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1 
BY MR. SCAROLA: 
2 
Q. Of the lint page of this composite is 
3 
that there is a notation that says Alan Dershowitz 
4 
II:45 a.m., New York City, right? 
5 
A. Eleven -- A.D. I I A5 and then there's a 
6 
word that I can't read 
7 
Q. How about a.m.? 
8 
A. Oh, 5:00 a.m.. New York City. yes. 
9 
Q. Okay. Thank you, sir. 
10 
And the next page, where did — where did 
11 
your wife have opera instructions? 
12 
A. I have no idea. We go to the opera in 
13 
Boston, we go to the opera in New York, we go to the 
14 
opera in Florida. We do a lot --a lot of opera. I 
15 
don't know what "opera instructions' means. 
16 
Maybe it would be best if you asked my 
17 
wife about these things. It's her calendar. 
18 
Q. I — I Intend to, sir, but — 
19 
A. Sure. 
20 
Q. — these are calendars that you produced 
21 
as part of the evidence that you contend exonerates 
22 
you. So, I assumed that you had some knowledge of 
23 
the meaning of these pages. 
24 
A. No. 
25 
Q. But I may be wrong. 
315 
1 
BY MR. SCAROLA: 
2 
Q. And you would appear in New York —
3 
A. Well, no --
4 
Q. — for those Court TV appearances —
5 
A. I would appear --
6 
Q. — on a regular basis, correct? 
7 
A. I would appear wherever I was. So when I 
8 
was in New York. I appeared in New York, iota they 
9 
would do it by remote when I was in a different 
10 
city. And I clearly did some remotes for Court TV. 
11 
Q. In fact, you took an apartment In New York 
12 
for purposes of convenience to facilitate your 
13 
New York Court TV appearances, correct? 
14 
A. Totally false. 
15 
Q. Did you have an apartment in New York 
16 
during this period of time in December of 2000? 
17 
A. I had an apartment for -- I've had an 
18 
apartment in Ncw York for 30 — 30 years or more. 
19 
But I certainly didn't take an apartment for 
20 
purposes of Court TV, no. 
21 
Q. On Tuesday, December 12, the eau y is 
22 
I:30, Jeff, correct? 
23 
A. Right. Yeah. 
24 
Q. And that's a reference to Jeffrey Epstein. 
25 
correct? 
314 
1 
A. Wc have --
2 
Q. So you're telling me that you don't know 
3 
where she was and that's — 
4 
A. We just — we just gave you everything we 
5 
lad-
6 
MR. SCOTT: We provided hundreds and 
7 
hundreds of gages. You're picking out one. 
BY MR. SCAROLA: 
9 
Q. Let's go — let's go to the next page, if 
10 
we could, please, the third page in this composite. 
11 
A. The third. okay. Third, okay. 
12 
Q. And can we agree that this is a calendar 
13 
from December of 2000? 
14 
A. Yes 
15 
Q. Can we agree it's your calendar from 
16 
December of 2000? 
17 
A. That's right. yeah. 
18 
Q. And can we also agree that during this 
19 
period of time, you were making regular appearances 
20 
In New York on Court TV? 
21 
MR. SCOTT: Review the document before you 
22 
answer the question. please. 
23 
A. h says 12/30, Court TV, yes. There was a 
24 
period of time where I had a contract with Court TV 
25 
and I would appear when they asked me to. yeah. 
316 
1 
A. I don't -- I don't know. 
2 
Q. Well, what other Jeff might it be? 
3 
A. I know -- I know many, many Jeffs. 
4 
Q. Tell me which other Jeffs it might have 
5 
been a reference to —
6 
A. I have no idea. 
7 
Q. — on this calendar page. 
8 
A. 'just have no idea. I would be 
9 
speculating, 
10 
Q. During the same period of time on 
11 
December 12 when there's a calendar entry that 
12 
reflects 1:30, Jeff, we know from the flight logs 
13 
that Jeffrey Epstein traveled on December II from 
14 
Palm Beach International Airport to Teterboro 
15 
Airport, which is the private plane facility that 
16 
services the New York Metropolitan area. 
17 
A. I have no idea. 
18 
Q. You don't know? 
19 
A. No, I have no idea whether he was on that 
20 
plane. I hmen't seen the flight log. 
21 
Q. Well, I'm calling your attention to the 
22 
flight log. It's the next page. 
23 
A. Ifs the next page here? 
24 
Q. Yes, sir. 
25 
A. Okay. 
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319 
1 
Q. December 11,2000, PB1 to Teterboro. 
1 
that, but that you were in New York at the same time 
2 
passengers, Jeffrey Epstein — 
2 
Jeffrey Epstein -
3 
A. Wait a second. I have to find it. 
3 
A. And that Carolyn --
4 
MR. SCOTT: Well, let him -- let him read 
4 
Q. — and Virginia were in New York and you 
5 
the exhibit. 
5 
were — 
6 
A. What — what's the date? 
6 
A. And that Carolyn arranged for a massage. 
7
BY MR. SCAROLA: 
7 
Q. — having a massage. 
8 
Q. December 11. 
8 
A. And that my wife arranged for a massage. 
9 
A. December II. Yes, I sec that. 
9 
Q. No, I didn't say that at all, sir? 
10 
Q. Palm Beach International Airport to 
10 
MR. SCOTT: Well. that's what he's saying 
11 
Teterboro? 
11 
that the record reflects. 
12 
A. Right, yeah. 
12 
A. The record --
13 
Q. Passengers, Jeffrey Epstein? 
13 
MR. SCOTT: Don't cut him off. 
