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1 
said. She said what I said she said. 
2 
And then she said that her lawyers would 
11:23:00 
3 
be in touch with me. And her lawyer then called me 
4 
and corroborated again that there had been contact 
5 
and eventually there was greater contact. 
6 
Q. 
Contact by whom with whom? 
11:23:15 
7 
A. 
Contact by -- by 
' lawyer, 
11:23:17 
8 
lawyers. I wasn't -- it wasn't clear at that point. 
9 
Q. 
Which lawyer or lawyers? 
11:23:26 
10 
A. 
I wasn't clear at that point. They didn't 
11:23:27 
11 
indicate to me which lawyer or lawyers 
12 
Q. 
Didn't you ask? 
11:23:31 
13 
A. 
-- contact. 
11:23:32 
14 
Q. 
Didn't you want to know, is this Bradley 
11:23:32 
15 
Edwards or Professor Paul Cassell who is --
16 
A. 
I asked -- 
11:23:35 
17 
Q. 
-- making this 
11:23:36 
18 
A. 
I asked -- 
11:23:36 
19 
MR. SCOTT: Objection, form. Go ahead. 
11:23:37 
20 
A. 
I asked whether there was a letter and 
11:23:39 
21 
they wouldn't show me a letter. I asked if there 
22 
were phone calls. They were a -- they wanted to be 
23 
discreet about how the contact had occurred. But 
24 
they told me that the contact had occurred. 
25 
EFTA00601234

82 
1 
BY MR. SCAROLA: 
11:23:52 
2 
Q. 
But they wouldn't tell you who? 
11:23:53 
3 
A. 
They wouldn't show me any letter. 
11:23:55 
4 
Q. 
That's not my question. Did they tell 
11:23:58 
5 
you -- did you ask who contacted Leslie Wexner? 
6 
A. 
The first answer was 
11:24:07 
7 
lawyer. 
8 
I then subsequently learned that among 
11:24:11 
9 
those who contacted Leslie Wexner's lawyers was 
10 
David Boies and Sigrid McCawley. 
11 
Q. 
Not Bradley Edwards, correct? 
11:24:24 
12 
MR. SCOTT: Objection as to the form. 
11:24:27 
13 
BY MR. SCAROLA: 
11:24:28 
14 
Q. 
Correct? 
11:24:29 
15 
A. 
I was not given the name Bradley Edwards 
11:24:30 
16 
at that time. But was subsequently told by David 
17 
Boies that Bradley Edwards and Paul Cassell --
18 
MS. McCAWLEY: I'm going to object to the 
11:24:43 
19 
extent this reveals any conversations that 
20 
happened in the context of settlement 
21 
discussions. 
22 
MR. SCOTT: Okay. Note your objection. 
11:24:48 
23 
Go ahead. 
24 
A. 
That I was ultimately told by David Boies 
11:24:52 
25 
that he had done an extensive investigation of the 
EFTA00601235

83 
1 
allegations against Leslie Wexner and had concluded 
2 
that they were 
3 
MS. McCAWLEY: Again, I'm going to object 
11:25:05 
4 
to this has happened in the context of 
5 
settlement --
6 
A. 
-- false. 
11:25:07 
7 
MS. McCAWLEY: -- negotiations. I'm going 
11:25:07 
8 
to move for sanctions if information is 
9 
revealed that happened in the context of 
10 
settlement discussions. 
11 
MR. SCOTT: I don't know whether -- I 
11:25:12 
12 
don't believe there were settlement 
13 
discussions. But even if they weren't, they 
14 
would still be admissible. 
15 
A. 
Let me continue -- 
11:25:21 
16 
MR. SCOTT: For discovery purposes. 
11:25:22 
17 
A. 
-- that David Boies had done -- 
11:25:23 
18 
MS. McCAWLEY: I disagree. I think we're 
11:25:24 
19 
going to have to take this to the judge, then; 
20 
if we're going to reveal settlement 
21 
conversations in this conversation, then we 
22 
need to go to the judge on it. 
23 
MR. SCOTT: Whatever you need to do. 
11:25:31 
24 
A. 
Let me continue the -- what he told me. 
11:25:33 
25 
That David Boies had --
EFTA00601236

