EFTA01116693

Exhibit 1 
EFTA01116713

1 
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 DEPOSITION OF 
ALAN M. DERSHOWITZ 
VOLUME 1 
Pages 1 through 179 
Thursday, October 15, 2015 
9:31 a.m. - 4:13 p.m. 
Cole Scott & Kissane 
110 Southeast 6th Street 
Fort Lauderdale, Florida 
Stenographically Reported By: 
Kimberly Fontalvo, RPR, CLR 
Realtime Systems Administrator 
EFTA01116714

93 
1 
people that abused Virginia? 
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 
EFTA01116715

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 
hich 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 
EFTA01116716

95 
1 
2 
3 
4 
MS. McCAWLEY: I have a standing objection 
and, I'm objecting again. I'm not going to --
THE WITNESS: No, no, no. Does she have 
standing in this deposition? 
11:39:47 
11:39:49 
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. 
EFTA01116717

Exhibit 2 
EFTA01116718

180 
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. 
 
/ 
CONTINUED VIDEOTAPE DEPOSITION OF 
ALAN M. DERSHOWITZ 
VOLUME 2 
Pages 180 through 333 
Friday, October 16, 2015 
9:18 a.m. - 12:26 p.m. 
Cole Scott & Kissane 
110 Southeast 6th Street 
Fort Lauderdale, Florida 
Stenographically Reported By: 
Kimberly Fontalvo, RPR, CLR 
Realtime Systems Administrator 
www.phippsreporting.com 
(888)811-3408 
EFTA01116719

181 
183 
1 
APPEARANCES: 
1 
INDEX 
a 
2 
3 
On behalf of Mairatiflk 
Examination 
Page 
SEARCY. DENNEY, SCAROLA 
3 
4 
BARNHART & SHIPLEY. P.A. 
4 
VOLUME 2 (Pages 180 - 333) 
2139 Pain Beach Lakes Boulevatd 
S 
Direct 
By Mr. Scarola 
184 
s 
West Palm Beach, Florida 33402.3626 
BY: JACK SCAROLA ESQ. 
6
Certificate of Oath 
330 
6 
jingscarcybw.com 
Certificate of Reporter 
331 
7 
7 
Read and Sign Letter to Witness 
332 
8 
On behalf of Defendant 
Errata Sheet (forwarded upon execution) 
333 
9 
COLE. SCO1T & KISSANE. RA 
$ 
PLAINTIFF EXHIBITS 
Doieland Cate II - Sum 1400 
9 
10 
9150 South Dadeland Boukvard 
Miani, Florida 33156 
No. 
Page 
11 
BY: THONIAS EMERSON SCOTT— M. ESQ. 
thomasscon@sklegatrom 
10 
I 
Television Interview Transcript 
193 
12 
BY: STEVEN SAFRA. ESQ. (Via phone) 
11 
13 
stevensafra€esklepleont 
2 
Except from Deposition of Alan M. 
193 
14 
SWEDE R & RC6S. LLP 
12
Dershowitz
131 °titer Saco 
13 
3 Photograph - 8x10 - Color 
194 
15 
Boston. MA 02110 
14 
4 Photograph - 8x10 - Color 
197 
BY: KENNETH A. SWEDER, ESQ. 
15
5 Flight Log Information Sheet 
198 
16 
kswederensvinkerosneorn 
16 
6 Composite - Flight logs 
240 
18 
WILEY, REIN 
17
7 Composite - Flight manuals 
240 
17769 K Sava NW 
18 
8 Photograph - 8x10 - Color 
305 
19 
Washington. DC 20006 
19 
9 Composite - Calendar entries 
306 
20 
BY: RICHARD A SIMPSON. ESQ. 
RSimsongmikyreinecen 
20 
10 Composite - Calendar entries 
307 
BY: NICOLE A. RICHARDSON. ESQ. 
21 
II Compositc - Calendar entries 
307 
21 
nrichankoe44.40eyreincom 
22
12 Composite - Calendar entries 
307 
22 
23 
23 
24 
34
25 
25 
182 
184 
1
APPEARANCES (Continued): 
1 
VIDEOGRAPHER: Going on the record. This 
2 
On behalf of Jeffrey Epstein: 
2 
is day two of Alan Dershowitz's deposition. 
3 
DARREN K. INDYKE. PLLC 
3 
The date is October 16, 2015, and the time is 
575 Lexington Ave.. 4th Fl. 
4 
approximately 9:18 a.m. 
4 
New York, New York 
BY: DARREN K. INDYKE, ESQ. (Via phone) 
5 
MR. SCAROLA: Would you please reswear the 
5 
6 
witness. 
6
On behalf o 
7 
TILE COURT REPORTER: Would you raise your 
7 
BOWS. 
NER, LLP 
8 
right hand. please? 
401 E. 
, 
00 
9 
Do you swear or affirm that the testimony 
8 
Fort Lauderdale. Florida 33301 
10 
you arc about to give will be the truth. the 
9 
BY: SIGRID STONE MCCAWLEY, ESQ. 
smeeawley@bsfIlp.com 
11 
whole truth, and nothing but the nth? 
10 
12 
THE WITNESS: Yes. 
11
ALSO PRESENT: 
13 
Thereupon: 
12 
Joni Jones, Utah Attorney General Office 
14 
ALAN M. DERSHOWIT2 
13
Travis Gallagher, Videographer 
15 
having been first duly sworn, was examined and 
14 
16 
testified as follows: 
15 
16 
17 
DIRECT EXAMINATION 
17 
18 
BY MR. SCAROLA: 
18 
19 
Q. Mr. Dershowitz, what Is rhetorical 
19 
20 
hyperbole? 
20 
21 
A. Rhetorical means veibel and hyperbole 
21 
22 
22 
means exaggeration. 
23 
23 
4 Something other than the truth, correct? 
24 
24 
A. Truth--
25 
25 
MR. SCOTT: Objection. form. relevancy. 
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187 
1 
A. Truth has many, many meanings and is a 
1 
transcript of the interview? We'd like to see 
2 
continuum. The Supreme Court has held that 
2 
it. 
3
rhetorical hyperbole cannot be the basis• for 
1 
MR. SCAROLA: That's exactly what I gave 
4 
example, of perjury prosecutions or generally of a 
4 
you, the photocopy. 
5 
defamation prosecution. 
5 
MR. SCOTT: We're doing it right now. 
6 
So it depends on the context. You might 
6 
Maybe we can move on and conic back then. 
7
just look at the dictionary and probably get a 
7 
MR. SCAROLA: No, I would like to proceed. 
8
variety of definiticas for it. 
8 
MR. SCOTT: Then let's stop until I get a 
9 
BY MR. SCAROLA: 
9 
copy of it. Because he -- I want --
10 
Q. Well, what I'm concerned about, 
10 
MR. SCAROLA: I don't think that's 
11 
Mr. Dershowltz, Is not a dictionary definition. I 
11 
necessary because your client has told us that 
12 
want to know what your understanding of rhetorical 
12 
he has a superb memory and one of the things I 
13 
hyperbok Is. 
13 
would like to know is what he's able to recall. 
14 
And do you agree that pursuant to your 
14 
If he needs to refresh his memory. the 
15 
understanding of rhetorical hyperbole, It Is an 
15 
transcripts will be here in just a moment, but 
16 
exaggeration beyond the facts? 
