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1 
media, only Dershowitz speaks to the media, lying by 
2 
omission and by commission, failing to state that he 
3 
was trying to get publicity through ABC, that he was 
4 
pleading with ABC and he was trying to sell her 
5 
story to tabloids. So he was lying by omission, 
6 
lying by commission, and so were you. 
7 
Q. 
Have you produced -- do you have a list 
8 
from BBC or -- reporter or anyone else that 
9 
indicates a list of questions or whatever it is 
10 
you're testifying to --
11 
A. 
Yes. 
12 
Q. 
-- that came from somebody other than Paul 
13 
Cassell? 
14 
A. 
I don't understand that question. 
15 
Q. 
Well, you just threw in "and so were you," 
16 
and we're only talking about a list of questions 
17 
that you know about from the BBC. 
18 
MR. SCOTT: I'm not sure -- can you 
19 
rephrase the question so we have it clear? 
20 
MR. EDWARDS: Sure. 
21 
BY MR. EDWARDS: 
22 
Q. 
I asked for you to identify anyone else 
23 
that provided you information about Paul Cassell 
24 
that helped to form your opinions. Your answer was, 
25 
a BBC reporter. Do you know her name? 
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9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
1 
A. 
You must, because you know it's a her. 
2 
Q. 
I'm asking 
3 
A. 
I provided it and we have 
4 
the record. 
5 
Q. 
As you sit here today, do you 
6 
name? 
7 
A. 
No, I don't know the names of 
8 
Q. 
Okay. And the thing 
reporter whose name you do not 
A. 
But I can get it for 
Q. 
that 
know 
you. 
you, do you know her name? 
-- it's part of 
know her 
reporters. 
that BBC 
right now --
I'm just describing the reporter since you 
don't know her 
not 
name. The reporter whose name you 
recall right now provided you an e-mail 
A. 
Q. 
A. 
BY MR. 
Q. 
correct me 
showed you 
that were 
to you. 
A. 
No. 
Showed you an e-mail? 
No. 
MR. SCOTT: Let him ask the question. 
SPECIAL MASTER POZZUOLI: Let him 
EDWARDS: 
I understood your testimony, 
if I'm wrong, that this BBC 
an e-mail of questions from 
requested by Paul Cassell to 
do 
finish. 
and please 
reporter 
Paul Cassell 
be directed 
Yes. But it was not done by the reporter. 
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1 
It was done by the producer. It was a man producer. 
2 
And he told me and showed me on his BlackBerry or 
3 
his iPhone the questions that Paul Cassell had asked 
4 
him to ask me. 
5 
Q. 
In addition to the questions that Paul 
6 
Cassell had asked him to ask you, is it your 
7 
testimony that Paul Cassell spoke to the media about 
8 
the allegations or the facts as Paul understood them 
9 
in the case? 
10 
A. 
Yes, I don't about spoke, but we know that 
11 
he -- yes, we know he spoke to ABC. I think I can 
12 
give you the names of the people he spoke to there. 
13 
Jim Hill. 
14 
MR. SCAROLA: Pardon me. I think there's 
15 
a feedback problem again. 
16 
MR. SIMPSON: On the phone, there seems to 
17 
be a feedback problem. 
18 
MR. SCAROLA: Cross talk. 
19 
MR. INDYKE: Do you know if it's coming 
20 
from Darren Indyke or another phone? 
21 
SPECIAL MASTER POZZUOLI: There's no way 
22 
to know. 
23 
MR. SIMPSON: It's not there now. 
24 
BY MR. EDWARDS: 
25 
Q. 
I want to limit this so that I can 
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1 
understand exactly what you're saying to this BBC 
2 
reporter that you have identified that provided you 
3 
information that helped to support your opinions 
4 
about Paul Cassell. 
5 
A. 
That's right. 
6 
Q. 
Okay. That person provided you an e-mail 
7 
or you saw through this person an e-mail that Paul 
8 
Cassell -- that evidenced questions that Paul 
9 
Cassell wanted you to be asked? 
10 
A. 
It was my recollection it was an e-mail 
11 
from Paul Cassell to the producer is my 
12 
recollection. 
13 
Q. 
Okay. In addition -- so my question 
14 
that's pending is, in addition to the questions, is 
15 
there anything in the body of that e-mail or that 
16 
you were told by this reporter that Paul Cassell 
17 
spoke or communicated with the BBC beyond the 
18 
content of those questions? 
19 
A. 
Yes, the reporter told me that Paul 
20 
Cassell had spoken to him, and my recollection is 
21 
that they had spoken and then he sent him a 
22 
follow-up e-mail is my recollection. Again, it's a 
23 
year ago. And this was at the time that Paul 
24 
Cassell was saying and you were saying through your 
25 
lawyers and certainly trying to convey the 
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1 
impression that you were trying to keep this case 
2 
out of the media and that it was I who was putting 
3 
it into the media, while it turns out that 
4 
secretly --
5 
MR. EDWARDS: Object. Move to strike as 
6 
nonresponsive. 