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1 
MS. McCAWLEY: No, we're -- 
11:25:35 
2 
MR. SIMPSON: No, no, no. 
11:25:37 
3 
MS. McCAWLEY: -- going to discontinue. 
11:25:38 
4 
We will contact the judge. 
5 
MR. SCAROLA: We'll move on to another 
11:25:41 
6 
area and address that issue with the judge as 
7 
to whether or not a protective order is 
8 
appropriate. 
9 
A. 
Would you like to establish the foundation 
11:25:46 
10 
for why it's not protected? 
11 
MR. SWEDER: Alan 
11:25:50 
12 
MR. SCOTT: Alan, just let it alone. Let 
11:25:51 
13 
it alone. 
14 
THE WITNESS: Okay. 
11:25:53 
15 
BY MR. SCAROLA: 
11:25:55 
16 
Q. 
This second conversation you've told us 
11:26:00 
17 
was conducted while you were in New York, correct? 
18 
A. 
That's my best recollection. 
11:26:06 
19 
Q. 
The first conversation also conducted 
11:26:09 
20 
while you were in New York? 
21 
A. 
That's my best recollection. 
11:26:12 
22 
Q. 
Are you aware that New York is a one-party 
11:26:17 
23 
consent state for purposes of permitting the 
24 
recording of communications, correct? 
25 
MR. SCOTT: Objection. Do you know? 
11:26:31 
EFTA00601237

85 
1 
A. 
I'm -- I think that's right, yeah. 
11:26:34 
2 
BY MR. SCAROLA: 
11:26:40 
3 
Q. 
Okay. So you knew that these significant 
11:26:41 
4 
conversations could have been recorded by you had 
5 
you chosen to record them, correct? 
6 
A. 
I don't think I thought about that at the 
11:26:52 
7 
time. I certainly -- I didn't think about that at 
8 
the time, no. 
9 
Q. 
How many conversations in total did you 
11:27:00 
10 
have with Rebecca and/or Michael when you were in 
11 
New York and had the legal right, had you chosen to, 
12 
not only to make contemporaneous notes but to 
13 
actually record the conversations? 
14 
MR. SCOTT: Objection, asked and answered. 
11:27:20 
15 
A. 
I think I was in New York for two of the 
11:27:21 
16 
conversations. I think I was in Massachusetts for 
17 
several of the conversations. I don't think I was 
18 
in Florida. I think it was New York and 
19 
Massachusetts. 
20 
BY MR. SCAROLA: 
11:27:33 
21 
Q. 
Massachusetts is also a one-party consent 
11:27:33 
22 
state, is it not? 
23 
A. 
You don't know the law, sir, no. 
11:27:36 
24 
Q. 
It is not? 
11:27:38 
25 
A. 
No. 
11:27:38 
EFTA00601238

86 
1 
Q. 
Okay. 
11:27:39 
2 
A. 
It is clearly not. 
11:27:39 
3 
Q. 
Okay. So, you -- you recognize the 
11:27:40 
4 
significant distinction between making the phone 
5 
call from New York and making the phone call from 
6 
Massachusetts because in New York you would be 
7 
permitted to -- excuse me, to record the phone call; 
8 
whereas, in Massachusetts you could not record it 
9 
without the consent of all parties involved? 
10 
A. 
It never -- 
11:27:58 
11 
MR. SCOTT: Objection, argumentative. 
11:27:58 
12 
A. 
It never occurred to me. 
11:28:00 
13 
BY MR. SCAROLA: 
11:28:02 
14 
Q. 
Never occurred to you? 
11:28:02 
15 
A. 
No. 
11:28:03 
16 
Q. 
Have we covered the entire content of the 
11:28:09 
17 
second conversation? 
18 
A. 
I think so, yes. I continued to ask her 
11:28:25 
19 
if -- if I could use her -- if she was willing to 
20 
give me -- allow me to use her name. But that's 
21 
all. There were -- the substance of what she told 
22 
me I think I've covered fairly thoroughly, yes. 
23 
Q. 
Did Michael ever tell you that 
11:28:46 
24 
had said she never met you? 
25 
MR. SCOTT: Read that back, will you, for 
11:28:53 
EFTA00601239

