EFTA00601154

41 
1 
Q. 
Ashe? 
10:14:57 
2 
A. 
Thomas Ashe is not a lawyer. He was one 
10:14:58 
3 
of the first people I called on the day I was 
4 
informed of the lies being spread by your clients. 
5 
Because he could help me gather all the information 
6 
necessary to prove that the only time I was ever in 
7 
New Mexico was visiting him and his wife, who is a 
8 
prominent film person, and his daughter, who is a 
9 
sex offender prosecutor in the Brooklyn District 
10 
Attorney's Office who specializes in sex 
11 
trafficking. 
12 
I needed to call them to prove what I knew 
10:15:49 
13 
immediately, that the only time I was ever at 
14 
Jeffrey Epstein's ranch was when I went to visit the 
15 
Ashes in New Mexico. I spoke to their daughter, the 
16 
prosecutor's, class. She was then in high school, 
17 
and took a day trip to Santa Fe. 
18 
Ashe had known -- had heard that Jeffrey 
10:16:15 
19 
Epstein had bought a ranch, a very large ranch in 
20 
New Mexico and Ashe was very interested in the 
21 
outdoors and asked me if I would do him a favor and 
22 
call to see if we could just take a look at what the 
23 
ranch looked like. And I did that. 
24 
And we spent about an hour looking around 
10:16:35 
25 
the house that was under construction. And I needed 
EFTA00601194

42 
1 
Ashe to gather all the evidence for me, including 
2 
journal entries in his daughter's journal, 
3 
photographs, other evidence and proof of our visit 
4 
to the ranch, which your client encouraged 
5 
to include in an affidavit -- perjurious 
6 
affidavit, that she submitted with details, false 
7 
and mendacious details that could not have occurred 
8 
about an alleged sexual encounter between her and me 
9 
at the ranch in New Mexico. 
10 
Q. 
Which of my clients are you swearing under 
10:17:30 
11 
oath encouraged 
to include 
12 
allegations of an encounter with you at the 
13 
New Mexico ranch? 
14 
A. 
Both of them, both of your clients, both 
10:17:49 
15 
Judge Cassell and Mr. Edwards were both involved in 
16 
encouraging your client to file a perjurious 
17 
affidavit that they knew or should have known was 
18 
perjurious and did know was perjurious recently when 
19 
they sought to file another defamatory allegation in 
20 
the federal proceeding. 
21 
Q. 
Was the encouragement such that what you 
10:18:21 
22 
are charging Bradley Edwards and Professor Paul 
23 
Cassell with doing was suborning perjury? 
24 
A. 
Absolutely. 
10:18:34 
25 
MR. SCOTT: Objection, form. 
10:18:35 
EFTA00601195

43 
1 
Go ahead. 
10:18:36 
2 
A. 
Absolutely. If you ask me the question, I 
10:18:37 
3 
am directly charging Judge Cassell and Bradley 
4 
Edwards with suborning perjury. I have been advised 
5 
that 
did not want to mention me, 
6 
told her friends that she did not want to mention 
7 
me. And was, quote, pressured by her lawyers into 
8 
including me and including these totally false 
9 
allegations against me. Yes, your clients are 
10 
guilty of suborning perjury. 
11 
BY MR. SCAROLA: 
10:19:06 
12 
Q. 
Who told you that Bradley Edwards 
10:19:06 
13 
pressured 
into falsely identifying 
14 
you? 
15 
A. 
A friend of 
who called 
10:19:17 
16 
me out of the blue, and told me that she was 
17 
horrified by what was happening to me, and that she 
18 
recently had meetings with 
and 
19 
had told her that she never 
20 
mentioned me previously. That the lawyers pressured 
21 
her into mentioning me. And mentioning me over her 
22 
desire not to mention me, yes. 
23 
Q. 
Do you remember what the question is? 
10:19:55 
24 
A. 
Yes, and I answered it. 
10:19:57 
25 
Q. 
What do you understand the question to be 
10:19:59 
EFTA00601196