7 
SPECIAL MASTER POZZUOLI: Are you almost 
8 
finished? 
9 
A. 
Almost done. 
10 
Secretly you were communicating with the 
11 
media and trying very hard to get them to cover this 
12 
story in a way negative to me. 
13 
BY MR. EDWARDS: 
14 
Q. 
Was this a reporter or a producer that was 
15 
telling you this information? 
16 
A. 
Producer. 
17 
Q. 
And what is the name of that producer, if 
18 
you know? 
19 
A. 
We can find that out. But I'm sure you 
20 
have the e-mail. I'm sure Cassell has the e-mail. 
21 
SPECIAL MASTER POZZUOLI: Do you know? 
22 
A. 
I don't know the name of the producer. 
23 
BY MR. EDWARDS: 
24 
Q. 
And what was it that this producer told 
25 
you that Paul told him? 
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1 
A. 
To please ask me very critical and hard 
2 
questions. And I assumed -- this is an 
3 
assumption -- that the reason the BBC may have 
4 
called me was they were put on to it by Paul 
5 
Cassell, who urged them to call me. 
6 
Q. 
My question, if we back up a few, though, 
7 
is beyond the substance of the questions from Paul 
8 
Cassell, do you have information that Paul Cassell 
9 
spoke to them? 
10 
A. 
Yes. 
11 
Q. 
Okay. And I think, as you said, yes, 
12 
because I talked to this reporter. What did the 
13 
reporter tell you that Paul Cassell said beyond the 
14 
substance of those questions? 
15 
A. 
It's the producer. 
16 
Q. 
Producer. 
17 
A. 
Not the reporter. The reporter was part 
18 
of the conversation, too, but I think the 
19 
conversations had been between Paul Cassell and the 
20 
producer. 
21 
The conclusion I drew from our 
22 
conversation was that Paul Cassell had reached out 
23 
to BBC and asked to have them ask me hard questions, 
24 
and the questions were all very critical and hard 
25 
questions designed to make her story believable. 
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1 
And that the producer then responded to 
2 
Cassell and said send me an e-mail, and Cassell sent 
3 
an e-mail with the questions listed. And they, in 
4 
fact, asked me those questions. 
5 
Q. 
Okay. 
6 
A. 
But the point of my answer is that at the 
7 
same time, you, Mr. Scarola, and Mr. Cassell were 
8 
communicating to the press --
9 
MR. EDWARDS: Object and move to strike as 
10 
nonresponsive. 
11 
SPECIAL MASTER POZZUOLI: I would agree 
12 
with that and grant the motion. Go ahead and 
13 
ask your next question. 
14 
BY MR. EDWARDS: 
15 
Q. 
Beyond the communication from Paul Cassell 
16 
to a producer, ask Alan Dershowitz these questions, 
17 
is it your understanding that Paul Cassell 
18 
communicated anything further to that producer? 
19 
A. 
Yes. 
20 
Q. 
Okay. What did the producer tell you that 
21 
Paul Cassell said to him beyond "ask Alan Dershowitz 
22 
these questions"? 
23 
A. 
Well, the producer certainly came to the 
24 
interview having been, it seemed to me, briefed by 
25 
Cassell and came with a conclusion that he had 
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1 
2 
3 
4 
5 
6 
reached that I was guilty. So I can draw a 
reasonable inference that he was told that by Paul 
Cassell. 
Q. 
Did the producer tell you that he was told 
anything beyond "ask Alan Dershowitz these 
questions"? 
7 
A. 
The producer told me that he had other 
8 
communications with Cassell. But beyond that, I had 
9 
to draw my own inferences. 
10 
Q. 
Without you drawing your own inferences, 
11 
did the producer tell you the substance of those 
12 
other communications with Paul Cassell beyond "ask 
13 
Alan Dershowitz these questions"? 
14 
A. 
No. 
15 
SPECIAL MASTER POZZUOLI: We're beginning 
16 
to approach a break, so as your deposition --
17 
find a time in the next 10 or 15 minutes or so. 
18 
MR. EDWARDS: I think this is as good a 
19 
time as any. 
20 
THE WITNESS: I'm happy to go on. 
21 
MR. SIMPSON: Take a break. 
22 
MR. SCOTT: Take a break. 
23 
SPECIAL MASTER POZZUOLI: I don't want to 
24 
interrupt a flow. 
25 
MR. EDWARDS: This is good stopping point, 
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1 
and then we'll take a break and be back. 
2 
VIDEOGRAPHER: We're going off the record. 