87 
1 
me. Sorry. 
2 
(Requested portion read back.) 
11:28:54 
3 
MR. SCOTT: Okay. Thank you. 
11:29:00 
4 
A. 
Michael and I did not discuss the 
11:29:04 
5 
substance of 
conversations with Rebecca 
6 
because the conversations were between 
and 
7 
Rebecca. So there was no conversation about that. 
8 
BY MR. SCAROLA: 
11:29:18 
9 
Q. 
Did Rebecca ever tell you that 
11:29:19 
10 
ever said that she had never met you? 
11 
A. 
The implication was quite clear that she 
11:29:25 
12 
had never mentioned me, that she didn't want to 
13 
mention me, and that the lawyers pressured her into 
14 
falsely accusing me of an act that simply never 
15 
occurred. 
16 
Q. 
Okay. I'm not asking you about what you 
11:29:44 
17 
implied from what was said. 
18 
A. 
Inferred. 
11:29:47 
19 
Q. 
Inferred. 
11:29:49 
20 
A. 
Right. 
11:29:50 
21 
Q. 
Inferred from what was said. 
11:29:51 
22 
What I am asking you is whether Rebecca 
11:29:53 
23 
ever told you that 
said she had never met 
24 
you. 
25 
MR. SCOTT: Objection, asked and answered. 
11:30:03 
EFTA00601240

88 
1 
A. 
Not in those words. 
11:30:04 
2 
BY MR. SCAROLA: 
11:30:06 
3 
Q. 
Did she say any words that conveyed that 
11:30:06 
4 
message? 
5 
A. 
Yes. 
11:30:09 
6 
Q. 
What words did she say? 
11:30:10 
7 
A. 
That she had never mentioned me 
11:30:12 
8 
previously. And that she was pressured into 
9 
mentioning me by her lawyers and that certainly gave 
10 
rise to an inference on my part that the story -- an 
11 
inference that simply confirmed what I knew to be 
12 
the fact, that her allegations against me were 
13 
completely, totally and entirely made up out of 
14 
whole cloth. 
15 
Q. 
Let's see if we can make sure that we're 
11:30:37 
16 
understanding one another, sir. 
17 
Do you recognize that there's a 
11:30:44 
18 
distinction between 
having met you, 
19 
having been sexually abused by you on multiple 
20 
occasions, but not wanting to name you, as opposed 
21 
to 
never having met you and never 
22 
having been sexually abused by you? 
23 
MR. SCOTT: Objection -- 
11:31:12 
24 
BY MR. SCAROLA: 
11:31:12 
25 
Q. 
Are those two things different in your 
11:31:13 
EFTA00601241

89 
1 
mind? 
2 
MR. SCOTT: Objection, argumentative and 
11:31:15 
3 
compound. 
4 
A. 
Not in the context of this case. Because 
11:31:17 
5 
said that she was going to seek 
6 
justice from everybody that had abused her. And if 
7 
she didn't want to name me, I think the inference is 
8 
inescapable that I was not among those people that 
9 
she had had any sexual contact with. So that was 
10 
certainly the inference I drew and I think it's an 
11 
inescapable inference. 
12 
BY MR. SCAROLA: 
11:31:45 
13 
Q. 
When did 
say she was 
11:31:45 
14 
going to seek justice from everyone who had abused 
15 
her? 
16 
A. 
In her -- in her depositions, in her 
11:31:50 
17 
interviews with the media, certainly that's been a 
18 
common theme, that it was time that -- that Jeffrey 
19 
Epstein's friends who had abused her were brought to 
20 
justice and were not seen as above the law. Just go 
21 
back and check, you'll see there are repeated 
22 
references to that in her statements. 
23 
Q. 
Which depositions? 
11:32:17 
24 
A. 
You'll have to check those. You know 
11:32:18 
25 
those as well as I do. 
EFTA00601242

90 
1 
Q. 
Well, I'm -- I'm sorry. My memory is not 
11:32:22 
2 
superb. 
3 
A. 
Okay. So let me go over them. 
11:32:26 
4 
Q. 
And -- and I would like you to tell us 
11:32:29 
5 
based --
6 
MR. SCOTT: Objection. Please just ask 
11:32:29 
7 
questions, Counsel. 
8 
MR. SCAROLA: I am doing that. 
11:32:32 
9 
BY MR. SCAROLA: 
11:32:32 
10 
Q. 
I would like you to tell us which 
11:32:33 
11 
depositions 
said -- in which 
12 
depositions 
said, I am going to 
13 
seek justice from everyone who abused me. 
14 
A. 
My recollection is she said it on multiple 
11:32:44 
15 
occasions. She may have said it in her 
16 
conversations -- in her telephone interview with 
17 
Bradley Edwards and you. She may have said it in 
18 
her interviews with various British media for which 
19 
she was apparently paid. She may have said it in 
20 
her two false affidavits that she filed in the 
21 
federal court. 
22 
I'm not sure where she said it, but I'm 
11:33:18 
23 
completely confident that she said it. 
24 
Q. 
What is a deposition? 
11:33:25 
25 
A. 
What we're having here now. 
11:33:27 
EFTA00601243