44 
1 
that you were answering? 
2 
MR. SCOTT: Object to form. 
10:20:01 
3 
BY MR. SCAROLA: 
10:20:01 
4 
Q. 
Based upon your superb memory, what is it 
10:20:02 
5 
that I asked you? 
6 
A. 
I think you asked me to tell me how I 
10:20:07 
7 
found out who told me that your clients had suborned 
8 
perjury. 
9 
BY MR. SCAROLA: 
10:20:14 
10 
Q. 
No, sir. What I asked you was to give me 
10:20:14 
11 
a name. Who? 
12 
MR. SCOTT: Objection. 
10:20:17 
13 
BY MR. SCAROLA: 
10:20:18 
14 
Q. 
Who? What's the name of the person? 
10:20:18 
15 
A. 
Her name is -- her first name is Rebecca. 
10:20:20 
16 
Q. 
Yes. 
10:20:25 
17 
A. 
I don't know her last name. 
10:20:26 
18 
Q. 
Did you attempt to find out her last name? 
10:20:28 
19 
A. 
I have her last name written down but -- 
10:20:30 
20 
Q. 
Where? 
10:20:32 
21 
A. 
It's in my -- in my notes. And I could 
10:20:34 
22 
get it for you. 
23 
Q. 
When did you -- 
10:20:40 
24 
A. 
I have told -- 
10:20:41 
25 
Q. 
When did you write Rebecca's name down? 
10:20:43 
EFTA00601197

45 
1 
A. 
When she -- when she first called me 
10:20:45 
2 
let me be very clear since you've asked me the 
3 
question. 
4 
At first her husband and she called me on 
10:20:50 
5 
the phone. They would not give me their names. 
6 
They did not want to disclose their names. But they 
7 
told me the story. We had a series of phone 
8 
conversations in which I asked them, please, to tell 
9 
me their names. And after a period of time, after 
10 
she told me the story in great detail, she was 
11 
willing to give me her name. She asked me to 
12 
promise that I would not disclose her identity 
13 
without her permission. I have been trying to call 
14 
her. Called her as recently as this morning and 
15 
last night. 
16 
I want to recall -- I don't think I called 
10:21:35 
17 
her this morning. I called her twice last night to 
18 
try to get her permission to reveal her complete 
19 
name and identity. But I have the name and I will 
20 
be happy to give it to you. I just don't have it on 
21 
off the top of my head. 
22 
Q. 
You obviously had her telephone number 
10:21:52 
23 
also? 
24 
A. 
No. She called me and she wouldn't give 
10:21:54 
25 
me a phone number, initially. And she said and her 
EFTA00601198

46 
1 
2 
3 
husband said she would call me back. They were 
being quite circumspect about this. Ultimately I 
got her phone number. Yes, I have her phone number. 
4 
Q. 
I'm a little bit confused. 
10:22:10 
5 
A. 
There's no reason -- 
10:22:12 
6 
Q. 
Is the answer -- 
10:22:12 
7 
A. 
There's no reason for you to be confused. 
10:22:12 
8 
Q. 
Well, I am. Is the answer to the question 
10:22:14 
9 
10 
you do have her phone number or 
MR. SCOTT: Counsel, you're arguing with 
10:22:19 
11 
12 
the witness. 
BY MR. SCAROLA: 
10:22:19 
13 
Q. 
-- you do have her phone number or you 
10:22:19 
14 
don't have her phone number? 
15 
A. 
I don't have the phone number in my head. 
10:22:21 
16 
I have the phone number written down, yes. 
17 
Q. 
And the last time you called her was -- 
10:22:27 
18 
A. 
Last night. 
10:22:29 
19 
Q. 
-- last night? 
10:22:29 
20 
A. 
That's right. Left a message. 
10:22:30 
21 
Q. 
From where? 
10:22:32 
22 
A. 
From my apartment in Miami Beach. 
10:22:33 
23 
24 
Q. 
landline? 
Did you call her from a cell phone or a 
10:22:41 
25 
A. 
Cell phone. 
10:22:44 
EFTA00601199

47 
1 
Q. 
Is it the cell phone that you have with 
10:22:49 
2 
you right now? 
3 
A. 
It is a cell phone that I have with me 
10:22:54 
4 
right now. 
5 
Q. 
Would you take out your cell phone and 
10:22:56 
6 
tell us what that number is, please. 
7 
MR. SCOTT: We'll do -- I'm not going to 
10:23:00 
8 
have him do that. At a break I'll speak to him 
9 
and we'll provide you the number, as he's 
10 
indicated. 
11 
BY MR. SCAROLA: 
10:23:07 
12 
Q. 
How many phone conversations did you have 
10:23:12 
13 
with this person Rebecca? 
14 
A. 
More than six. Probably between six and 
10:23:21 
15 
ten, maybe closer to ten. The first few she called 
16 
me and after I got their number I called her a 
17 
number of times. 
18 
Q. 
What is her husband's name? 
10:23:43 
19 
A. 
Michael. Different last name from hers, 
10:23:44 
20 
but again. 
. 
21 
Q. 
Where do they live? 
10:23:50 
22 
A. 
Palm Beach. Or West Palm Beach, in the 
10:23:51 
23 
Palm Beach area. They have been friends of 
24 
since she was a young child. 
25 
Q. 
Were there any witnesses to any of these 
10:24:03 
EFTA00601200

