavit. 
I suspected from the very beginning that 
for information in his possession in January of 
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1 
2 
3 
4 
5 
6 
7 
a 
9 
in this case and that they pretended to be pro bono 
10 
lawyers when they were, in fact, money-grubbing, 
11 
money-hungry lawyers who had earned a very 
12 
substantial amount of money already on these cases 
13 
and were expecting to earn more money. 
14 
Let me think of what other information I 
15 
had. 
16 
SPECIAL MASTER POZZUOLI: At the time of 
17 
the question. 
18 
A. 
At the time of my statements, right. 
19 
20 
21 
22 
23 
24 
25 
forward. 
A. 
Okay. I knew that there was a financial 
motivation here. I also knew that Cassell and 
Edwards had lied when they said they were 
representing 
in a pro bono basis. 
I had been informed repeatedly that they 
were in it for the money and that they expected to 
earn a lot of money from representing her and others 
It's just inconceivable to me that this 
uneducated woman could have come up with this story 
on her own. 
I understood the motives of the lawyers, 
and I was convinced, therefore, it was my opinion 
based on my experience, in fact, that she could not 
have done this by herself and that she had to have 
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1 
worked in coordination with her lawyers. 
2 
Her lawyers were also at that point 
3 
claiming that the story should be believed because 
4 
of who they were. Mr. Cassell, in my view, 
5 
unethically signed his pleading with the University 
6 
of Utah imprimatur, suggesting that he was a State 
7 
actor, suggesting that he acted on behalf of his 
8 
university, something I would never do and I've 
9 
stopped clients from doing. When I represent 
10 
people, I represent them on my own behalf, not on 
11 
behalf of any university. 
12 
The very fact that the Attorney General of 
13 
Utah was here yesterday indicates that he may very 
14 
well be a State actor and subject to the rules of 
15 
State action rather than individual action. 
16 
SPECIAL MASTER POZZUOLI: That portion I 
17 
will strike. That sentence. 
18 
A. 
Sorry. 
19 
BY MR. EDWARDS: 
20 
Q. 
Okay. 
21 
A. 
I'm not finished. 
22 
SPECIAL MASTER POZZUOLI: Is there any 
23 
other information that you haven't touched 
24 
on --
25 
THE WITNESS: I'm trying to --
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1 
SPECIAL MASTER POZZUOLI: -- as of, what, 
2 
January? 
3 
MR. EDWARDS: January of 2015. 
4 
THE WITNESS: Oh, yes. 
5 
MR. SCAROLA: January 4. 
6 
MR. EDWARDS: January 4, 2015. 
7 
A. 
Okay, that's the question. But, of 
8 
course, I made a series of statements that continued 
9 
beyond January 4, and they always took into account 
10 
11 
12 
13 
14 
15 
16 
important to this. I did not make a single call to 
17 
a single newspaper or single television station, to 
18 
my knowledge, or a single newspaper. I was 
19 
constantly responding. 
20 
MR. SCAROLA: That's not responsive. 
21 
A. 
Excuse me. In the last deposition --
22 
SPECIAL MASTER POZZUOLI: No, no. 
23 
A. 
-- there was an interruption by 
24 
Mr. Scarola that I want to put on the record. 
25 
SPECIAL MASTER POZZUOLI: No, no, no, no, 
new developments and new information that I had. 
I was also aware that Mr. Cassell was 
promoting himself as a former federal judge and 
using his status and imprimatur in a false effort to 
try to add credibility to the story. 
And I did not make -- this is very 
EFTA01138036

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1 
no, no, no. No. Respond to the question that 
2 
was answered and go ahead because I haven't 
3 
heard any objection yet. 
4 
MR. EDWARDS: I'm objecting to all of this 
5 
as being nonresponsive to the question. 
6 
SPECIAL MASTER POZZUOLI: Is there 
7 
anything else that you would like to add to the 
8 
answer? 
9 
THE WITNESS: Yes. 
10 
A. 
When the newspapers called me, they all 
11 
asked me the following question --
12 
SPECIAL MASTER POZZUOLI: Was this in 
13 
January? 
14 
A. 
This was in January. 
15 
BY MR. EDWARDS: 
16 
Q. 
The question on the table is --
17 
SPECIAL MASTER POZZUOLI: Hang on one 
18 
second. 
19 
A. 
I'm going to tell you. 
20 
MR. EDWARDS: What information that 
21 
Mr. Dershowitz had in January 4, 2015, when he 
22 
made the statement that Paul Cassell and Brad 
23 
Edwards fabricated the allegations against him. 
24 
MR. SIMPSON: The question was about in 
25 
January of 2015. 