91 
1 
Q. 
Your testimony was that 
11:33:35 
2 
made these statements in depositions, plural. You 
3 
then went on to talk about a telephone interview and 
4 
interviews with the British media. Let's go back to 
5 
my question, if we could. 
6 
When you made the statement under oath 
11:33:50 
7 
that 
said she was going to seek 
8 
justice from everyone who abused her in depositions, 
9 
which depositions were you talking about? 
10 
A. 
I was using -- 
11:34:05 
11 
MR. SCOTT: Objection, asked and answered. 
11:34:06 
12 
He's already provided --
13 
A. 
I was using the term loosely, I apologize. 
11:34:08 
14 
I meant in statements, including statements under 
15 
oath. So I withdraw the statement about 
16 
depositions. But I insist that she made statements 
17 
along those lines in her interviews of both formal 
18 
and informal, both legal and to the media, so that I 
19 
was entitled to draw the conclusion, the reasonable 
20 
inference, that when she did not want to name me, it 
21 
was because that I -- I never had any sexual or any 
22 
other contact with her, which I know to be the 
23 
truth. So that's an inference that I draw. 
24 
BY MR. SCAROLA: 
11:34:47 
25 
Q. 
Okay. And it is an inference that you 
11:34:47 
EFTA00601244

92 
1 
drew, not something that either Rebecca or Michael 
2 
ever told you, correct? 
3 
A. 
I certainly believe that they believe 
11:34:57 
4 
that. But Rebecca was very careful about the words 
5 
that she communicated to me and she told me 
6 
precisely what it was that 
had told 
7 
her and didn't go beyond that and didn't draw any 
8 
and didn't tell me any words that weren't, in fact, 
9 
recited by 
10 
So the words were she never mentioned you 
11:35:24 
11 
before all this stuff in the media, and she told me 
12 
expressly that she did not want to include you in 
13 
any of the allegations of sexual misconduct but her 
14 
lawyers pressured her into doing it. 
15 
MR. SCOTT: I'd like to take a break in 
11:35:47 
16 
another five minutes or so. We've been going 
17 
another hour. So where ever you think is good, 
18 
Jack. 
19 
MR. SCAROLA: We're not quite there yet. 
11:35:55 
20 
BY MR. SCAROLA: 
11:35:58 
21 
Q. 
Who are the people that Rebecca says 
11:35:58 
22 
had previously told her that 
was 
23 
abused by? 
24 
A. 
I never asked her that question. 
11:36:10 
25 
Q. 
Did you ask her was Les Wexner one of the 
11:36:14 
EFTA00601245

93 
1 
people that abused 
2 
A. 
I told you I never asked her the question. 
11:36:21 
3 
Q. 
Are you aware that years before December 
11:36:48 
4 
of 2014, when the CVRA pleading was filed, that your 
5 
name had come up repeatedly in connection with 
6 
Jeffrey Epstein's abuse of minors, correct? 
7 
MR. SCOTT: Objection, form, overly broad. 
11:37:16 
8 
A. 
Let me answer that question. I am aware 
11:37:17 
9 
that never before 2014, end of December, was it 
10 
ever, ever alleged that I had acted in any way 
11 
inappropriately with regard to 
12 
that I ever touched her, that I ever met her, that I 
13 
had ever been with her. I was completely aware of 
14 
that. There had never been any allegation. 
15 
She claims under oath that she told you 
11:37:48 
16 
that secretly in 2011, but you have produced no 
17 
notes of any such conversation. You, of course, are 
18 
a witness to this allegation and will be deposed as 
19 
a witness to this allegation. I believe it is an 
20 
entirely false allegation that she told you in 2011 
21 
that she had had any sexual contact with me. I 
22 
think she's lying through her teeth when she says 
23 
that. And I doubt that your notes will reveal any 
24 
such information. 
25 
But if she did tell you that, she would be 
11:38:24 
EFTA00601246