16 
I don't want to delay going forward. 
17 
MR. SCO•IT: Objection, argumentative and 
17 
MR. SCOTT: Do you need the transcript to 
18 
compound, throe questions. 
18 
refresh your memory? 
19 
A. No.- 
19 
TIIE WITNESS: Well, I have no memory of 
20 
MR. SCOTT: You can answer. 
20 
what specifically I said on a particular day in 
21 
A. -- I would not agree with that definition. 
21 
a particular interview. 
22 
BY MR. SCAROLA: 
22 
MR. SCOTT: Since you hate a copy in front 
23 
Q. Okay. Then define it for us, if you 
23 
of him, why don't you just show him your copy 
24 
would, please. 
24 
then? Read the — ask your question and let 
25 
A. I think I have already. 
25 
him read it. 
186 
188 
1 
Q. I'm sorry, I missed the definition. Could 
1 
BY MR. SCAROLA: 
2
you tell us what rhetorical hyperbole is? 
2 
Q. Do you recall having been Interviewed on 
3 
MR. SCOTT: Objection, repetitious. He's 
3 
CNN Tonight by Don Lemon? 
4 
done it. 
4 
A. Ycs. I do. 
5 
A. Why don't we just read back my answer. 
S 
Q. Do you recall hating been interviewed on 
6 
BY MR. SCAROLA: 
6 
CNN Tonight by Don Lemon In early January of 2015, 
7 
Q. Because I didn't understand it, so I would 
7 
where you spoke about marten that have become the 
8
like you to try to give us a direct response to that 
8 
subject of thb litigation? 
9
question if you're able to. 
9 
A. Yes, I do. 
10 
A. I will repeat exactly that I said. A 
10 
Q. Did you make the following statement 
11 
rhetorical means verbal and hyperbole means some 
11 
during the course of that interview: "As to the 
12 
exaggeration of the facts for political or other 
12 
airplanes, there are manifests that will prove 
13 
reasons, but generally it is truthful in a literal 
13 
beyond any doubt that I was never on a private 
14 
sense but perhaps -- it all depends on context. 
14 
airplane with Ibis woman or ally other underage 
15 
And if you tell me the context in which I 
15 
girl"? 
16 
used it, I will be happy to describe what I meant in 
16 
MR. SCOTT: You need to see the 
17
that context. But I don't think you can really 
17 
transcript? 
18
answer a question about what two words put together 
18
THE WITNESS: No. No. 
19
mean without understanding the context. 
19 
A. That is a truthful statement. I would 
20 
Q. Okay. Well, we're going to talk about 
20 
repeat it right now. I've reviewed the manifests. 
21 
some context. 
21 
First, I know I was never on the airplane 
22 
Do you recall having been interviewed on 
22 
with any underage woman. I know that for a fact. I 
23
CNN Tonight on January 5, 2015? 
23 
have absolutelyno doubt in tny mind about that And 
24 
25 
A. I have no current recollection of --
MR. SCOTT: Do you have a copy of the 
24 
25 
the records that 
ant that. 
Thcy ha 
a number or 
3 (Pages 185 to 188) 
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189 
191 
1
airplane flights with Jeffrey Epstein. They have me 
1 
to the transcription, the official transcription of 
2
on a number of flights, none-- let me emphasize. 
2 
that testimony, was that, quote: 
3
none within the relevant time period, none within 
3 
"Let me emphasize that the manifests that 
4 
the relevant time period. That is. there are no 
4 
do exculpate me do not show me flying wit 
5
manifests that have me on Jeffrey E 
eon's airplane 
5 
not show me flying with a 
6
during the time t 
ants to 
6 
women." 
7 
have -- falsely c 
th me. 
7 
That was the testimony you gave under 
8 
So. yes, not only recall making that 
8 
oath. Do you stand by that testimony today? 
9
statement, but I repeat it here today. And it is 
9 
A. The manifests that I saw corroborate my 
10 
absolutely t 
what I know. 
10
own memory -- my own memory is as clear as could 
11
and that is t 
up the Mire 
11 
be— that I never saw any inappropriately aged, 
12 
story, 
12 
'Wagged women on any airplane to my knowledge that 
13 
BY MR. SCAROLA: 
13 
were visible to me at any time that I flew. That is 
14 
Q. Your Statement — 
14 
my testimony. yes. 
15 
MR. SCOTT: What page arc you reading 
15 
Q. Well, that's not a response to the 
16 
from? 
16 
question that I asked. Is it your testimony today 
17 
MR. SCAROLA: Page 5. 
17 
that you never flew on a private airplane with, 
18 
Q. Your statement was that you were never on 
18
quote, "any young women"? 
19
a private airplane with this woman, which I assume 
19 
MR SCOTr: Objection, foam 
20 
was a referc 
et 
20 
A. By young women, I obviously meant in Mat 
21 
A. It is, 
21 
context underage women. And underage women in the 
22 
Q. Or any other underage girl? 
22 
context of sexuality. And, yes, I — I stand by 
23 
A. Thai's right. 
23 
that statement. 
24 
Q. All right. How many times — 
24 
BY MR. SCAROLA: 
25 
A. Well, let me be very clear. I have no 
25 
Q. Affright So your — your elarificadon 
190 
192 
1
idea who was in the front cabin of the airplane with 
1 
of your earlier testimony is that you never saw any 
2
the pilots. Obviously what I intended to say and 
2 
young women in a sexual context? 
3
what I say here now is I never saw an underaged 
1 
A. Th3es not clarification. I think that's 
4 
person on an airplane. 
4 
what I initially said. That's what l initially 
S 
Now, when I — when I flew with Jeffrey 
5 
intended. And that's the way a ny reasonable — any 
6
Epstein to the launch, my recollection is that there 
6 
reasonable person would interpret what my original 
7
may have been a couple on the plane with their child 
7 
testimony was. So I don't believe my original 
s 
who was going to see the launch. But that was 
8 
testimony required anyclarification. 
9
certainly not the context in which I made the 
9 
Q, So what you meant to convey by the 
10
statement 
10 
statement that you made when you said you never flew 
11 
I never saw any underage, young person who 
11. 
with any underage girt or any young women was you 
12 
would be the subject or object of any improper 
12 
never flew with any underage girl or young women in 
13 
sexual activities. Had I seen Jeffrey Epstein ever 
13 
a sexual context? 
14
in the presence of an underage woman in a context 
14 
MR. SCOTT: Objection, Than. 
15
that suggested sexuality. / would have, A, left the 
15 
BY MR SCAROLA: 
16 
scene; B, reported it; and. C, never had any further 
16 
Q. Is that correct? 
17
contact with Jeffrey Epstein. 
17 
A. Let me simply repeat the fact and that is. 
18 
Q. You have also made the statement that you 
18 
to my knowledge. I never flew on an airplane or was 
19
were never on a private airplane with any underage 
19 
ever in the presence on an airplane with any 
20 
women or any young women, correct? 
20 
underage warn who would be somebody who might be in 
21 
A. Thc context was underage woolen in a sexual 
21 
a sexual context. I say that only to eliminate the 
22 
context. If it was a — you know, a four-year-old 
22 
possibility that some four-teat...3H was on the lap 
23 
child being carried by her mother. that would not be 
23 
of a mother or somebody was on the airplane with 
24
included in what I intended to say. 