3 
The time is 11:52 a.m. 
4 
SPECIAL MASTER POZZUOLI: You can go off 
5 
the record but stay on the record. 
6 
With respect to the issues over privilege, 
7 
and as it appears that this witness may be held 
8 
over beyond today, I would ask the parties to 
9 
discuss and see if you can agree among 
10 
yourselves how you wish, if you wish, to 
11 
address those issues so that whether it's in 
12 
front of me or in front of Judge Lynch, so that 
13 
in several weeks or whenever he's reset, should 
14 
there need to be a readdressing of questions 
15 
that were not answered because of that issue, 
16 
just as I'm not foretelling -- don't take 
17 
anything in it, but just for purposes of 
18 
scheduling, we probably ought to try to deal 
19 
with -- I would suggest that the parties try to 
20 
deal with that issue between now and the next 
21 
time Mr. Dershowitz sits for deposition. 
22 
MR. SCAROLA: That absolutely makes sense. 
23 
And we will be filing, after we have received 
24 
the transcript, an appropriate Motion to 
25 
Compel, and I think that it is best that the 
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1 
Court deal with that motion. 
2 
SPECIAL MASTER POZZUOLI: I'm --
3 
MR. SCAROLA: I think it's beyond the 
4 
scope of the responsibilities that have been 
5 
agreed to be resolved by you, and that would be 
6 
our request. 
7 
SPECIAL MASTER POZZUOLI: Okay. I wanted 
8 
to raise that just from the purposes of just an 
9 
administrative standpoint. 
10 
MR. SCAROLA: Yes. Thank you very much. 
11 
(Recess was held from 11:54 a.m. until 1:04 p.m. 
12 
after which the proceedings continued in Volume 6.) 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
EFTA01138155

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CERTIFICATE OF OATH 
STATE OF FLORIDA 
COUNTY OF BROWARD 
I, the undersigned authority, certify 
that ALAN M. DERSHOWITZ personally appeared 
before me and was duly sworn on the 13th day of 
January, 2016. 
Signed this 17th day of January, 2016. 
KIMBERLY FONTALVO, RPR, CLR 
Notary Public, State of Florida 
My Commission No. FF 226848 
Expires: 7/12/2019 
EFTA01138156

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CERTIFICATE OF REPORTER 
STATE OF FLORIDA 
COUNTY OF BROWARD 
I, KIMBERLY FONTALVO, Registered 
Professional Reporter, do hereby certify that I 
was authorized to and did stenographically report 
the foregoing videotape continued deposition of 
ALAN M. DERSHOWITZ; pages 648 through 455; that a 
review of the transcript was requested; and that 
the transcript is a true record of my 
stenographic notes. 
I FURTHER CERTIFY that I am not a 
relative, employee, attorney, or counsel of any 
of the parties, nor am I a relative or employee 
of any of the parties' attorneys or counsel 
connected with the action, nor am I financially 
interested in the action. 
Dated this 14th day of January, 2016. 
KIMBERLY FONTALVO, RPR, CLR 
EFTA01138157

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January 14, 2016 
COLE, SCOTT & KISSANE, P.A. 
Dadeland Centre II - Suite 1400 
9150 South Dadeland Boulevard 
Miami, Florida 33156 
BY: THOMAS EMERSON SCOTT, JR., ESQ. 
[email protected] 
Re: Bradley Edwards, et al., v. Alan M. Dershowitz 
Please take notice that on the 12th day of January, 
2016, you gave your deposition in the above cause. 
At that time, you did not waive your signature. 
The above-addressed attorney has ordered a copy of 
this transcript and will make arrangements with you 
to read their copy. Please execute the Errata 
Sheet, which can be found at the back of the 
transcript, and have it returned to us for 
distribution to all parties. 
If you do not read and sign the deposition within a 
reasonable amount of time, the original, which has 
already been forwarded to the ordering attorney, may 
be filed with the Clerk of the Court. 
If you wish to waive your signature now, please sign 
your name in the blank at the bottom of this letter 
and return to the address listed below. 
Very truly yours, 
KIMBERLY FONTALVO, RPR, CLR 
Phipps Reporting, Inc. 
1551 Forum Place 
Building 200, Suite E 
West Palm Beach, Florida 33401 
I do hereby waive my signature. 
ALAN M. DERSHOWITZ 
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ERRATA SHEET 
DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE 
In Re: BRADLEY EDWARDS, ET AL., V. ALAN M. 
DERSHOWITZ 
Case No.: 
ALAN M. DERSHOWITZ 
January 12, 2016 
PAGE 
LINE 
CHANGE 
REASON 
Under penalties of perjury, I declare that I have 
read the foregoing document and that the facts 
stated in it are true. 
Date 
ALAN M. DERSHOWITZ 
EFTA01138159