14 
A. Right. 
14 
A. •• reflects that Carolyn -- Carolyn always 
15 
Q. GM, a reference to Chislaine — excuse me, 
15
wanted me to have massages because she thought it 
16 
Ghislaine Maxwell, 
16 
would relax me. I don't like massages particularly, 
17 
A. Uh-huh. 
17 
but whin Carolyn arranged massages, almost always we 
18 
Q. And ET and Virginia, right? 
18 
had than togahcr at the swim time. We would have 
19 
A. That's what it says. yes, sir. 
19 
the same masseuse, sometimes a man, sometimes a 
20 
Q. And then we see three of the same four 
20 
woman. conic to the house and give us massages 
21 
passengers leaving the New York area. 
21 
together. 
22 
A. Uh-huh. 
22 
The idea that my wife would arrange for me 
23 
Q. To fly to another destination three days 
23 
to have a massage with an underage girl for sexual 
24 
later on December 14, correct? 
24 
purposes is so bizarre and absurd as to defy any 
25 
A. Yes. 
25 
kind of credibility, but go on 
318 
320 
1 
Q. And let's look at the next page of your 
1 
BY MR. SCAROLA: 
2
wife's diary for December 13, the period of lime 
2 
Q. Yes. Thank you very much, sir. 
3
when the flight log shows Jeffrey Epstein and 
3 
A. Go on. 
4 
Virginia in New York — 
4 
Q. I intend —
5 
A. IJh-huh. 
5 
MR. SCOTT: Since you're both smiling. 
6 
Q. — at the same time when it would appear 
6 
them scents to be some hung that I'm missing 
7
that you were in New York. And at the bottom of 
7 
here. I guess I —
8
this calendar, Wednesday. December 13. A.D., 
8 
MR. SCAROLA. Well, Fm missing the humor 
9
massage, right? 
9 
too. 
10 
A. 10:00 a.m. it says? What is it? 
10 
BY MR. SCAROLA: 
11 
Q. It says 10. 10-A.D. massage? 
11 
Q. Let's go to Composite Exhibit Number 10. 
12 
A. Yeah. 
12 
A. Yeah. 
13 
Q. Okay. 
13 
Q. The first page of that composite exhibit 
14 
Let's go to the next composite. 
14 
is a photocopy of pages from your personal calendar 
15 
A. I don't have •• there's another page after 
15 
in January 2001, correct? 
16 
that. Oh. the next composite. 
16 
A. That's right, yes. 
17 
Q. Yes, sir. 
17 
Q. Another Court TV appearance on January II, 
18 
A. Yeah. 
18 
correct? 
19 
Q. Composite Number 10. 
19 
A. January 11. 
20 
A. Uh-huh. But -- but I just want to be 
20 
Q. Yes, sir. Thursday, January II, entry In 
21 
clear. So you're saying Carolyn was with me in 
21 
the left-hand column, Court TV. 
22 
Ncw York during that period of time. 
22 
A. Entry on -- ms. January -- I see it as —
23 
Q. No, I'm not saying that at all, sir. I 
23 
I see it on January 12. I don't see it on 
24 
suggest that when we lake a close look al the 
24 
January IL but... 
25 
calendar, It's going to reveal something other than 
25 
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321 
BY MR. SCAROLA: 
Q. I'm sorry, maybe it is January n, but 
some time between the I Ith and 12th, either on the 
lint or on the 12th, it's Court TV, correct? 
A. No, no, no. You're just totally--
Q. It's the 12th - 
A. -- wrong -- it's the 12th, yes. 
Q. Okay. Good. Thank you. 
A. Ifs clearly stated on the I?. yeah. 
Q. Okay. And then on Friday, the 19th, a 
week later, another Court TV appearance, correct? 
A. 19th. Yes. 
Q. Okay. And on the 26th on Friday, 
another Court TV appearance, correct? 
A. That's what it says, yes. These were 
all —
Q. During this period of time —
MR. SCOTT: Whoa. Let — let him finish 
his answer. 
A. These are all scheduled appearances. I 
assume that I did thaw These -- these were — when 
they requested me to 
to do them. I would do them, 
yes. 
BY MR SCAROLA: 
Q. Okay. And It looks like you're appearing 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
323 
MR. SCOTT: Wait a minute. Let him get to 
it. 
A. 2 of the composite. Page 2, and what —
what day arc we on? 
MR. SWEDER: Do we even have it? 
MR. SCOTT: I'm sorry. Excuse me. Do we 
have copies of this exhibit? 
MR. SCAROLA: I've given you ccpies of 
everything --
THE WITNESS: Were these produced in 
discovery? 
MR. SCOTT: I assume. 
A. Okay. What am we up to? What page? 
BY MR. SCAROLA: 
Q. Page 2 of Composite Exhibit Number 10. 
MR. SCOTT: Okay. Now, stop. 
BY MR. SCAROLA: 
Q. Tuesday, the 16th. 
MR. SCOTT: What year arc we talking about 
now? 
MR. SCAROLA: 2001, the only year covered 
in this composite exhibit. 
A. Yeah, dinner foreign policy Epstein, that 
was dinner we had at Jeffrey Epstein's house with a 
group of very distinguished foreign policy experts, 
322 
1 
on a scheduled basis every Friday during this period 
2 
of time? 
3 
A. I don't think that was right. Yeah, I 
4 
don't think that was right. I think that they 
5 
called me when they wanted me. And it may have been 
6 
several Fridays in a row, but I think it depended on 
7 
breaking news at the --
Q. What is "scheduled appearance" --
9 
MR. SCOTT: Well, wait a minute. Let him 
10 
finish his questions laic]. 
11 
A. It would depend very much on whether there 
12 
was a particular trial because I would be the 
13 
commentator on the trial, along with other lawyers. 
14 
And there were some days when them were trials and 
15 
some clays when there weren't and I would be 
16 
available because I was living in New York at the 
17 
lime. 
18 
BY MR. SCAROLA: 
19 
Q. On Tuesday. the 161h, there Is an entry 
20 
that says Epstein, right? 