48 
1 
phone conversations other than Rebecca, Michael and 
2 
you? 
3 
A. 
Yes. 
10:24:10 
4 
Q. 
Who? 
10:24:11 
5 
A. 
My wife. 
10:24:11 
6 
Q. 
When did the first conversation occur? 
10:24:14 
7 
A. 
I can probably get you specific 
10:24:17 
8 
information about that. But it was months ago. 
9 
When the story was in the newspapers, she called and 
10 
related the entire story to me and related to me 
11 
that this was part of a massive extortion plot. 
12 
MR. SCOTT: When you're ready to take a 
10:24:39 
13 
break, let's take break. You've been going 
14 
about an hour. 
15 
BY MR. SCAROLA: 
10:24:43 
16 
Q. 
How long after the filing of the Crime 
10:24:44 
17 
Act pleading in which you were 
18 
referenced did you receive the phone call, the first 
19 
phone call from Rebecca? 
20 
A. 
I would be speculating, but it would 
10:24:58 
21 
probably be about a month or two after that. 
22 
MR. SCOTT: Don't speculate, sir. If you 
10:25:03 
23 
know the facts. 
24 
A. 
I -- I don't recall. 
10:25:06 
25 
EFTA00601201

49 
1 
BY MR. SCAROLA: 
2 
Q. 
Your best estimate as you sit here today 
3 
is? 
4 
5 
6 
beginning of March, but I can get you those specific 
7 
dates. There's no secret about that. 
8 
9 
10 
11 
12 
Q. 
Did you take contemporaneous notes of 
13 
those phone conversations? 
14 
15 
notes of the substance, no. 
16 
Q. 
Have you ever made notes with regard to 
17 
18 
19 
20 
conversations. I had these conversations. And I 
21 
22 
23 
24 
25 
10:25:06 
10:25:06 
A. 
Two -- two months, probably. So let's say 
10:25:08 
January, February -- probably end of February, 
MR. SCOTT: Want to take a break? 
MR. SCAROLA: In just a moment. 
MR. SCOTT: Certainly. 
BY MR. SCAROLA: 
the substance of any communication that you 
allegedly had with Rebecca and/or Michael? 
A. 
I didn't allegedly have these 
don't recall taking any notes of these 
conversations. 
MR. SCOTT: Let's take a break. 
MR. SCAROLA: Yes. 
VIDEOGRAPHER: Going off the record. The 
10:25:22 
10:25:24 
10:25:26 
10:25:26 
10:25:30 
A. 
No. I took notes of names, but not really 
10:25:36 
10:25:48 
10:25:58 
10:26:09 
10:26:10 
10:26:12 
EFTA00601202

50 
1 
time is approximately 10:26 a.m. 
2 
(Recess was held from 10:26 a.m. until 10:44 a.m.) 
10:26:16 
3 
VIDEOGRAPHER: Going back on the record. 
10:44:08 
4 
The time is approximately 10:44 a.m. 
5 
BY MR. SCAROLA: 
10:44:11 
6 
Q. 
How many phone calls did you have with 
10:44:13 
7 
this person Rebecca before she informed you as to 
8 
the reason why she was calling you? 
9 
A. 
She informed me the first time. 
10:44:29 
10 
Q. 
The very first conversation? 
10:44:31 
11 
A. 
Yes. 
10:44:32 
12 
Q. 
How many phone calls was it before she 
10:44:34 
13 
asked you for money? 
14 
A. 
Never asked me for money. 
10:44:38 
15 
Q. 
How many phone calls was it before her 
10:44:40 
16 
husband asked you for money? 
17 
MR. SCOTT: Objection, form. 
10:44:43 
18 
A. 
I was never asked for money, ever. 
10:44:43 
19 
BY MR. SCAROLA: 
10:44:45 
20 
Q. 
Do you know how it is that these people 
10:44:47 
21 
knew how to contact you? 
22 
A. 
They told me they went on my website and 
10:44:54 
23 
got my number and left a message for me to call. 
24 
Yeah, that's what happened. Oh, no, they sent me 
25 
they went on my website and sent me an e-mail and 
EFTA00601203