24 
family members. 
25 
Q. Your sworn testimony yesterday, according 
25 
But, no, trio 001 recall — and flu very 
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193 
195 
1
firm about this — being on an airplane with anybody 
1 
A. I don't remember that I flew with her or 
2
who I believed could be the subject of Jeffrey 
2 
not. I may have. But I don't recall necessarily. 
3
Epstein or anyone else's improper sexual activities. 
3
But I did meet -- I remember meeting a woman named 
4 
MR. SCAROLA: All right Let's mark the 
4 
'is does not look like 
ke the 
5 
transcript that we've been referring to as 
5
woman I 'net. 
6 
Exhibit Number I, please. That's the 
6 
Q. Okay. So that's a — that's a different 
7 
transcript of the television interviews that 
7 
8 
we'll be discussing. 
8 
A. No, I don't know. 
9 
(Thereupon, marked as Plaintiff Exhibit 
9 
MR. SCOTT: Objection, fonn, 
10 
I.) 
10 
argumentative. 
11 
MR. SCOTT: This is actually 2. right? We 
11 
A. I have no idea. I do not recognize this 
12 
had one yesterday, an anicle from the British 
12 
woman. She's not familiar to inc at all. 
13 
newspaper? 
13 
I can tell you this: Without any doubt. I 
14 
MR. SCAROLA: No. It was not marked as an 
14
never met anybody dressed like this on any airplane 
15 
exhibit. This is the first exhibit that's been 
15
or in the presence of Jeffrey Epstein or in any 
16 
marked. 
16
Context — 
17 
MR. SCOTT: No. I know that, but I thought 
17
BY MIL SCAROLA: 
18 
we were going to mark that one. Maybe I was — 
18 
Q. Did she have -
19 
I asked for that. Okay. 
19 
A. -- related to this case. 
20 
It was an answer and counterclaim about 
20 
Q. — more clothes on or less clothes on when 
21 
the allegation shown to the witness. 
21 
you met her? 
22 
MR. SCAROLA: And Exhibit Number 2 will be 
22 
MR. SCOTT: Objection, form. He said he 
23 
the transcript from yesterday's proceedings 
23 
never met her. Misrepresent --
24 
that I have just referenced. 
24 
BY MR. SCAROLA: 
25 
(Thereupon marked as Plaintiff 
25 
Q. When you met the woman that you're 
194 
196 
1 
Exhibit 2.) 
1 
referencing, did she have more clothes on or less 
2 
MR. SCOTT: You don't have a copy of that, 
2 
clothes on than that wonmn? 
3 
do you, of the transcript? 
3 
A. Every woman that I met in the presence of 
4 
MR. SCAROLA: No. Got sent to you. I 
4 
Jeffrey Epstein was properly dressed. usually in 
5 
assume you have it. 
5 
suits and dresses and -- and appropriately covered 
6 
BY MIL SCAROLA: 
6 
up. I never met any women in the context of Jeffrey 
7 
Q. I'm going to hand you what we'll now mark 
7 
Epstein who weredossed anything like this. 
8
as Exhibit Number 3. 
8 
Q. Would you agree that that is a young woman 
9 
(Thereupon, marked as Plaintiff 
9 
in that photograph? 
10 
Exhibit 3.) 
10 
A I have no idea what her age is. 
11 
MR. SCOTT: There's no question. 
11 
Q. So you don't know whether she was underage 
12 
MR. SWEDER: Yes. 
12 
or overage or a young woman or not a young woman? 
13 
BY MR. SCAROLA: 
13 
A. I don't --
14 
Q. Do you recognize that young woman, 
14 
MR. SCOTT: Objection, form. 
15 
Mr. Dershowitz? 
15 
A. — know this wanan. so I have no idea how 
16 
A. No. 
16 
old a woman in a picture is. She could be — the 
17 
Q. Never saw her? 
17
could be 30. She could be 25. I have no ides 
18 
A. Not that I know of. 
18
BY MR. SCAROLA: 
19 
Q. Never flew on an private airplane with 
19 
Q. Or she could be 15 or 16? 
20 
her? 
20 
A. I don't think so. 
21 
A. Not that I know of. 
21 
Q. But you don't know? 
22 
Q. Do you recognize the name 
22 
A. This doesn't — well, I don't know how old 
23 
A. I do recall that Jeff 
Epstein had a 
23 
you arr. This does not strike me --
24 
friend 
24 
Q. Old enough to know that —
25 
Q. Thal you flew with? 
25 
MR. SCOTT: You're cutting --
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199 
1 
BY MR. SCAROLA: 
1 
ographs identify the woman as 
2 
Q. — that's a 
woman. 
2
t? 
3 
young 
MR. SCOTT: Objection. You're cutting the 
3 
4 
witness off. You're not letting him finish 
4 
MR. SCOTT: Mr. Dershowin, take your 
S 
A. This looks like a picture out of a Playboy 
5 
time --
6
or Penthouse magazine. It does not look to me like 
6 
TIIE WITNESS: Yeah. 
7
a person who is under the age of IE. or I? or IS. 
7 
MR. SCOTT: — review the exhibits. Dont 
8
But I don't think you can tell anything from the 
8 
be rushed by Mr. Scarola. 
9
picture. I think you can tell much more front 
9 
A. Yes, it's aditto:sent — different 
10 
meeting somebody and being with them and having a 
10 
spelling of the name. The Tatiana on the manifest 
11
conversation with them. 
11 
is spell 
12 
MR. SCAROLA: Let's mark this photograph. 
12 
Th 
ph is 
13 
if wc could, as Exhibit Number 4. 
13 
I have no idea whether — 
14 
(Thereupon, marked as Plaintiff 
14 
BY MR. SCAROLA: 
15 
Exhibit 4.) 
15 
Q. The last name -
16 
BY MR. SCAROLA: 
16 
A. — they arc the same person 
17 
Q. Does Exhibit Number 4 help you at all to 
17 
Q. — is the same, 
ht? 
18 
recognize this young woman? 
18 
A. There's no last name. 
19 
A. I've never -- I have no — no recollection 
19 
Q. Well, read down a little bit further. If 
20
of this young woman at all. 
20 
you would, Mr. Dershowitz. 
21 
All 
ht. Would 
describe for 
21
A. You mean as to a different flight? 
22 
Q. 
ri 
you 
us, 
please, the •
ou flew with Jeffrey 
22 
Q. Yes, sir. Identifying the return flight 
23
Epstein on November 17,2005? 
23 
for the sam 
24 
A_ First, I want to emphasize that that's 
24 
A. I have no idea that it's a return flight. 
25 
three years later than any of the issues involved in 
25 
I have nothing on the record that suggests that it's 
198 
200 
1 
this case. I have no recollection of
 with 
1
a return flight. And it has different people on it 
2 
this woman. I saw the name 
m a manifest. 
2 
So I have no reason to believe it's a return flight. 
3 
And my recollection of 
• I have 
3 
Q. Is the last — the question that I asked 
4 
no recollection c4
S 
with her, but my 
4 
you, Mr. Denhowitx, is: Is the last name spelled 
5 
recollection of 
is that she %usurious. 
5 
exactly the same as the last name is spelled in the 
6 
mid 20s woman friend ofleffrey Epstein, who I may 
6 
two photographs I have shown you? 