94 
1 
absolutely, categorically lying. So I am completely 
2 
aware that never, until the lies were put in a legal 
3 
pleading at the end of December 2014, it was never 
4 
alleged that I had any sexual contact with 
5 
6 
I know that it was alleged that I was a 
11:38:46 
7 
witness to Jeffrey Epstein's alleged abuse and that 
8 
was false. I was never a witness to any of Jeffrey 
9 
Epstein's sexual abuse. And I wrote that to you, 
10 
something that you have falsely denied. And I stand 
11 
on the record. The record is clear that I have 
12 
categorically denied I was ever a witness to any 
13 
abuse, that I ever saw Jeffrey Epstein abusing 
14 
anybody. 
15 
And -- and the very idea that I would 
11:39:18 
16 
stand and talk to Jeffrey Epstein while he was 
17 
receiving oral sex from 
, which she 
18 
swore to under oath, is so outrageous, so 
19 
preposterous, that even David Boies said he couldn't 
20 
believe it was true. 
21 
MS. McCAWLEY: I object. I object. I'm 
11:39:40 
22 
not going to allow you to reveal any 
23 
conversations that happened in the context of a 
24 
settlement discussion. 
25 
THE WITNESS: Does she have standing? 
11:39:46 
EFTA00601247

95 
1 
MS. McCAWLEY: I have a standing objection 
11:39:47 
2 
and, I'm objecting again. I'm not going to --
3 
THE WITNESS: No, no, no. Does she have 
11:39:49 
4 
standing in this deposition? 
5 
MR. SCOTT: Let's take a break for a 
11:39:51 
6 
minute, okay? 
7 
THE WITNESS: I'm not sure she has 
11:39:54 
8 
standing. 
9 
MR. SCAROLA: Are we finished with the 
11:39:57 
10 
speech? 
11 
MR. SCOTT: No. If he -- 
11:39:58 
12 
MR. SCAROLA: I'd like him to finish the 
11:39:59 
13 
speech so that we can get to my question and 
14 
then we can take a break. 
15 
A. 
So the question -- the answer to your 
11:40:02 
16 
question is --
17 
MR. SIMPSON: Wait a minute. Wait a 
11:40:04 
18 
minute. Wait a minute. Please don't disclose 
19 
something that she has a right to raise that 
20 
objection if she wants to. 
21 
MR. SCOTT: Exactly. 
11:40:13 
22 
THE WITNESS: Okay. 
11:40:14 
23 
MR. SCOTT: Ask your question. 
11:40:17 
24 
MR. SWEDER: Maybe you want to read back 
11:40:20 
25 
the last couple of sentences. 
EFTA00601248

96 
1 
MR. SCAROLA: No, how about just reading 
11:40:22 
2 
back the last question and maybe we can get an 
3 
answer to the question. 
4 
MR. SCOTT: Again, I move to strike your 
11:40:27 
5 
comments, Counsel, because it's inappropriate 
6 
and you're too good a lawyer to know that 
7 
that's not true --
8 
MR. SCAROLA: Nothing inappropriate about 
11:40:33 
9 
my insisting upon an answer to the question 
10 
that I asked instead of a speech. 
11 
MR. SCOTT: Well, you know, he's trying to 
11:40:37 
12 
answer your question to the best of his 
13 
ability. Counsel objected to it. I wanted to 
14 
take a break to make sure that we explained to 
15 
him the position so that we didn't have a 
16 
problem, and I was trying to protect everybody 
17 
in this room. But if you want to proceed, we 
18 
can do it. 
19 
MR. SCAROLA: Well, if we simply answer 
11:40:52 
20 
the questions that are asked, there won't be a 
21 
problem. 
22 
MR. SCOTT: Well, I guess everybody -- you 
11:40:59 
23 
can characterize it one way, I can characterize 
24 
it another, that he's doing the best he can to 
25 
answer your questions. 
EFTA00601249

97 
1 
MR. SCAROLA: And ultimately Judge Lynch 
11:41:05 
2 
will make that determination. 
3 
MR. SCOTT: Absolutely. Sobeit. 
11:41:08 
4 
MR. SCAROLA: So read back the last 
11:41:08 
5 
question, if you would, please. We'll get a 
6 
hopefully get an answer to that and then we can 
7 
take a break. 
8 
MR. SCOTT: Again, I object to the 
11:41:14 
9 
comments, Counsel. 
10 
(Requested portion read back as follows:) 
11:41:16 
11 
THE COURT REPORTER: "Are you aware that 
11:41:39 
12 
years before December of 2014, when the CVRA 
13 
pleading was filed, that your name had come up 
14 
repeatedly in connection with Jeffrey Epstein's 
15 
abuse of minors, correct?" 
16 
MR. SCOTT: Objection, asked and answered 
11:41:41 
17 
several times. Go ahead. 
18 
A. 
I have answered that question. If you 
11:41:45 
19 
would like, I will answer it again. 
20 
BY MR. SCAROLA: 
11:41:50 
21 
Q. 
I would like an answer to that question. 
11:41:50 
22 
A. 
I am aware -- 
11:41:51 
23 
Q. 
Seems to me it calls for yes or no 
11:41:52 
24 
response. 
25 
A. 
It does not -- 
11:41:54 
EFTA00601250