51 
1 
asked me -- and the e-mail had a blank name but a 
2 
way to respond. And so I responded to the e-mail 
3 
with my phone number and then they called, is my 
4 
recollection. That's my best recollection. 
5 
Q. 
Is that an e-mail that you produced in 
10:45:26 
6 
discovery? 
7 
A. 
I have no idea. 
10:45:28 
8 
MR. SIMPSON: The attorneys have handled 
10:45:30 
9 
discovery. 
10 
BY MR. SCAROLA: 
10:45:33 
11 
Q. 
Have you ever seen that e-mail since it 
10:45:34 
12 
was received? 
13 
A. 
I have no recollection. 
10:45:39 
14 
Q. 
Certainly you recognized the significance 
10:45:40 
15 
of preserving that e-mail? 
16 
A. 
I'm sure I have it. 
10:45:46 
17 
Q. 
You sure you have it? 
10:45:47 
18 
A. 
I'm positive, of course. 
10:45:48 
19 
Q. 
So from the very first conversation that 
10:45:55 
20 
you had with this person, you had information 
21 
indicating that this person was informing you that 
22 
Bradley Edwards had engaged in unethical conduct, 
23 
correct? 
24 
MR. SCOTT: Objection, form. 
10:46:19 
25 
A. 
Let me just be very clear what -- what she 
10:46:20 
EFTA00601204

52 
1 
said to me. She said to me that she had been told 
2 
directly by her friend, 
, who stayed 
3 
with her overnight for a period of time, that she 
4 
never wanted to mention me in any of the pleadings. 
5 
And that her two lawyers in the pleadings, or her 
6 
lawyers who filed the pleadings, pressured her in to 
7 
including my name and the details. 
8 
BY MR. SCAROLA: 
10:46:52 
9 
Q. 
Did Rebecca ever suggest to you that the 
10:46:53 
10 
details sworn to by 
with regard to 
11 
you were false? 
12 
MR. SCOTT: Objection, form. Go ahead. 
10:47:08 
13 
A. 
She certainly suggested that, yes. She 
10:47:09 
14 
mentioned to me that 
had never, 
15 
ever mentioned to her me, among any of the people 
16 
that she had had any contact with until she -- until 
17 
she was pressured into doing so by her lawyers, yes. 
18 
BY MR. SCAROLA: 
10:47:28 
19 
Q. 
So, from the very first conversation, the 
10:47:29 
20 
impression you had was that this was a witness who 
21 
could provide information that Bradley Edwards and 
22 
Paul Cassell had acted unethically and dishonestly, 
23 
correct? 
24 
A. 
I wasn't sure she could provide the 
10:47:48 
25 
information because she was very reluctant to come 
EFTA00601205

53 
1 
forward. She didn't want to be involved. She 
2 
didn't want her name involved. But I knew she had 
3 
provided me with information, yes, but I didn't 
4 
know, and still don't know, whether she is prepared 
5 
to be a witness. I don't know the answer to that 
6 
question. 
7 
Q. 
Well, there is a difference, is there not, 
10:48:09 
8 
sir, between what she could do and what she would 
9 
do? 
10 
MR. SCOTT: Objection, form. 
10:48:16 
11 
Argumentative. 
12 
A. 
I don't understand. 
10:48:18 
13 
BY MR. SCAROLA: 
10:48:18 
14 
Q. 
You don't understand that? 
10:48:19 
15 
A. 
I don't understand that. She could do or 
10:48:19 
16 
would do. 
17 
Q. 
She was telling you that she had the 
10:48:22 
18 
ability to impeach 
' assertions 
19 
against you? 
20 
MR. SCOTT: Same objection. 
10:48:31 
21 
A. 
What she told me was the truth, is that 
10:48:32 
22 
never wanted to mention me, but 
23 
that she was pressured by her lawyer into mentioning 
24 
me. And that was the truth. 
25 
EFTA00601206