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1 
SPECIAL MASTER POZZUOLI: That's what it 
2 
was. That was the original question, which is 
3 
why he was afforded a tremendous amount of 
4 
latitude. 
5 
MR. EDWARDS: Understood. 
6 
A. 
And I got continuing information all 
7 
through January and amended my statements as 
8 
consistent with the information that I got. 
9 
The newspapers called me. They all said 
10 
to me, why would anybody make a false allegation if 
11 
he's a former Federal judge, if he's a professor, if 
12 
he's a distinguished trial lawyer? 
13 
Clearly the -- on the 4th of December, 
14 
talking about that day, that's the day on which 
15 
Mr. Cassell wrote to ABC 
16 
BY MR. EDWARDS: 
17 
Q. 
January. 
18 
A. 
January 4, 2015, that's the date on which 
19 
Mr. Cassell wrote to ABC News asking them to 
20 
publicize his client's story and to -- and again 
21 
making it clear to ABC who he was and what he -- and 
22 
who he had been and what offices he had held. 
23 
And so it was clear to me at that point, 
24 
and through January it became clearer and clearer 
25 
that she could not have done this on her own, that 
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1 
she had to have sat with her lawyers and concocted 
2 
this story, added the kind of detail to the story 
3 
that would make a lie seem plausible and credible. 
4 
And I think that any reasonable lawyer reading that 
5 
affidavit would have come to exactly the same 
6 
conclusion that I came to. 
7 
SPECIAL MASTER POZZUOLI: Okay. 
8 
BY MR. EDWARDS: 
9 
Q. 
Mr. Dershowitz, when you first made the 
10 
statement on January 4, 2015 that Mr. Cassell and 
11 
Brad Edwards had participated in the fabrication of 
12 
these allegations, did you have before you any 
13 
affidavit or, as you have repeatedly called it, 
14 
deposition of 
15 
MR. SIMPSON: Object to the form. It's 
16 
referring to a specific statement that has not 
17 
been identified for the witness. 
18 
A. 
Affidavit of 
What I had 
19 
was the lawyers' statements that were included in 
20 
the Complaint, which they then sought to publicize 
21 
all around the world and got more than a thousand 
22 
newspapers to cover the story, every television 
23 
station in the world, every radio station virtually 
24 
in the world, based on what they themselves had 
25 
written, actually gives me even a greater basis, 
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1 
because it wasn't at that point based on her 
2 
affidavit, it was based on what the lawyers had 
3 
said. 
4 
MR. EDWARDS: I object. Can I have the 
5 
question read back. I'm lost as to what the 
6 
question is anymore. 
7 
SPECIAL MASTER POZZUOLI: Ask -- reread 
8 
the question. 
9 
COURT REPORTER: "Mr. Dershowitz, when you 
10 
first made the statement on January 4, 2015 
11 
that Mr. Cassell and Brad Edwards had 
12 
participated in the fabrication of these 
13 
allegations, did you have before you any 
14 
affidavit or, as you have repeatedly called it, 
15 
deposition of 
." 
16 
BY MR. EDWARDS: 
17 
Q. 
Did you? 
18 
SPECIAL MASTER POZZUOLI: So that's the 
19 
question. Answer that question only. 
20 
MR. SCAROLA: Move to strike everything 
21 
else he's said. 
22 
A. 
On January 4th, to my memory, I did not 
23 
refer to a deposition or to whatever other word you 
24 
used -- what was the word? 
25 
MR. SIMPSON: Affidavit. 
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1 
MR. EDWARDS: Affidavit. 
2 
A. 
-- if I hadn't seen it at that point. I 
3 
don't remember the exact day when her affidavit came 
4 
in. I referred obviously to the pleadings. That 
5 
was the allegation, the allegation in the pleadings. 
6 
So if I said that you and Cassell sat and 
7 
helped her make it up, it was based on -- at that 
8 
point in time, based on you and her, primarily you 
9 
and Cassell, because she didn't submit -- it wasn't 
10 
an affidavit at that point. 
11 
It was your words, you, that were accusing 
12 
me of these heinous crimes without any basis. So I 
13 
surely had a basis on January 4th of attributing it 
14 
to you because it was your signature on the 
15 
SPECIAL MASTER POZZUOLI: Hold on a 
16 
second. So I understand, the question is what 
17 
did you have on January 4th --
18 
MR. EDWARDS: -- 2015 to support that 
19 
statement. 
20 
SPECIAL MASTER POZZUOLI: Just answer that 
21 
question first and then you can explain, but --
22 
A. 
With due respect, Your Honor, I think the 
23 
question was, did you have the affidavit in front of 
24 
you. 
25 
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1 
BY MR. EDWARDS: 
2 
Q. 