21 
A. On Tuesday, the 16th? 
22 
Q. Yes, sir. 
23 
A. Where are we? Which calendar nowt? 
24 
Q. Page 2. Page 2 of the composite, Tuesday, 
25 
the 16th, Epstein. 
1 
2 
3 
4 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
324 
Yes-
BY MR. SCAROLA: 
Q. All right, sir. Let's go to the next 
page. I've just focused on this period of time in 
January 2001 and on Friday. January 12 —
A. So we're going back to Friday, January 12. 
Yeah. 
Q. Your wife is in Cambridge, correct? 
A. No. I don't think so. My wife was living 
in New York with me at the time. I don't see any 
record of her being in Cambridge. 
She was 
we were living together in 
New York at NYU downtown. I was a visiting scholar. 
Having been appointed by John Sexton of NYU to be a 
visiting scholar, we were there for the year. And 
my wife was with mc during the year. Our daughter 
was in school in New York. She went to Little Red 
Schoolhouse in New York. And we had -- our life was 
in New York for a period of one year. 
Q. And on Friday, January 12, you had another 
massage, right? 
A. I don't see anything on my record that —
Q. Massage, A.D.? 
A. We must be looking at the different pages. 
Q. Friday, January 12, page 4 — 
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327 
1 
A. Who's — 
1 
A. Uh-huh. 
2 
Q. — of Composite Exhibit 10. 
2 
Q. Okay. Or from 3:30 to 4:15, that would be 
3 
MR. SCOTT: Let me see the page you're 
3
a playing time for you in Cambridge; is that 
4 
talking about so he can — 
4
correct? 
5 
MR. SCAROLA: I've given you the entire 
5 
A. You'd be asking me to speculate. I can't 
6 
calendar. 
6
speculate based on my wires calendar. It says 
7 
MR. SCOTT: Come on. Jack. 
7
utility bill, Reservoir address. That suggests 
8 
MR. SCAROLA: I've given you the entire 
8
Cambridge. Reservoir is ow house in Cambridge. 
9 
composite -- 
9 
Q. So, it would appear that this is another 
10 
TIE WITNESS: So you're talking about my 
10 
manage that you got somewhere? 
11 
wires — 
11 
A. Butt would like to also say one thing. I 
12 
MR. SCAROLA: Fourth page — fourth page 
12 
daft --1 at least wonder were these records 
13 
of Exhibit 10. You have Exhibit 10. rye given 
13
available to your clients at the time they made the 
14 
a copy of that. 
14 
falseaccusations against me or arc they 
15 
MR. SCOTT: I understand it and he has it 
15
after-the-fact constructs designed to simply try to 
16 
front of him and rm trying to get him to the 
16
find excuses to justify their false allegations? It 
17 
right page. Thank you. Please take it down. 
17
scents to me the latter is probably the case. 
18
BY MR. SCAROLA: 
18 
Q. And you are going to have an opportunity 
19 
Q. Fourth page, Composite Exhibit 10. 
19
through your counsel to ask those questions. 
20 
A. Yes. 
20 
A. And we will. 
21 
Q. Friday. January 12. 
21 
Q. And my clients are anxious to be able to 
22 
A. Okay. mars very simple. We were both 
22 
answer those questions. 
23
in Cambridge and I had a massage in Cambridge. flow 
23
A. Not as anxious as I am to hear their 
24 
do I know that? Because it had basketball. And 
24 
answers. 
25
that's where I play and watch basketball was in 
25 
Q. Okay. 
326 
328 
1
Cambridge. So probably I was in Cambridge if it 
1 
MR. SCOTT: Okay. Let's wrap it up. 
2 
says B ball 3:30.4:15 and says Cambridge with Ella, 
2 
MR. SCAROLA: Not quite. 
3
so I'm sure I was in Cambridge. 
3 
MR. SCOTT: Yeah, its 12:30. I'm ending 
4 
Q. All right. So — 
4 
this. That gives you three and a half hours. 
5 
A. But I'm -- I'm looking at my wires 
5 
We take a lunch break and than we have three 
6 
calendar. I can't tell you and nor can you tell me 
6 
and a half. 
7
where I was at that period of lime. 
7 
MR. SCAROLA: We don't need three and a 
8 
Q. So, the basketball entries are references 
8 
half hours for lunch. 
9
to your watching basketball in Cambridge? 
9 
MR. SCOTT: No. 1 didn't say that, I said 
10 
A. No. They could be playing basketball. I 
10 
we take an hour break and then we have three 
11
played basketball in those days -- 
11 
and a half hours with your client, just like... 
12 
Q. Watching or playing basketball? 
12 
MR. SCAROLA: If -- if that's what you 
13 
MR. SCOTT: Let him finish his answer, 
13 
want to do --
14 
please. 
14 
MR. SCOTT: That's the fair thing to do 
15 
A. I either watched basketball or played 
15 
because that's why we're dividing it equally 
16
basketball, yeah. I did not go to basketball games 
16 
and I suggested that --
17
in New York. to my recollection, unless the Celtics 
17 
MR. SCAROLA: I will state -- I will state 
18
were in New York and maybe we can check — 
18 
for the record that Exhibits 2.3 and 4 --
19 
MR. SCOTT: You've get about five minutes, 
19 
excuse me, Exhibits 9, 10, I I and 12. 
20 
Counsel. 
20 
composite exhibits, directly conflict with the 
21 
BY MR. SCAROLA: 
21 
witness's assertion --
22 
Q. The Celtics didn't play from 4:15 to 5:00, 
22 
MR. SCOTT: This is all a speech on your 
23 
did they? 
23 
part. 
24 
A. No, but I did. 
24 
MR. SCAROLA: It is a speech. 