7 
have met on one cc two or three occasions when he 
7 
A. Let me look. So. on the 20th of 
8 
was with her in — perhaps at Harvard University 
8
November — 
9 
where he was meeting with academies and scholars. or 
9 
Q. Is the last name —
10 
mhos — II think lhars probably the comma 
10 
MR. SCOTT: Whoa. whoa --
11 
where — where she might have been. 
11 
BY MR. SCAROLA: 
12 
Q. But you never flew with her? 
12 
Q. — spelled the same way on both the flight 
13 
A. I have no recollection or flying with her. 
13 
log and the two photographs I have shown you? 
14 
Q. Okay. Well, let me see if this helps to 
14 
A. On — you mean on a flight log that I was 
15 
refresh your recollection, Mr. Denhowitz. 
15 
not on the flight? Is that right? You're talking 
16 
MR. SCAROLA: Let's mark this as Exhibit 
16 
about a flight log that I was not on the flight. 
17 
Number 5, please. 
17
right? 
18 
THE WITNESS: Uh-huh, yes. 
18 
Q. That flight log shows you on multiple 
19 
(Thereupon. marked as Plaintiff 
19
flights, does it not? 
20 
Exhibit 5.) 
20 
A. It shows me not on that flight. It shows 
21 
BY MR. SCAROLA: 
21 
me on a number of flights, but not on that flight. 
22 
Q. Do you see that the name of the woman In 
22 
MR. SCOTT: What's the date of the 
23 
v 
you b 
23 
flights? 
24 
Victoria Secrets model? 
24 
TOE WITNESS: The date of that flight 
25 
The photographs, sir, look 21 the 
25 
is -- looks like November 20th, 2005, more 
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I 
than three years aft 
len 
1 
BY MR. SCAROLA: 
2 
for -- 
2 
Q. Is the last name on the photograph spelled 
3 
BY MR. SCAROLA: 
3 
exactly the same way as the last name on the flight 
4 
Q. Mr. Dershowitz — 
4 
log? 
S 
MR. SCOTT: You're cutting the witness 
5 
A. If you're talking °beet a flight log that 
6 
off. 
6 
I was not on that flight, thc answer is yes. 
7 
MR. SCAROLA: Ile's not answering my 
7 
Q. All right. Thank you very much, slr. 
8 
question. Tom. 
8 
Now, that flight log also shows you flying 
9 
MR. SCOTT: Well - 
9 
repeatedly In the company of a woman named Tatiana 
10 
MR. SCAROLA: I want to know whether the 
10 
correct? 
11 
last name is spelled the same or it isn't 
11 
A. rye only seen one reference ha 
12 
spelled thc samc on the flight log marked as an 
12 
November I?. If you want to show me any other 
13 
exhibit and on the photographs. That's a very 
13 
references. Id be happy to look at than. 
14 
direct question. It calls for a vary direct 
14 
Q. All right, sir. Thank you. 
15 
yes or no response. 
15 
Let's go back to the —
16 
And this witness has demonstrated a clear 
16 
MR SCOTT: Are we done with this exhibit? 
17 
refusal to respond directly to direct 
17 
MR. SCAROLA: We are done with the 
18 
questions, which will result, when we resume 
18 
exhibit. 
19 
this deposition, in our requesting that the 
19 
MR. SCOTT: Okay. Then let's collect the 
20 
Court appoint a special master so that this 
20 
exhibits so that we don't have a big — then 
21 
deposition doesn't take two weeks to complete. 
21 
well turn them over to the court reporter to 
22 
MR. SCOTT: You know, Mr. Scarola, that's 
22 
keep safekeeping. 
23 
a nice speech and I appreciate it. 
23 
That you go, young lady. don't Rise 
24 
MR. SCAROLA: Thank you. 
24 
those, don't get than wet. And well proceed. 
25 
MR. SCOTT: I don't agree with your 
25 
202 
204 
1 
characterization. And if you recall. months 
1
BY MR. SCAROLA: 
2 
ago I suggested a special master for this 
2 
Q. Did you state during the same Inteniew, 
3 
lients' depositions and 
3
the CNN Don Lemon interview: "She has said that 
4 
f 
and your response to me 
4 
Bill Clinton was with her at an orgy on Jeffrey's 
5 
was: I'll consider it, I won't pay far it. If 
5 
island"? 
6 
your client wants to pay for it -- so basically 
6 
A. I did state that. yes. 
7 
you blew me off. 
7 
Q. Was that statement intended as fact, 
8 
So. I appreciate you finally come around. 
8 
opinion, or was it Intended as rhetorical hyperbole? 
9 
And your clients. 
9 
MR. SCOTT: Do you understand the 
10 
MR. SCAROLA: Your client's misconduct has 
10 
question? 
11 
clearly convinced me, having now considered it, 
11 
THE WITNESS: Yes, I do. 
12 
that it is absolutely necessary. 
32
A. It was a statement based on what I 
13 
MR. SCOTT: Okay. Now -- 
13 
believed were the facts at the time I said them. 
14 
BY MR SCAROLA: 
14 
Various newspapers and Hogs had placed 
15 
Q. So now could I get an answer to my 
15 
Bill Clinton on, quote, 'orgy island" on -- in the 
16 
question — 
16
presence ofJeffrey Epstein when there were orgies. 
17 
MR. SCOTT: Now that we have -- 
17
And at the time I made that statement, I had a 
18 
BY MR. SCAROLA: 
18 
belief that she had accused Bill Clinton of 
19 
Q. — whether the last name on the flight log 
19
participating or being -- as being a part of cr an 
20 
is spelled exactly the same way as the last name in 
20
observer or -- or a witness or a participant in 
21 
the photographs? 
21 
orgies on what was called Jeffrey Epstein's orgy 
22 
MIL SCOTT: Nov that all the lawyers 
22 
island. That was my state of belief, honest belief 
23 
speeches arc done, read the question back and 
23 
at the time I made that statement. 
24 
the witness will answer it. 
24 
BY MR_ SCAROLA: 
25 
MR. SCAROLA: I will repeat the question. 
25 
Q. Yes, sir. And What I want to know is what 
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1 
the source of that honest belief was? Identify any 
2 
source that attributed to 
.he 
3 
statement that Bill Clinton was with her at an orgy 
4 
on Jeffrey's island. 
5 
A. We can provide you about, I think, 20 
6 
newspaper articles and blogs which certainly raise 
7 
the implication that Bill Clinton had improperly 
participated in sexual activities on the island 
9 
either as an observer or as a participant. The 
10 
issue was raised on Sean Hannitys program. The 
11 
headlines in various British media had suggested 
12 
that 
13 
It's my belief th 
14 
intended to convey that [monism 
was 
15 
trying to sell her story to various media, which she 
16 
successfully sold her story to in Britain. that she 
17 
wanted to keep that open as a possibility. 
18 
And then when I firmly declared, based on 
19 
my research, that Bill Clinton had almost certainly 
20 
never been on that island, she then made a finn 
21 
statement that she -- which was a -- which was a 
22 
perjurious statement, a finn penurious statement 
23 
saying that although Bill Clinton had been with her 
24 
on the island and had had dinner with her, the 
25 
perjurious statement was that Bill Clinton had been 
207 
Clinton on orgy island, things of that kind. I 
2 
would be happy to provide than for you. I donl 
3 
have them on the top of my head. 