Right. Okay. Did you have the affidavit 
3 
or deposition of 
on that day? 
4 
A. 
To my recollection, I did not. I had only 
5 
your characterization of the accusation which you 
6 
were making against me. 
7 
Q. 
And in your experience as an attorney, 
8 
isn't it common knowledge that attorneys drafting 
9 
complaints or pleadings take the word of the client 
10 
to form the basis of that Complaint or pleading? 
11 
A. 
No, it's not common knowledge. It's 
12 
common knowledge that unethical lawyers of the kind 
13 
that your reputation told me you were help the 
14 
clients 
15 
MR. EDWARDS: I object. Move to strike as 
16 
nonresponsive. 
17 
SPECIAL MASTER POZZUOLI: That, I am going 
18 
to strike. Try -- try to answer the question. 
19 
A. 
But I think the generic answer is ethical 
20 
lawyers -- let me put it this way, ethical lawyers 
21 
should not elaborate on what a client tells them in 
22 
an affidavit. 
23 
In my experience, there's a continuum. 
24 
Many, many lawyers, when they see a statement by a 
25 
client, they'll say, no, no, no, no, could you 
EFTA01138042

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1 
please elaborate on that. You say you had sex with 
2 
him. Was it one time? Was it two times? Could it 
3 
have been six times? Could it have been on the 
4 
airplane? Could it have been -- et cetera. 
5 
So I think it's a continuum of the way 
6 
lawyers work with clients. The most ethical lawyers 
7 
don't change what a client says. They word for word 
8 
repeat what the client says. 
9 
The most unethical lawyers will put all of 
10 
their own thoughts, words, ideas if it strengthens 
11 
their position and strengthens their case. 
12 
From what I had been -- from the 
13 
information I knew at that time, I put you on the 
14 
extreme unethical end of the continuum. 
15 
SPECIAL MASTER POZZUOLI: That wasn't the 
16 
question, so 1 will strike the last sentence. 
17 
We need to get focused on answering the 
18 
question, so please try to do that. 
19 
A. 
Okay, I will do that. 
20 
BY MR. EDWARDS: 
21 
Q. 
When you first made the statements that 
22 
Paul Cassell and Brad Edwards fabricated the 
23 
allegations --
24 
A. 
Would you read me the statement that you 
25 
say I made on January 4th so I can understand what 
EFTA01138043

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1 
you're saying? 
2 
Q. 
Do you deny making the statement that Brad 
3 
Edwards and Paul Cassell fabricated the allegations 
4 
against you? 
5 
A. 
I remember making a series of statements 
6 
over time. I do not remember what I said on 
7 
January 4th. In order to ask me what I had at the 
8 
time I made the statement, I need to know with 
9 
precision the exact statement you are referring to 
10 
and the exact date. I think that's a fair request. 
11 
Q. 
We'll get that for you. It would be 
12 
easier had you made less statements, but we'll sift 
13 
through them. 
14 
A. 
If would be easier if you had called 
15 
MR. SIMPSON: There's no question. Object 
16 
to the sidebar comments. 
17 
SPECIAL MASTER POZZUOLI: Yes, let's --
18 
BY MR. EDWARDS: 
19 
Q. 
What are the names -- please list for me 
20 
all of the names of the people who told you that --
21 
in quotes -- Brad Edwards was -- participated in a 
22 
major fraud with Rothstein. Names of people. 
23 
MR. INDYKE: Objection based upon 
24 
attorney-client, work product, common interest. 
25 
SPECIAL MASTER POZZUOLI: Well, okay. 
EFTA01138044

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1 
MR. INDYKE: Instruct Alan not to answer 
2 
to the extent it would disclose communications 
3 
of who made those --
4 
SPECIAL MASTER POZZUOLI: Objection noted. 
5 
You can answer it. 
6 
A. 
What framework are you giving me in terms 
7 
of time? 
8 
SPECIAL MASTER POZZUOLI: In January. 
9 
BY MR. EDWARDS: 
10 
Q. 
You told me that before you made these 
11 
statements, one of the things that you had in your 
12 
possession was a series of phone calls, "a bunch of 
13 
people called me" --
14 
A. 
That is right. That's true. 
15 
Q. 
-- "and told me Brad Edwards participated 
16 
in major fraud with Rothstein." That's the first 
17 
18 
19 
20 
21 
22 
23 
BY MR. EDWARDS: 
24 
Q. 
What are the names? 
25 
SPECIAL MASTER POZZUOLI: Stop, stop, 
question I want answered. What are the names of 
those people? 
A. 
A number of them who called me were ones 
who volunteered --
MR. SCAROLA: That's not a response to the 
question. 
EFTA01138045