25 
Q. You did? 
25 
MR. SCOTT: It is a speech and --
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329 
MR. SCAROLA: I'm giving you notice as to 
what you can do to do your homework. Okay? 
They directly conflict with the witness's 
assertion that the flight logs exonerate him. 
In fact --
MR. SCOTT: Wait a minute. 
MR. SCAROLA: -- the fli hi lo 
the 
flight logs corroborat 
assertions. 
MR. SCOTT: And I thank you very much for 
that explanation and we look forward to 
resuming this at the appropriate time and 
responding to that. 
THE WITNESS: And that is a false 
statement. 
MR. SCOTT: Thank you. 
VIDEOGRAPHER: Going off the record. The 
time is approximately 12:26 p.m. 
(The proceedings ADJOURNED at 12:26 p.m.) 
331 
CERTIFICATE OF REPORTER 
STATE OF FLORIDA 
COUNTY OF BROWARD 
I, KIMBERLY FONTALVO, Registered 
Professional Reporter, do hereby cern fy that I 
was authorized to and did stenographically report 
the foregoing videotape deposition of ALAN M. 
DERSIIOWITZ; pages through 145; that a review of 
the transcript was requested; and that the 
transcript is a true record of my stenographic 
notes. 
I FURTHER CERTIFY that I am not a 
relative. employee, attorney, or counsel of any 
of the parties, nor am la relative or employee 
of any of the parties' attorneys or counsel 
connected with the action, nor am 1 financially 
interested in the action. 
Dated this 16th day of October, 2015. 
KIMBERLY FONTALVO, RPR, FPR. CLR 
330 
CERTIFICATE OF OATH 
STATE OF FLORIDA 
COUNTY OF BROWARD 
I, the undersigned authority, certify 
that ALAN M. DERSHOWITZ personally appeared 
before me and was duly sworn on the libliday of 
October. 2015. 
Signed this 16th clay of October, 2015. 
S 
KIMBERLY FONTALVO, RPR, FPR, CLR 
Notary Public, State of Florida 
My Commission Na EE 161994 
Expires: 2701/16 
October 16.2015 
COLE. SCOTT& KISSANE. P.A. 
Dorkland Centre11- Suite140o 
9150 South Dodeland Boulevard 
Miami. Florida 33156 
BY: THOMAS EMERSON SCOTT. JR. ESQ. 
Re: Edwards v. Denhovitz 
Please take notice that on the 16th day of October. 
2015. you gave your deposition in the above cause. 
At that time. you did not waive your signature. 
The above-addressed attorney has ordered a copy of 
this transcript and will make arrangements with you 
to read their copy. Please octane the Errata 
Sheet. which can be found at the bock of the 
transcript. and have it resumed to us for 
disinlyution to all patties. 
If you do not read and sign the deposition within a 
reasonable amount of time, the original. which has 
already been forwarded to the ordering attorney. may 
be filed with the Clerk of the Court_ 
Wynn wish to waive your signature now, please sign 
your name in the blank at the bottom of Ibis laser 
and return to the address listed below. 
Very nuly )cuts. 
KIMBERLY FONTALVO. RPR. FPR. CLR 
Phipps Reporting. Inc. 
1615 Foshan Place. Suite 500 
West Palm Beach. Florida 33401 
I do hereby WaiVe my signature. 
ALAN M. DERSHOW1TZ 
332 
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ERRATA SHEET 
DO NOT WRITE ON TRANSCRIPT- ENTER CHANGES HERE 
In Re: EDWARDS V. DERSHOWITZ 
AIAN M. DERSHOWITZ 
October 16.2015 
PAGE LINE 
CHANGE 
REASON 
Under potables orpetjuty. It:Rehm Art I have 
read the feregomg doctarcnt and that the that 
axed m ii ac true. 
Date 
ALAN M. DERSIIOWIT2 
40 (Page 333) 
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Exhibit 3 
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3 
) 
1 
APPEARANCES CONTINUED 
2 
Also on behalf of the Defendant: 
1 
IN THE CROAT COURT OF IHE SEVENTEENTH 
2 
JUIRWIFCUI7 IN MD FCR 
COADY. FLORIDA 
3 
SWEDER 8 ROSS, LIP 
BY: KENNETH A. SWEDER, ESQUIRE 
4 
131 Oliver Street 
3 
CASE /83. 
CARE 15.000072 
Boston, 14•ssechusetts 02110 
4 
6 
Fax  
617.646.4466 
Fax: 
617.646.4470 
5 
BRADLEY J. EDWARDS and PAIL G. Catcall, 
6 
E-mall: ksweder•sweder•ross.com 
6 
7 
Plaintiffs/Counterclaim Defendants. 
7 
On behalf of the Witness: 
vs. 
8 
8 
UTAH ATTORNEY GENERAL'S OFFICE, P.A. 
8 
BY: TONI ). TONES, ASSISTANT 
9 
ALAN N. DERSEICIAITZ. 
ATTORNEY GENERAL, Litigation Division 
10 
10 
160 East 300 South 
Defendant/Counterclaim Plaintiff. 
Heber w ells Building • 6th Floor 
11 
F 
11 
Salt Lake City, Utah 84114 
12 
Tel: 
801.366.0100 
12 
Fax: 
801.366.0101 
13 
E•m all: JoniJoneS• utah.gov 
14 
VICEOTAPED DEPOSITION CF 
13 
15 
PAUL G. MRCP I 
14 
Telephonically on behalf of Jeffrey Epstein: 
18 
TAMS CH BEHALF OF DE 0FFEIDOM 
16 
DARREN K. !NOTICE, PLLC 
BY: DARREN K. INDYKE, ESQUIRE 
17 
VOLU1E I 
PAGES 1 to 151. 