4 
Q. There's a big difference between saying 
5 
that Bill Clinton was on Jeffrey's Island and saying 
6 
that Bill Clinton was at an orgy on Jeffrey's 
7 
Island, isn't there? 
8 
MR. SCOTT: Objection --
9 
BY MR. SCAROLA: 
10 
Q. Do you recognize a distinction between 
11 
those statements? 
12 
MR. SCOTT: Font 
13 
A. I don't think that distinction was ekarty 
19 
drawn by the media. 
15 
BY MR. SCAROLA: 
16 
Q. I'm asking whether you recognize the 
17 
distinction? 
18 
A. Oh. I -- I certainly recognize a 
19 
distinction. 
20 
Q. Oh, so — 
21 
A. Let me finish. I certainly recognize a 
22 
distinction between Bill Clinton being on the 
23 
island, which I believe she perjuriously put in her 
24 
affidavit. and Bill Clinton participating actively 
25 
in an orgy. I also think it's a continuum. 
206 
1 
on the island with her. 
2 
The lie was that she described in great 
3 
detail a dinner with Bill Clinton and two underaged 
4 
Russian women who were offered to Bill Clinton for 
S 
sex but that Bill Clinton turned down. 
6 
So she then put in her affidavit that 
7 
although -- perjuriously, although she had seen Bill 
8 
Clinton on that island, she then stated that she had 
9 
not had sex with Bill Clinton. To my knowledge, 
10 
that was — to my knowledge at least, that was the 
11 
first time she stated that — that she not had sex 
12 
with Bill Clinton. She had certainly implied, or at 
13 
least some of the media had inferred from her 
14 
statements that she may very well have observed Bill 
15 
Clinton in a sexually compromising position. 
16 
So, when I made that statement to Don 
17 
Lemon. 1 had a firm belief, based on reading 
18 
newspaper accounts and blogs. that it was true. 
19 
Q. Canyouidentify a
le newspaper that 
20 
attributed 
 the statement that 
21 
Bill Clinton was with her at an orgy on Jeffrey's 
22 
island? 
23 
A. I think there -- I don't have them in my 
24 
head right now. But I do recall reading headlines 
25 
that talked about things like, sex slave places 
208 
1 
And there is the possibility, which I 
2 
don't personally believe to be true, that he was on 
3 
the island. There was the possibility, which I 
4 
don't believe to be true, that he was on the island 
5 
when orgies were taking place. There was the 
6 
possibility that he was on the island and observed 
7 
an orgy, and there was the possibility that hens 
8 
on the island and participated in on orgy. 
9 
Newspapers picked up those stories. Ill 
10 
give you an example of a newspaper that actually 
11 
said that that she had placed or that I was on the 
12 
island and -- that I participated in an orgy along 
13 
with Stephen Hawkings {sic.), the famous physicist 
14 
from Cambridge University, that was a newspaper 
15 
published in the Virgin Islands, which falsely 
16 
claimed that I was at an orgy with Stephen Hawkings. 
17 
So. many newspapers were suggesting, 
18 
implying, and I infened from reading those 
19 
newspapers that that's what she had said to the 
20 
media. 
21 
If I was wrong about that based on 
22 
subsequent infonnatiai. I apologize. But I 
23 
certainly, at the time I said it. believed it and 
24 
made the statement in good faith in the belief that 
25 
it was an honest mammal. 
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1 
Q. Okay. So you now are withdrawing the 
1 
Your client is doing everything he can to avoid 
2
statement that you made tha 
d 
2 
giving direct answers to these questions. 
3
that Bill Clinton was with h 
3 
I would appreciate it if you would take a 
4
Jeffrey's island; that was wrong? 
4 
break, counsel your client that the speeches 
5 
A. I don't know whether she ever said that 
5 
arc not helpful to anyone, and especially not 
6
!would not repeat that statement and have not 
6 
helpful to him. 
7 
repeated that statement based on her denial. As 
7 
MR. SCOTT: If you want to take a break, 
8
soon as she denied it, I never again made that 
8 
I'll take a break and I will advise my client 
9
statement and would not again make that statement 
9 
whatever I feel is appropriate, not what you 
10 
Q. You — 
10 
instruct me to do. 
11 
A. But I did reiterate the fact that she 
11 
MR. SCAROLA: Okay. Well, if you think it 
12 
committed perjury when she said she was on the 
12 
might help at all in the progress of this 
13
island with Bill Clinton. 
13 
deposition, then I do want to take a break. If 
14 
MR. SCAROLA: Move to strike the 
14 
you don't think taking a break would be 
15 
nonresponsive -. 
15 
helpful, I don't want to take a break. 
16 
A. That was the perjurious statement. 
16 
MR. SCOTT: Do you want to take a break or 
17 
MR. SCAROLA: Move to strike the 
17 
not? 
18 
nonresponsive portions of the answer. 
18 
THE WITNESS: I'm going to leave it to 
19 
BY MR. SCAROLA: 
19 
your judgment. I'm happy to proceed --
20 
Q. You have made a reference during 
a 
a 
20 
MR. SCOTT: Okay. I'll be glad to take a 
21
N Interview to this woman, referring i 
21
break.
22 
ing a criminal record? 
22 
MR. SCAROLA: Thank you. 
23 
A. 
t's right. 
23 
MR. SCOTT: I can't say - 
24 
Q. Okay. What — what is a criminal record? 
24 
MR. SCAROLA: Five minutes. 
25 
A. Well• the way I used the term is that she 
25 
MR. SCOTT: -- it will help you or 
210 
212 
1
committed a crime and legal -- some kind of 
1 
anything but --
2 
proceedings resulted from her committing a crime. 
2 
MR. SCAROLA: I can understand that you 
3
The crime she committed was stealing money from a 
3 
don't — you don't have that control, but if 
4 
restaurant that she worked at while she was also 
4 
there's any reasonable --
5 
working for Jeffrey Epstein. And it was my 
5 
MR. SCOTT: You know, Counsel --
6 
information that there was a criminal record of her 
6 
MR. SCAROLA: -- prospect that it might 
7
theft. 
7 
help, let's give it a try. 
8 
Q. How old was she at the lime this alleged 
8 
MR. SCOTT: You know, I really don't 
9 
offense occurred? 
9 
appreciate thecomments about my abilities as 
10 
A. I don't know. But old enough to be held 
10 
an attorney, like I don't have that control and 
11 
criminally responsible in the State of Florida. to 
11 
things of nature. It really is —
12
my knowledge. To my knowledge, I— I recall a case 
12 
MR. SCAROLA: I don't have the control 
13 
where a I4-year-old boy was sentenced as an adult 
13 
either. 
14 
for -- 
14 
MR. SCOTT: It's not --
15 
MR. SCAROLA: Mr. Scott — 
15 
MR. SCAROLA: I'm not trying to disparage 
16 
A. — a serious -- 
16 
you at all in any respect. I'm just suggesting 
17 
MR. SCAROLA: — did my question ask 
17 
that --
18 
anything about a I4-year-old boy'? 
18 
MR. SCOTT: Okay. 
19 
A. You asked if -- 
19 
MR. SCAROLA: -- there is reason to doubt 
20 
MR. SCAROLA: Do we really need to listen 
20 
that it will do any good. But I want to give 
21 
to this? 
21 
it a try. 
22 
MR. SCOTT: You're asking questions, my 
22 
MR. SCOTT: Okay. Fine. Thank you. 