54 
1 
BY MR. SCAROLA: 
10:48:46 
2 
Q. 
Well, you also have told us that not only 
10:48:47 
3 
did she suggest to you that 
didn't 
4 
want to mention you, but that 
had 
5 
not had the sexual encounters with you that she has 
6 
sworn under oath she did have, correct? 
7 
MR. SCOTT: Objection. Go ahead. 
10:49:07 
8 
A. 
What she told me was that she didn't 
10:49:09 
9 
believe -- that is, this woman didn't believe that 
10 
there had been any contact between me and 
11 
because 
had never mentioned 
12 
me previously until her lawyers pressured her 
13 
into -- into allowing my name to be included in the 
14 
pleading, that's what she told me. 
15 
BY MR. SCAROLA: 
10:49:31 
16 
Q. 
Did you have the impression that there was 
10:49:32 
17 
improper pressure that had been exerted on 
18 
based upon what you were being told by this 
19 
woman? 
20 
MR. SCOTT: Objection, form. 
10:49:47 
21 
A. 
Absolutely. Of course. 
10:49:48 
22 
BY MR. SCAROLA: 
23 
Q. 
So this was based upon what this woman was 
10:49:50 
24 
telling you, evidence of unethical, unprofessional 
25 
dishonest conduct on the part of Bradley Edwards and 
EFTA00601207

55 
1 
Paul Cassell, right? 
2 
A. 
That was certainly the impression I got 
10:50:04 
3 
and certainly an impression that confirmed what I 
4 
already believed. I mean, I've known from day one 
5 
that they were engaged in unethical, unprofessional, 
6 
in my view and my opinion, disbarrable conduct. 
7 
This simply confirmed that. 
8 
Q. 
Yes, sir. We're going to get to that 
10:50:20 
9 
shortly, but I want to stay focused right now on 
10 
these communications that you claim to have had --
11 
A. 
Not claimed to have had. 
10:50:28 
12 
Q. 
-- with Rebecca. 
10:50:29 
13 
A. 
Communications that I had. Let's be 
10:50:30 
14 
clear. Communications that I had. No claim. I had 
15 
them. 
16 
Q. 
Let's first try, if we could, to pinpoint 
10:50:39 
17 
a little better when the first of these 
18 
conversations occurred. Do you recall having been 
19 
propounded interrogatories in this case that asked 
20 
you to identify all persons with knowledge of any 
21 
circumstance in which it is alleged that Bradley 
22 
Edwards engaged in unethical conduct, unprofessional 
23 
conduct or dishonest conduct? 
24 
MR. SCOTT: Objection, form. 
10:51:13 
25 
A. 
I have no recollection as to the sequence 
10:51:14 
EFTA00601208

56 
1 
or chronology. 
2 
BY MR. SCAROLA: 
10:51:17 
3 
Q. 
Well, let me hand you for purposes of 
10:51:18 
4 
refreshing your recollection the answers to 
5 
interrogatories that were filed as of February 23, 
6 
2015. 
7 
A. 
What was the date again? I missed that. 
10:51:55 
8 
MR. SCOTT: He's going to show you the 
10:51:58 
9 
exhibit. 
10 
BY MR. SCAROLA: 
10:52:00 
11 
Q. 
The answers to interrogatories bear a 
10:52:01 
12 
certificate of service dated February 23, 2015 and a 
13 
verification --
14 
MR. SCOTT: Are you going to mark that as 
10:52:15 
15 
an exhibit, please? 
16 
MR. SCAROLA: I will in just a moment. 
10:52:17 
17 
BY MR. SCAROLA: 
10:52:18 
18 
Q. 
And a verification that appears to be your 
10:52:19 
19 
signature. 
20 
A. 
It is. 
10:52:22 
21 
Q. 
Is that, in fact, your signature? 
10:52:23 
22 
A. 
It is, in fact, my signature. 
10:52:24 
23 
Q. 
Were you verifying those answers intending 
10:52:25 
24 
them to be your sworn responses to those 
25 
interrogatories? 
EFTA00601209

57 
1 
A. 
I was verifying my lawyer's responses, 
10:52:30 
2 
yes. 
3 
Q. 
Well, were they your responses or were 
10:52:35 
4 
they your lawyer's responses? 
5 
A. 
My lawyers 
10:52:38 
6 
MR. SCOTT: Objection, argumentative. 
10:52:40 
7 
You can answer it. 
10:52:42 
8 
A. 
My lawyers drafted the responses. I was 
10:52:42 
9 
asked to look over them. I looked over them and I 
10 
signed, yes. 
11 
BY MR. SCAROLA: 
10:52:47 
12 
Q. 
You signed them -- 
10:52:48 
13 
A. 
Yes. 
10:52:48 
14 
Q. 
-- and swore to their truthfulness, 
10:52:49 
15 
correct? 
16 
A. 
Let me just read what it says. 
10:52:51 
17 
Yes, they were true to the best of my 
10:52:57 
18 
knowledge and belief, yes. 
19 
Q. 
Since there is no reference in those 
10:53:05 
20 
answers to interrogatories to Rebecca or Michael, 
21 
can we assume that the first of your phone calls 
22 
must have occurred some time after February 23 when 
23 
you verified the answers to those interrogatories? 
24 
MR. SCOTT: Objection, form, asked and 
10:53:26 
25 
answered. 
EFTA00601210