16 
575 Lexington Avenue 
18 
4th Floor 
17 
New York, New York 10022 
19 
Tel: 
212.971.1314 
20 
Friday, October 16. 2015 
18
21 
1:33 p.m. • 0:31 p.m. 
19 
Also Present: 
22 
20 
DON SAVOY, Videographer 
110 Southeast 6th Street
BRADLEY J. EDWARDS 
23 
110 Tower - Suite 1650 
Fort laUderdale, Florida 33301 
21 
ALAN M. DERSHOWIT2 
24 
CAROLYN COHEN 
22 
25 
Theresa Tcmaselli, FM 
23 
ESQUIRE DEPOSITION SOLUTIONS 
24
26 
(954) 331-4400 
ESQUIRE DEPOSITOR SOLUTIONS 
(954) 331.4400 
2 
4 
1 
APPEARANCES OF COUNSEL 
1 
INDEX OF EXAMINATION 
2 
2 
WITNESS 
PAGE 
On behalf of the Plaintiffs: 
3 
3 
PAUL G. CASSELL 
SEARCY DENNEY SCAROLA 
4 
BARNHART & SHIPLEY, P.A. 
BY: JOHN SCAROLA, ESQUIRE 
4 
DIRECT EXAMINATION 
6 
6 
2139 Palm Beach Lakes Boulevard 
BY MR. SIMPSON 
West Palm Beach, Florida 33409 
6 
6 
Tel: 
561.686.6300 
Fax: 
561.383.9541 
6 
7 
E-mail: m e eel searcylaw •COIn 
INDEX TO EXHIBITS 
7 
43 
On behalf of 
8 
EXHIBIT 
DESCR IPTION 
PAGE 
9 
B 0 I 
. LLP 
9 
10 
BY: SIGftID STONE NCCAW LEY, ESQUIRE 
401 East Las Olas Boulevard 
Cassell 1.1). Exhibit No. 1 - Plaintiff's 
21 
11 
Suite 1200 
Fort Lauderdale, Florida 33301 
10 
Response to Notion for Limited Intervention 
by Alan H. Dershowitz 
12 
Tel: 
954.356.0011 
11 
Fax: 
954.356.0022 
Cassell I.D. Exhibit No. 2 - Jane Doe 
22 
13 
E•m ail: sm ccaw ley° bsfllp.com 
12 
Number 3 and lane Doe Number Cs Motion 
Pursuant to Rule 21 for Joinder in Action 
14 
13 
On behalf of the Defendant: 
Cassell 1.0. Exhibit No. 3 - one -page 
106 
16 
14 
document produced by the witness 
WILEY REIN LIP 
16 
BY: RICHARD A. SIMPSON, ESQUIRE 
15 
AND: NICOLE A. RICHARDSON. ESQUIRE 
17 
1776 K Street Northwest 
Washington, DC 20006 
16 
16 
Tel: 
202.719.7000 
19 
Fax: 
202.719.7049 
e-mail: rsim pion° w ileyrein.com 
17 
18 
20 
Also on behalf of the Defendant: 
19 
21 
COLE. SCOTT a KISSA NE, P.A. 
20 
(Original Exhibits have been attached to the 
22 
BY: THOMAS EMERSON SCOTT, JR., ESQUIRE 
original transcript.) 
23 
9150 South Dadeland Boulevard 
fl atland Centre II • Suite 1400 
21 
22 
Miami, florida 33156 
U 
Tel: 
305.350.5329 
23 
Fax: 
305.373.2294 
24 
26 
E•mall: thoMa4SCOROCsklegal.com 
26 
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63 
of ins 
1 
Q. 
I would like to know why you alleged " and 
011235 
1 
was your basis for this? 
01.1067 2 
other minors "  given what you have said about your 
ei on 
2 
A. 
All right 
So the Initial 
basis for it 
vinyl 
3 
knowledge of the factual basis, so to speak, for that 
o1 :o00 3 was —
01 nos 4 
allegation. 
ociwo 4 
MR. SCAROLA: First of all, let me object 
on no. 5 
A. 
Okay. 
There 
are going 
to be — I ' m 
going 
to 
oi out 
5 
because Professor Cassell is not here as an 
o1 „a 
6 
end up giving 
you nine reasons, 
each of which 
is 
011304 6 
expert witness and hypotheticals 
are 
oil' n 7 
complicated, 
so I just 
want 
to — if -- if - 
I don ' t 
01.1301 7 
inappropriate. 
You ' re calling for speculation on 
00 17 Is 8 
want 
to be accused 
of -- of fi libustering 
or anything. 
vi no. 8 
his part. 
I ' m not going to instruct him not to 
oi 1113 
9 
I just 
want 
you to know 
that 
you have asked 
a broad 
011310 9 
answer, but it is an Improper question. 
0111 IA 10 
question 
that
' s going 
to require 
a broad 
and extended 
011114 10 
MR. SIMPSON: 
I disagree, but you can answer 
011120 11 
answer. 
It — it -- 
010,4 11 
the question. 
onus 12 
O. 
Answer the question. 
01131.1 12 
THE WITNESS: 
Right. 
So the -- the factual 
011,23 13 
A. 
Okay. 
Then I ' m going 
to 
to a -- I have 
es 13 n 13 
basis would
— we are setting aside 
011177 14 
a — well, actually, 
I don ' t 
011131 14 
attorney/client 
communications, 
right? 
011121 15 
Q. 
Let me ask you this: 
Before you refer to 
unit 
15 
BY MR. SIMPSON: 
01.1130 16 
something 
-- 
01 on 16 
O. I'm asking: 
What would you tell the judge? 
*inn 17 
A. 
Yeah. 
u 42.1 17 
A. 