23 
client is providing his response. 
23 
MR. SCAROLA: Thank you. 
24 
MR. SCAROLA: No your client is not 
24 
VIDEOGRAPHER: Going off the record. The 
25 
responding Your client is filibustering 
25 
time is approximately 9:49 a.m. 
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215 
1 
(Recess was held from 9:49 a.m. until 10:01 am) 
1 
Q. That would certainly have been prior to 
2 
VIDEOGRAPHER: Going back on the record. 
2
February 23rd of 2015, correct? 
3 
The titer is approximately !R0I a.m. 
3 
A. Yes. 
9 
MR. SCOTT: ifyou've finished your bagel 
4
MR. SCOTT: Are you going back to the 
5 
we're ready to proceed. I think. 
5 
exhibit now with the newspapers and --
6 
MR. SCAROLA: I think we arc. I was 
6 
MR. SCAROLA: Not yet. 
7 
actually ready to proceed a little bit earlier, 
7 
MR. SCOTT: Okay. 
8 
but we'll proceed now. 
8 
BY MR. SCAROLA: 
9 
BY MR. SCAROLA: 
9 
Q. Having reviewed the available airplane 
10 
Q. Mr. Dershowltz, do you agree with the 
10
flight logs, you are aware that Bill Clinton flew on 
11 
basic concept that one is presumed to be Innocent 
11
at least 15 occasions with Jeffrey Epstein on his 
12 
until proven guilty? 
12 
private plane, correct? 
13 
A. Yes 
13 
A. Yes. 
14 
Q. Ha 
:or been proven to 
14 
Q. Have you ever attempted to get flight log 
15
be guilty o any crime a any me, anywhere, at any 
15 
information with regard to Former President 
16 
age? 
16
Clinton's other private airplane travel? 
17 
A. I don't know the answer to that question, 
17 
A. No. 
18 
bee I do know that she was brought into the legal 
18 
Q. Never made a public records request —
19 
system for stealing money from her employer and 1 
19 
A. Yes. 
20 
think ifs fair to characterize that as her having a 
20 
Q. — under the Freedom of Information Act 
21
criminal record. yeah. 
21 
with regard to those records? 
22 
Q. To the extent that anyone m tht interpret 
22 
A. Well we have made a Freedom of 
23
your comment tha 
was ever 
23
Information request. My -- my attorney in New York. 
24 
convicted of a crime, they would be drawing a false 
24 
Louis Reek the former head of the FBI, has made a 
25
conclusion as far as you know, correct? 
25 
FOIA request for all information that would 
214 
216 
1 
A. As far as I know. I don't know of her 
1
conclusively prove that Bill Clinton was never on 
2 
having convicted of any crime. But I do know that 
2 
Jeffrey Epstein's island, yes. 
3
she was proceeded against for having stolen money. 
3 
Q. And you were denied those records, 
4
And I don't think she contested that. I don't think 
4 
correct? 
5 
there's any dispice about the fact that she stole 
s 
A. No, no, no. 
6 
money and engaged in other crimes as well. 
6 
Q. Oh, you got them? 
7 
Q. When did you find out about this alleged 
7 
MR. SCOTT: Well wait a minute. Let's 
8
crime? 
8 
take it slow. Ask a question. 
9 
A. As soon as the false allegation against MC 
9 
A. As any lawyer knows, FOIA requests take a 
10 
was made public, I got call after call after call 
10 
long, long period of time. So they were neither 
11 
from people telling me about 
. about 
11
denied nor were they given to us. They ate very 
12 
your 22 clients. The calls ju 
m g in 
12 
much in process. 
13 
because there was such outrage at diis false 
13 
BY MR. SCAROLA: 
14 
allegation being directed against tm. 
14 
Q. When was — 
15 
MR. SCAltOIA: Move to strike the 
15 
A. While we're talking about -- may I 
16 
unresponsive portion of the answer. 
1 6 
complete -- I want to amend one answer I gave 
17 
BY MR. SCAROLA: 
17
previously. 
18 
Q. You found out as soon as the CVRA 
18 
While we're talking about the plane logs. 
19 
complaint was — the CVRA allegations referencing 
19
I must say that during the rims, my wife Googled 
20 
you were filed; is that correct? 
20
Tatiana and found out that she was, in fact, 24 
21 
A. I didn't say that. I said as soon as they 
21 
years old in 1995, at the lime she flew on that 
22 
were made public and as soon as the newspapers 
22 
airplane. So that my characterization of her as 
23 
carried these false stories, I received phonecalls 
23 
about 25 years old is absolutely correct. 
24 
and I teamed about -- I learned about her encounter 
24 
And the implication that you sought to 
25 
with the criminal justice system. 
25
draw by showing me those pictures was not only 
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1 
demonstrably fake, but you could have easily 
1
she has a history of lying, knowing that she is 
2 
discovered that the implication you were drawing was 
2
easily suggestible, and they basically pressured 
3 
demonstrably false by simply taking one second and 
3
her, according to my sources, into including me when 
4 
Googling her name as my wife did. 
4
she didn't want to include me. because by including 
5 
BY MR. SCAROLA: 
5
me, they could make a claim, false as it was, could 
6 
Q. And so at 25 years old, she wasn't a young 
6
make a false claim that a person who negotiated the 
7 
woman? 
7
NPA was also criminally involved with her. 
8 
A. She was not the kind of woman that I was 
8
They also lied — lied unethically and 
9
describing as underage. She was a mature, serious, 
9
unprofessionally by saying that I negotiated that 
10 
I think I said in my public statements a model. I 
10 
provision of the NM. which gave me, myself, any 
11 
wasn't aware at the time that see was Viorking for 
11
kind of • 
' 
cation had I had improper 
12 
Victoria's Secrets, but Google demonstrates that. 
12 
Sex wit 
vhich, of course, I did 
13
And I described her exactly, in exactly the right 
13 
not. And t t was ascot 
bases on which I was 
14 
tams, a serious person. 
14 
certain that they had engaged in unprofessional. 
15 
I always saw her domed when I saw her — 
15
disbarrable and unethical conduct by including that 
16 
I saw her maybe on two or three occasions. dressed 
16 
provision, as well as including a provision that 
17
appropriately. She was a serious adult worker and I 
17
Prince Andrew was included because he, Prince 
18 
think you insult and demean her when you suggest 
18
Andrew, pressured a United States attorney to try to 
19 
that anything other than that she was a serious 
19
get a good deal for Jeffrey Epstein. 
20 
adult when she flew on that airplane. 
20 
That is so laughable. How any lawyer 
21 
Q. You were asked on the occasion of that 
21 
could put that in a pleading. it doesn't pass even 
22 
same Don Lemon CNN Interview what possible motive 
22 
the minimal giggle test. And I'm embarrassed for 
23 
the attorneys, Brad Edwards and Paul Cassell, could 
23 
Professor Cassell that he would have signed his name 
24 
have had to have identified you in the pleading that 
24 
to a pleading that alleges that Prince Andrew would 
25 
was filed in the Crime Victim's Rights Act case. 
25
pressure the United States attorney for the Southern 
218 
220 
1 
Do you remember that? 
1 
District of Florida into giving Jeffrey Epstein a 
2 
A. That's right. yes. 
2 
good deal. 