58 
1 
A. 
I don't have a specific recollection as to 
10:53:28 
2 
the exact date of when the call came. 
3 
BY MR. SCAROLA: 
10:53:32 
4 
Q. 
Well, you certainly would not have sworn 
10:53:32 
5 
to the accuracy of those answers which ask you to 
6 
identify every person with knowledge of any 
7 
unethical, unprofessional, or dishonest conduct on 
8 
the part of Bradley Edwards, and omitted the name of 
9 
Rebecca and Michael --
10 
MR. SCOTT: Objection, argumentative. 
10:53:57 
11 
BY MR. SCAROLA: 
10:53:58 
12 
Q. 
-- if they already called you? 
10:53:58 
13 
MR. SCOTT: Argumentative and compound. 
10:54:01 
14 
A. 
I don't recall when Rebecca and Michael 
10:54:03 
15 
called me, but I do recall that they made me promise 
16 
that I would not disclose the information that they 
17 
had revealed until they gave me permission to do so. 
18 
They also did not give me their names, initially, 
19 
and I only learned both the names over time and the 
20 
information. 
21 
The information came out gradually. But 
10:54:23 
22 
there was a time when I did have the information 
23 
that the two clients pressured -- that was her word, 
24 
"pressured" -- 
into naming me, 
25 
right. 
EFTA00601211

59 
1 
BY MR. SCAROLA: 
10:54:43 
2 
Q. 
You certainly considered the communication 
10:54:53 
3 
that you were having with these individuals to be a 
4 
matter of significance from the timing of the first 
5 
phone call, correct, since it was in the first phone 
6 
call that they disclosed to you the essence of what 
7 
you are saying they said? 
8 
MR. SCOTT: Objection, compound. 
10:55:10 
9 
A. 
I wasn't sure whether it would be 
10:55:11 
10 
significant or not because I didn't know at the time 
11 
whether I would be free to reveal it or to use it. 
12 
I'm still -- I just wasn't sure whether I 
10:55:24 
13 
would be free to reveal it. It would not be 
14 
particularly significant except to my own 
15 
confirmation of what I knew to be true; namely, that 
16 
your clients had engaged in unethical and 
17 
unprofessional conduct. I knew that to be true. 
18 
But this provided me with some confirmation of that. 
19 
But I didn't know whether I was going to 
10:55:42 
20 
be able to use that confirmation because I had made 
21 
a promise that was elicited from me by them that I 
22 
would not disclose this information without their 
23 
permission. 
24 
BY MR. SCAROLA: 
10:55:55 
25 
Q. 
All right. Permission that you swore to a 
10:55:56 
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60 
1 
little while ago you still haven't received, 
2 
correct? 
3 
A. 
I have not received the permission to 
10:56:01 
4 
identify them by name, that's right. 
5 
By the way, in the recess 
oh, no, 
10:56:10 
6 
that's enough. Okay. 
7 
Q. 
What happened in the recess? 
10:56:15 
8 
MR. SCOTT: Objection -- 
10:56:17 
9 
A. 
I spoke to my lawyers. 
10:56:18 
10 
MR. SCOTT: -- don't answer that. It's 
10:56:19 
11 
conversations with counsel. 
12 
BY MR. SCAROLA: 
10:56:20 
13 
Q. 
You spoke to whom? 
10:56:20 
14 
A. 
I spoke to my lawyers. 
10:56:21 
15 
Q. 
Was your promise to these people that you 
10:56:29 
16 
wouldn't disclose their last name? 
17 
A. 
My promise to the people was that I would 
10:56:36 
18 
not identify them so that they would not be hassled 
19 
and harassed and any pressure put on them. That was 
20 
their concern, that they didn't want to be receiving 
21 
phone calls and they didn't want to be part of what 
22 
they regarded as a media circus. 
23 
Q. 
Well, you know you have broken that 
10:56:57 
24 
promise at this point, haven't --
25 
A. 
No, I haven't -- 
10:57:01 
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