Right 
So that 
— I -- I -- that
' s 
011130 18 
Q. -- please give me your best recollection 
of 
el lin 18 
speculative 
to -- I don ' t think 
I can give a fair answer 
0,1134 19 
what the basis was, the factual basis that you had in 
oi 17 30 19 
at this point 
because 
that 
would 
have Involved 
going 
0 nu 20 
mind. If the court said to you -- let me put it this 
011112 20 
back to my client 
and — and carving 
out what 
kinds 
oi iiie 21 
way. 
If you went to court and Judge Marra said, 
Of 0 36 21 
of things 
we were 
going 
to present 
to Judge Marra 
In 
in 110 22 
Professor Cassell, what ' s your factual basis for this 
oi 0 w 22 
light 
of the posture 
of the case at that point. 
co Ili, 23 
allegation? 
Tell me. 
What would you say? 
01 00 23 
So it ' s a speculative 
question. 
I would 
011140 24 
A. 
Right. 
011346 24 
have -- let me just 
— without 
going 
Into any 
0111414 25 
MS. McCAWLEY: Wait. 
Outside the context of 
01 044 25 
attorney/client 
privileged 
communications, 
I would 
have 
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en ,so 
so 
1 
anything 
that ' s been communicated 
to you. 
011331 
1 
provided 
an ample 
factual 
basis for those allegations. 
oi nu 
2 
MR. SCAROLA: Excuse me. 
You have asked two 
0 nn 2 
MR. SIMPSON: 
I move to strike as 
how 3 
different 
questions now, and I need to understand 
oi on 
3 
nonresponsive. 
allot 4 
which question you are asking. 
vi nos 4 
BY MR. SIMPSON: 
oi ilia 5 
The question that you posed before just now 
0113111 
5 
Q. 
Let me ask it this way: 
We have talked 
01,102 6 
was: 
what was the reason for your including 
no: 
6 
about -- somewhat about the basis for this allegation 
in use 7 
those allegations 
in this pleading? 
011403 7 
about other minors. 
Putting aside information 
as to 
011201 8 
Now you have asked: 
What is the factual 
u 1400 8 
which you 're claiming privilege, 
tell me what you knew 
nate 
9 
basis? And that ' s going back to questions that 
MHO 
9 
as of December 30th, 2014, that formed the factual basis 
011214 10 
we have already covered, and we have, I think, 
011420 10 
for your -- for that allegation 
about other minors. 
011717 11 
exhausted 
the ability to respond to that question 
°tun 
11 
MR. SCAROLA: And I 'll instruct you not to 
01 1720 12 
outside of privileged 
information. 
moos 12 
answer that question for the same reason, that 
oi on 13 
Do you want to go back to the question about: 
011427 13 
when the same question was asked earlier, I 
011224 14 
What was your reason for inducing 
those 
011421 14 
instructed you not to answer. 
011170 15 
allegations? 
011431 15 
MR. SIMPSON: 
I 'm -- I 'm -- maybe we are not 
oi nos 16 
MR. SIMPSON: Iii 
ask the question a 
01,433 16 
being clear, Jack. 
I ' m asking Nm to put 
es we 17 
different 
way. 
011431 17 
aside -- I mean, certainly, 
he -- he filed a 
011211 18 
MR. SCAROLA: Thank you. 
coup 18 
pleating. 
You' ve asserted privilege as to 
01,213 19 
By MR. SIMPSON: 
011440 19 
certain aspects. I'm simply asking him, putting 
0„ 213 20 
Q. 
Mr. Cassell, Fm going to ask you: 
If you 're 
0,1443 20 
aside whatever you 're claiming privilege for, 
oi nc 21 
in court and Judge Marra said to you, counsel, what is 
oi Hs 21 
right, so I ' m not -- I ' m not asking you right now 
011242 22 
the factual basis for your allegation that Professor 
01144/ 22 
to tell me anything 
you 're claiming as 
011241 23 
Dershowitz 
abused other minors, 
what would you say? And 
011441 23 
privileged. 
011251 24 
if you wouldn ' t say something 
because it was privileged, 
01141. 24 
BY MR. SIMPSON: 
011212 25 
then don ' t indude 
it. What would you tell the judge 
011410 25 
Q. 
Tell me whatever Is not privileged 
that 
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01 14:61 
1 
supports that allegation. 
01 1446 
2 
A. 
Okay. The privileged information, obviously, 
01 1414 
3 
you're asking me not to reveal at this point. 
assns 4 
Q. I'm asking you -- I'm asking you to tell me 
01. 144 5 
the nonprivileged information. And I'm not agreeing 
el Wm 
6 
with your privilege assertion --
wise( 7 
A. 
Sure. 
01:1507 
8 
Q. 
but for purposes of this question - 
01:1107 9 
A. 
For purposes of this question. 
011407 10 
Q. 
-- I'm accepting it. 
isw 11 
A. 
All right. 
01:1606 12 
Q. 
Putbng aside what you claim is privileged, I 
oi Imo 13 
want to know everything that's the factual basis for 
emir 14 
including the allegation about other minors. 
Mill. 15 
A. 
Okay. Privileged information which I'm not 
0111 17 16 
disclosing in any way would have interacted with a vast 
ensss 17 
body of other information. 
n 1622 18 
The vast body of other information would have 
01:1624 19 
started with an 89-page police report from the Palm 
faun 20 
Beach Police Department that showed for about a 
nue 21 
six-month period in 2005, there was sexual abuse of 
m ism 22 
minor girls going on on a daily basis, In — whenever 
stun 23 
Jeffrey Epstein was in his Palm Beach mansion. 
01:15.4. 24 
And on some cases, it was going on not once, 
0115.6 25 
not twice, but three times during the day. That -- let 
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01 16 52 
1 
began, you know, I guess what we would call 
ot ma 
2 
knock-and-talks, knocking on doors to try to get to some 
oiler 3 
of these girls, and they would get to the girls, and 
16/11 4 
many of them initially were — were afraid to explain 
ot i, 
5 
what had happened. 
el ore 6 
But as they — as they continued talking to 
011744 
7 
them, the girls began to explain that what was happening 
nun 8 
was, they were going over to Epstein's house under the 
seas u 9 
guise of giving a massage, and when they got there, the 
on2u 10 
massage was, in fact, sexual activity. 