98 
1 
Q. 
Yes, I am aware that my name is -- 
11:41:55 
2 
MR. SCOTT: Again, I object to -- I'm not 
11:41:57 
3 
trying to get into a fight with you, Jack, but 
4 
I object to the comments, you know. Really 
5 
just let him answer the question. 
6 
MR. SCAROLA: You and I don't need to 
11:42:02 
7 
fight. 
8 
MR. SCOTT: I agree. 
11:42:04 
9 
A. 
The word "in connection" is what requires 
11:42:05 
10 
a longer answer. Yes, I am aware that it was 
11 
falsely alleged by you that multiple witnesses had 
12 
placed me at places and scenes where multiple 
13 
victims had been abused by Jeffrey Epstein. That 
14 
statement by you, Mr. Scarola, was a false 
15 
statement. It is not true that multiple witnesses 
16 
have said that. And you misstated that. 
17 
I am aware that there were false 
11:42:35 
18 
allegations that I was a witness but never a 
19 
participant in any improper conduct. And I 
20 
categorically responded in letters to you, and to 
21 
Mr. Edwards, I think, that there was no truth to 
22 
that. That if any witness had so testified, they 
23 
would be committing perjury. 
24 
MR. SCAROLA: You have requested a break. 
11:43:04 
25 
MR. SCOTT: Let's do it. Good point. 
11:43:06 
EFTA00601251

99 
1 
VIDEOGRAPHER: Going off the record. The 
11:43:07 
2 
time is approximately 11:43 a.m. 
3 
(Recess was held from 11:43 a.m. until 12:02 p.m.) 
11:43:11 
4 
VIDEOGRAPHER: Going back on the record. 
12:02:12 
5 
The time is approximately 12:02 p.m. 
6 
BY MR. SCAROLA: 
12:02:16 
7 
Q. 
Have we completely covered the content of 
12:02:17 
8 
phone call number 2? 
9 
A. 
To my best of my recollection, yes. 
12:02:22 
10 
Q. 
Okay. Let's go to the very next 
12:02:25 
11 
communication between you and either Rebecca or 
12 
Michael. 
13 
A. 
My recollection is that I asked them if 
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14 
they had anything else that they were aware of, any 
15 
other information, I asked her whether she had been 
16 
in touch with 
. I think in the 
17 
third conversation we also talked about the charity. 
18 
And she agreed. 
19 
Q. 
I'm sorry, I need to stop you for a just a 
12:03:01 
20 
moment. Who contacted whom and when? 
21 
A. 
I think I contacted them. Normally the 
12:03:08 
22 
procedure was I speak to Michael, he would pick up 
23 
the phone, I only had his number. I only had his 
24 
phone number, not hers. 
25 
Q. 
So this was the third phone call initiated 
12:03:18 
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100 
1 
by you? 
2 
A. 
By me to the best of my recollection. 
12:03:22 
3 
I called him and he would always be the 
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4 
kind of gatekeeper and often she was putting the 
5 
babies to sleep, and sometimes she couldn't come to 
6 
the phone. The third conversation, substantive 
7 
conversation -- there may have been conversations 
8 
where I called and Michael wasn't there or I left a 
9 
message, or where Michael was there but she was 
10 
putting the babies to sleep and either she said they 
11 
would -- either he said they would call me back or I 
12 
called them back. 
13 
But the third substantive conversation, to 
12:03:48 
14 
the best --
15 
Q. 
Where were you? 
12:03:51 
16 
A. 
Huh? 
12:03:52 
17 
Q. 
Where were you when you 
12:03:53 
18 
A. 
Probably -- 
12:03:54 
19 
Q. 
-- initiated this call? 
12:03:55 
20 
A. 
Probably in Massachusetts at this point. 
12:03:55 
21 
And then -- we discussed the charity. And 
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22 
I think it was called ■, which is her initials, 
23 
, and also it stood for something, I 
24 
don't know, 
or something like that. 
25 
And she said that the lawyers had contributed 
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