3 
Q. And your response was, quote — 
3 
MR. SCAROLA: Mow to strike the 
4 
MR. SCOTT: Here's your transcript if you 
4 
unresponsive portions of the answer. And 
5 
need to rekr to it. 
5 
obviously the break didn't do any good. 
6 
BY MR. SCAROLA: 
6 
MR. SCOTT: Let's proceed. 
7 
Q. — "They want to be able to challenge the 
7 
MR. SCAROLA: We're going to. 
8 
plea agreement and I was one of the lawyers who 
8 
BY MR. SCAROLA: 
9 
organized the plea agreement. I got the very good 
9 
Q. You stated, quote: "If they," referring 
10 
deal for Jeffrey Epstein." 
10 
to Bradley Edwards and Paul Cassell, "could find a 
11 
Did you make that response? 
11 
lawyer who helped draft the agreement" —
12 
A. Yes. 
12 
A. Right. 
13 
Q. So, you recognized as of January 5, 2015. 
13 
Q. — "who also was a criminal having sex, 
14 
that the reason why the statements were filed in the 
14 
wow, that could help them blow up the agreement." 
15 
Crime Victim's Rights Act case wits because the Crime 
15 
Did you make that statement on --
16 
Victim's Rights Act case had, as an objective. 
16 
A. Yes. I just repeated it now, yea- under 
17
setting aside the plea agreement that you had 
17 
oath, yes. 
18 
negotiated for Jeffrey Epstein. correct? 
18 
Q. Did you state the following in that same 
19 
MR. SCOTT: Objection, form. Go ahead if 
19 
interview: "So 
• " 
' 
dley Edwards, 
20 
you can answer it. 
20 
Paul Cassell an 
at down 
21 
A. There were multiple motives. One of the 
21 
together, the three o t ern, I ese two sleazy. 
22 
motives was crassly financial. They ware trying to 
22 
unprofessional disbarrable lawyers" — 
23 
line their pockets with money. But as I also said. 
23 
A. Uh.huh, uh-huh. 
24 
and I said this over and over spin, they profiled 
24 
Q. — "they said" —
25 
me. They sat down with their client, knowing that 
25 
MR. SCOTT: Let him ask the question. 
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221 
223 
1 
1
who made transcripts of them. 
2 
BY MR. SCAROLA: 
2 
Q. Did you turn them over to opposing 
3 
Q. — "who would tit Into this description? 
3 
counsel —
4 
They and the woman got together and contrived and 
4 
MR. SCOTT: The transcripts — 
5 
made this up." 
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BY MR. SCAROLA: 
6 
Did you make that statement on national 
6 
Q. — in the course of discovery? 
7
television? 
7 
MR. SCOTT: The transcripts we consider to 
8 
A. Yes, and I just repeated it under oath. I 
8 
be work product. If you make a request to 
9 
believe that to be the ease. I think that's exactly 
9 
produce, we'll provide them. 
10 
what happened. And I think that my source has 
10 
MR. SIMPSON: Just for completeness, they 
11 
corroborated that. 
11 
were also after your discovery request. 
12 
By the way, can I add at this point -- I 
12 
MR. SCOTT: Request to produce, we'll 
11
don't mean to distract you, but I think the record 
13 
consider providing them. 
14
would be more complete if I indicated that I did get 
14 
BY MR. SCAROLA: 
15 
a phone call last night from Michael, who told me 
15 
Q. Is there an entry in any privilege log 
16
17 
that 
' 
3 
S phone calls and texts 
r 
eying to persuade her not to 
17 
16 
that identifies these allegedly privileged work 
product documents? 
18 
talk to me or cooperate with me and offering the 
18
MR. SIMPSON: We will -- the lawyers will 
19
help of a lawyer. 
19 
address the document production issues. But 
20 
And I also -- although you didn't ask the 
20 
two things, Mr. Scarola, first, they postdate 
21
question. Mr. Scarola, I think for completeness and 
21
your request and you have said several times 
22 
fullness, I do want to say that you asked me whether 
22
there's no duty to supplement. And second, 
23 
or not I knew about what could be taped and what 
23
they're work product. 
24 
did tape record some of what 
24 
MR. SCAROLA: Well, sir, if they postdated 
25 Illiec.] 
told me, with ha 
25
a full and complete production, which we are 
222 
224 
1 
permission, and I have those tape recordings. 
1 
now told they do not, then you wouldn't be 
2 
Q. Well, you're getting a little bit 
2 
obliged to supplement the production that had 
3 
overexcited, Mr. Derr 
ver tape 
3 
already been completed. But it is not the dale 
4 
recorded any 
Id you. 
4 
of the request that matters, it is the date of 
5 
A. Did I 
5 
the production that matters. 
6 
Q. You 
6 
And what we're now being told is there arc 
7 
A. I misspoke. You wouldn't know that. But, 
7 
allegedly highly relevant transcripts of a 
8 
in fact, let me be clear. 
8 
telephone conversation that occurred months ago 
9 
I tape recorded, with her permission, 
9 
when the last production that we received, 
10 
Rebecca's statements to me about whit Virginia 
10 
which we arc told still is not complete, 
11 
Roberts had told her. And I just want to make sure 
11 
occurred approximately two weeks ago 
12 
that for completeness, even though you didn't ask 
12 
So, there's no privilege log entry. 
13 
the question yesterday. that's part of the record. 
13 
There's no production of these documents. And 
14 
Q. WeILI actually did ask the question and 
14 
there is clearly a very significant discovery 
15 
my recollection is that you said you didn't even 
15 
violation if. in fact, such documents exist. 
16 
think about cape recording anything— 
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MR. SIMPSON: I'm not going to debate it 
17 
MR. SCOTT: No, that's not accurate. You 
17 
here. Mr. Scarola, but your assertions arc not 
18 
never asked that. 
18 
accurate. 
19 
BY MR. SCAROLA: 
19 
MR. SCAROLA: All right. There also was a 
20 
Q. But can you tell us, please, did you turn 
20 
subpoena duces tecum that was responded to 
21 
over those tape recordings In the discovery that you 
21 
tomorrow — l'in sorry, yesterday. Can you tell 
22 
were required to make In this case? 
22 
us whether the documents that are now being 
23 
A. The discovery — these events occurred 
23 
described arc included in response to the 
24 
after April of 2015. And I certainly aimed ma 
24 
subpoena duces tecum on the flash drive that 
25 
the recordings and the-- recordings to my lawyers. 
25 
you provided to us? 
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1 
MR. SIMPSON: The flash drive is the same 
2 
as the document production. 
3 
MR. SCAROLA: So the answer is no, they're 
4 
not there; is that correct? 
MR. SIMPSON: Correct. 
6 
MR. SCAROLA: Okay. And what's the 
7 
explanation for that? 
MR.. SIMPSON: I'm not going to debate this 
9 
on the record with you, Mr. Scarola. 
10 
MR. SCAROLA: All right. Thank you. 
11 
BY MR. SCAROLA: 
12 
Q. Which conversation with Rebecca did you 
13 
tape record? 
14 
A. I tape recorded a conversation with her 
15 
permission where she told me that she was pressured, 
16 
she didn't — where Rebecca told me that Virginia 
17 
was pressured and that she didn't want to name me 
18 
but she was pressured to name me, that she had never 
19 
previously named me. 
20 
By the way, I told this to Virginia 
21 
Roberts' lawyer. 