.11 11 
And for many of the girls, I think, as I say 
01022 12 
around 23, 24, something along those lines, they were 
nun 13 
underage. They were under the age of consent in 
011701 14 
Florida. 
Os 1.211 15 
And so each and every one of those events was 
or um 16 
a crime being perpetrated 
and let's be clear, not 
n oar 17 
just being perpetrated by Epstein, but by other people 
01 ITN 18 
who were involved there at the mansion. 
01 ITN 19 
And so what the -- the Palm Beach Police 
el 1740 20 
Department was putting together was that this mansion in 
n -1241 21 Florida was the nest of sexual abuse of young girls here 
01 1744 22 in Florida that Involved, literally, in the -- in this 
leas 23 period of time, more than a hundred events that they 
es Inv 24 
were able to document of sexual abuse. 
al use 25 
And when you put that together with the 
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1 
0115 SI 
2 
0135 45 
01'1556 
01 u551 
011617 
01 160S 
01 16 0/ 
01:1601 
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01 16 47 24 
et nee 25 
3 
4 
5 
6 
7 
8 
9 
86 
me just be clear. I mean, I -- I referred to the 
89-page police report. I have offered to put it into 
the record if -- if it would speed things up, but let's 
just talk about some of the things that are in that 
89-page police report. 
This was a -- a very Intensive investigation 
that the Palm Beach Police Department put together. 
They did, for example, what are called trash covers; 
that is when trash came out of the -- of the mansion of 
Epstein, the police would intercept the trash and then 
they would go through the trash and look for 
incriminating information. 
And what they began to discover was memo 
Pads -- and I say "memo pads,-  let's be clear, pad after 
pad after pad, or I guess I should say, sheet after 
sheet after sheet that had the name of a girl, and then 
there was a notation of something to the effect of a 
massage. 
And so the Palm Beach Police Department began 
tracking down, well, wait a minute, these -- these are 
girls giving massages and they don't seem to have any 
specialized training in massages; they don't seem to be 
masseuses in any sense of the term; what's going on 
here? 
And so the Palm Beach Police Department 
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01 1001 
1 
slim 2 
m a 
3 
onto, 4 
en ley 5 
mutt, 6 
onuw 7 
et is 
8 
011021 9 
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organ 12 
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011646 16 
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01:164 20 
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01'11112 25 
68 
pattern or practice that was being revealed there, there 
were hundreds of acts of sexual abuse going on In the 
mansion. 
But then what becomes -- and this is where I 
indicated that, you know, the answer would continue on. 
The — the problem was that the evidence was starting to 
show that this was a much broader series of events. For 
example, there were flight logs showing that Mr. Epstein 
was then flying with underaged girls, and those flight 
logs, you know, as -- as the flight logs began to 
develop, for example, we have seen, I k wi 
day or two here, one underage girl w 
who is on the flight, you know, with Epstein, and with 
Maxwell, and those sorts of things. 
So you start to look at the flight logs and 
you see what's going on is not just events that are 
occurring in Florida, but it's occurring on a 
multi-state basis, which now starts to make it a federal 
crime. For example, we are seeing evidence that --
let's just talk abo 
she's 
central to this ca 
We are seein 
flown 
from Florida to New Yor w ere s e s in 
c utches of 
Jeffrey Epstein who is sexually abusing her, you know, 
many times a week. And not just Jeffrey Epstein, but 
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01 ten 1 
other powerful persons. For example, Ghislaine Maxwell 
anis 2 
is there with him on all of these flights and apparently 
e,112, 
3 
being involved in the abuse. 
• nr.. 4 
Indeed -- and so you -- you have — you 
es nn 5 
have that. You also start to see on the flight logs, 
01 no 6 
what to my mind are some very sinister things, 
01 1104 
7 
suggesting that the pattern is not just confined to sort 
011•10 8 
of, you know, the girls that are there In Florida, but 
as an 9 It — it Is extending more broadly. 
011141 10 
Like one of the — to my mind, sinister and 
na 11 scary things on the flight logs is, we see, you know, 
sine 12 
,o we know has been sexually abused, 
in nu 13 
and we see Jeffrey Epstein, and then we see on the 
si nu 14 
flight logs one female. 
nu 15 
That's kind of an odd notation for a flight 
.nn. 16 
log because, you know, typically, I understand the 
ante 17 flight logs, the purpose is, well, if something happens 
012001 18 
with the flight, or there's some question about who was 
mans 19 on it, you want to know who -- who the person was who 
lone 20 
was on the flight. 
012000 21 
So, to my mind, when I started to see on 
sin to 22 
these flight logs entries like one female, I viewed that 
00016 23 
as a potential device for obscuring the fact that there 
anon 24 
was interstate trafficking of underage girls for 
1112011 25 
purposes of sexual activity. Serious federal offenses. 
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011022 
1 
But then that evidence extended, you know, 
012020 
2 
more broadly than that. The evidence also started to 
011021 3 
show, again, if we talk just abo 
011011 4 
the -- that underage girls such 
were 
costa 
5 
being flown Internationally fro , 
rboro 
0120 01 
6 in Now York to -- to locations, just to pick one, you 
an 
7 
know, for example, In London, where again sexual abuse 
01100S 
8 
was occurring. 