22 
MS. MCCAWLEY: Objection. To the extent 
23 
you're going to reveal anything that was said 
24 
during settlement discussions, I'm moving for 
25 
sanctions, period. We're not doing this today. 
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3 
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227 
A. I know what you know because I'm a logical 
t Virginia — I know that 
Sly called this 
this 
nd, rc 
knows her name. And you a 
lawyers are operating in psiv 
whispering to each other, you're passing notes You 
arc part of a joint legal team 
And if you want to know ha name, all you 
have to do is ask Sigrid McCawley and she'll tell 
you her name. I'm sure you know her name. And if 
you don't know ha name, it's became you haven't 
asked. 
Q. Okay. Well, I'm asking you —
A. fm not going to tell you -• 
Q. — and I'm telling you I don't know her 
name. 
A. Okay. 
Q. Okay? As an officer of the court, l am 
telling you I don't know her name. And you are 
under oath and obliged to answer material and 
relevant questions, and I want to know what her name 
is. 
MR. SCOTT: I will provide you the name 
off the record, but fin not -- if he feels it's 
226 
1 
Please ittstma the witness. 
2 
MR. SCOTT: Avoid that. We discussed that 
3 
yesterday. 
4 
THE WITNESS: That's line. 
BY MR. SCAROLA: 
6 
Q. What was the date of the phone 
7 
conversation that you tape recorded? 
8 
A. I don't recall. But it's on the 
9 
transcript. 
10 
Q. And does It also reflect that the 
11 
recording is being made with her permission? 
12 
A. Uh-huli. 
13 
Q. That's a yes? 
14 
A. Yes. Yes, that's a yes. 
15 
Q. What is Rebecca's last name? 
16 
A. You know Rebecca's last name and she has 
17 
asked me not to reveal it to the press. And so I 
18 
would like to comply with that 
with that request. 
19 
For purposes of discovery, you know her name, you 
20 
know her husband's name. you know her phone number, 
21 
and she has been called. But there's no reason for 
22 
tic to reveal it so that it appears in the press that 
23 
she would be called by newspapers and by the media. 
24 
Q. Mr. Dershowirs, how do you know what I 
25 
know if you haven't told me? 
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228 
inappropriate because of what — he's not going 
to answer the question. I will provide you the 
name. 
BY MR. SCAROLA: 
Q. Okay. She has still insisted that her 
name not be revealed; is that correct? 
A. I ler husband asked me to do whatever I 
could not to put her name in front of the press, in 
front of the media. 
Q. There's no — there's no one from the 
press here today. 
MR. SCOTT: Yeah, but they're going to 
order the transcript and they're going to see. 
so that's the same thing. And I've already 
told —
A. You will have her name in five --
MR. SCOTT: I will give you her Rome —
A. 
minutes. All you have to do is —
MR. SCOTT: And. Jack. if you want to take 
a break now — 
THE REPORTER: Hold on. Hold on, 
gentlemen. You can't talk at the same time. 
MR. SCOTT: Let me do the talking at this 
point. 
TIIE WITNESS: Please. 
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229 
2 3 ' 
1 
BY MR. SCAROLA: 
1 
moreaccomplished. 
2 
Q. What's her phone number? 
2
MR. SCAROIA: Let's take it easy and slow. 
3 
A. Ha phone number is kno 
. . . 
3 
BY MR. SCAROLA: 
4
Roberts and presumably- and to 
4 
Q. How did Michael ten you he knew these 
5 
roved ph 
5 
people he didn't speak to were lawyers? 
6 
So all you have to do is 
6 
vela phone call 
7 
you will get that. But I 
7
ft 
his wife recchal 
8
think there's no reason to put her phone number in 
8
n 
from her all through 
9
the public record so that she will receive massive 
9 
the night. And that they received phone calls as 
10
amounts of phone calls from the media. Scans to me 
10 
well from ha lawyers. One of them had a Miami 
11
that any — that a judge would try to prevent that 
11 
phone number. 
12 
from happening. I would hope so. And I'm — you 
12 
And I don't know how he knew they were 
13
can get the name and the phone minter from my lawyer 
13 
lawyers. But that's what he conveyed to me. All I 
14 
as long as it's -- 
14 
can tell you is what he told me, and I'm telling you 
15 
MR. SCOTT: We'll provide that. 
15 
that. 
16 
A. -- done off the record, not so that the 
16 
Q. Did you ask him for the phone number? 
17
twedia can see iL 
17 
A. I did not. 
18 
BY MR. SCAROLA: 
18 
Q. Why not? 
19 
Q. You just swore under oath that lawyers 
19 
A. I didn't think it was appropriate or 
20
contacted Rebecca; is that correct? 
20 
necessary. 
21 
A. I swore wider oath that I was told by 
21 
Q. What was Inappropriate about asIdng for 
22 
Michael that lawyers contacted Rebecca, yes. 
22 
the phone number to find out who was attempting to 
23 
Q. Which lawyers? 
23 
contact this witness? 
24 
A. I don't know the answer to that. 
24 
A. I was not particularly interested in that. 
25 
Q. Did you ask him? 
25 
All I was interested in was getting the truth from 
230 
232 
1 
A. I did. 
1 
the witness and trying to prevent her from having a 
2 
Q. And he said, I — 
2 
media banage that would interfere with their hies. 
3 
A. Ile wouldn't answer that. 
3 
Q. You told Don Lemon on CNN that the flight 
4 
Q. — refuse to tell you? 
4 
manifests would exonerate you, prove that you were 
5 
A. No, he didn't know the answer to that 
5 
not In the same place at the same time as Virginia 
6
either because he didn't return the phone calls. Ile 
6 
Roberts. correct? 
7
said -- 
7 
A. That's right. And that's true. 
8 
Q. How did he know they were lawyers if he 
8 
Q. You also told Don Lemon. quote, "I am 
9
didn't return the phone calls? 
9
waiving the statute of limitations or any immunity." 
10 
A. Because they len messages, presumably. 
10 
A. That's right. 
22 
Q. With names that identified them as 
11 
Q. You were then subsequently asked to waive 
12 
lawyers; is that right? 
12 
the statute or limitations and refined to, correct? 
13 
MR. SCOTT: You're arguing with the 
13 
A. Absolutely false. 
14 
witness-- 
14 
I waived the statute of limitations by 
15 
A. I don't know the answer to that. 
15 
submitting a statement under oath. Had I not 
16 
MR. SCAROLA: No, fm trying to find out 
16 
submitted that statanent under oath. the statute of 
17 
whether there's any logical basis for the 
17
limitations would have been long gone. But by 
18 
stories that the witness is telling. 
18 
stating wider oath categorically that I did not have 
19 
MR. SCOTT: And I think he's trying to 
19
any sexual contact with her, I waived the statue of 
20 
explain it. And I think he's trying to do it 
20 
limitations and could be prosecuted for the next 
21 
in an easy. slow format. So, you blow -- 
21 
five or so years for perjury in what I said was 
22 
MR. SCAROLA: Okay. Well, let's take it 
22 
false. 
23 
easy- 
23 
But what I said was true. SO I have no 
24 
MR. SCOTT: -- if we all take — if we all 
24 
fear of any statute of limitations or any criminal 
25 
take the tension down here, maybe we can get 
25 
prosecution. So, yes. 
I
 
did waive the statute of 
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