O1101/ 
9 
And so you started to put together this 
012001 10 
pattern of criminality that was started in this -- you 
sass, 11 
know, I don't know what the right word is here. I don't 
01:2001 12 
want to -- I don't want to -- you know, you've heard 
slain 13 
discussions of hyperbole and things like that, but we 
onto, 14 
have got this nest of — of — and I won't say snakes, 
012101 15 
but we have this nest of criminals in Florida, but it --
m 21 07 16 it seems to be spreading to Epstein's mansion in New 
eta,. 17 
York; it seems to be spreading to Ghislaine Maxwell's 
ay.. 18 
flat in London, and -- and -- and it goes on. 
a 21.7 19 
So those are the kinds of things that would 
or 21 TO 20 
have formed the -- the -- the basis, particularly when 
0121n 21 
you -- when you start to add in this fact: What the 
• 
n 22 
Palm — going back now to Florida with the Palm Beach 
011111 23 
Police Department. What the Palm Beach Police 
man 24 
Department has — had discovered was not a one-off kind 
0111/3 25 
of event, you know, on one particular day, one 
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011111 1 
particular girl had been sexually abused. 
ern. 2 
What the Palm Beach Police Department had 
o:no 3 
discovered was brazen, notorious, repetitive activity 
0121411 4 
sometimes occurring as often as three times in a 
er210 5 
particular day. And so that led me to believe that the 
oinst 6 
sexual activity that was going on in Florida was such 
012114 7 
that someone who was a regular house guest there would 
012111 8 
have immediately come to the conclusion that, well, 
eine 9 look, gee, there are these underage girls coming in here 
ones 10 
and they -- they seem to be -- you know, they don't seem 
mass 11 to be here to be doing, you know, business activities; 
or as 12 
they -- they might be here doing other kinds of 
nil 13 activities. So those would be the kinds of things that 
arra 14 
would -- would have formed the factual basis. 
or no 15 
There are other things as well, but I'm sure 
01 no 16 
you want to ask other questions in addition to that. So 
012222 17 I'll stop there, but those — that's — I think gives 
an 24 18 
you a small flavor of the kind of evidence that, you 
01 nn 19 
know, was form — undergirding the allegations that were 
Ginn 20 
being presented here. 
01 an 21 
Q. It sounds like you quite passionately believe 
01 2211 22 
that there was strong evidence that Mr. Epstein had 
w no 23 
engaged in sexual misconduct; is that right? 
wan 24 
A. 
I think "strong' understates it. 
oleo 25 
Q. In the course of that long answer, y0u didn't 
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012244 
oust 2 
nn 
3 
0101.. 4 
si nu 5 
mention Professor Dershowitz's name once. 
A. I said flight logs. And let's talk about 
flight logs. 
Q. 
Let me back up. You didn't answer his 
name -- mention his name once; is that -- is that your 
wow 6 recollection as well? 
01 ZS CO 
7 
A. 
That's correct. We were talking about a 
012302 8 
factual basis, and I'll be glad -- I told you that there 
ernes 9 
were other things if you want, factual basis for — for 
o, ow 10 
Mr. Dershowitz. I'll be glad to add that in. Let me --
es n io 11 let's — let me — let me -- I would like to supplement 
ens,, 12 
my answer then if I could. 
012112 13 
Q. 
Do you want to look at a document? 
man 14 
A. 
Yes. 
anis 15 
Q. 
Let me first -- have we exhausted your 
woe 16 
recollection without documents of all the evidence that 
011121 17 
you would refer to to support the allegation that 
012111 18 
Professor Dershowitz abused other minors? 
OS n1119 
A. No. 
woo 20 
MR. SCAROLA: And let me say that you have a 
011124 21 
right to refer to whatever documents you choose 
Dina 22 
to refer to, to be sure that you give a complete 
sins 23 
response to the question that has been asked, as 
long as you understand that whatever you refer to 
011340 25 
is going to be available to the other side, and 
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012443 10 
01240 11 
012443 12 
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we would be happy to make It available to you. 
MR. SIMPSON: And -- and I'll give you an 
opportunity to look at that --
THE WITNESS: Sure --
BY MR. SIMPSON: 
Q. 
-- but I'm entitled to ask first about your 
recollection. 
A. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
73 
Okay. 
Based on your recollection — 
Right. 
-. I want to know all the evidence --
Right 
you were relying on here. 
So what — what I'm going to do is, I'm going 
to make a list here on my -- on my notepad of all the 
things, and then I'm going to compare that with notes I 
have here. There may be a couple things that I don't 
cover. 
Q. 
As long as your counsel is okay with that. 
A. 
Yeah. 
Q. 
You understand you'll have to give that to 
me7
A. 
Yeah. 
give you the notes —
Q. 
All right. 
A. -- and then I will compare with what I've got 
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oinu 1 Mr. Epstein saying that she had been trafficked, 
°inn 2 
sexually trafficked, you know, not just abused by 
010 44 3 
Mr. Epstein, but now being forcibly sent to, you know, 
471 2446 4 
other people to abuse. 
01 x43 5 
And In the categories of people that were 
14 
010157 6 
sexually abusing her were academicians, and I knew that 
°Inas 7 
Mr. Dershowitz fell within that category of -- of being 
cram 8 
an academician. The — that complaint also Indicated 
02304 9 
that there 
I 
flight logs that would show that 
ono. 10
d been sexually abused in these 
etas* 11 
And that started to indicate to me 
0127+o 12 
that there might be what the la 
mon 
0x10 13 
scheme or plan. And that, just 
as 
*inn 14 
being trafficked to these powe 
Qin?, 15 
places, there might well be other girls. 
012024. 16 
And so I have mentioned a flight log, and let 
or as n 17 
you — you wanted to talk about Mr. Dershowitz. On 
01x33 18 
on December 30th, 2009, I was aware that there was a 
or sat 19 
flight log showing Mr. Dershowitz flying with Tatiana, 
size., 20 
who as far as I can tell was not a business person, was 
01044 21 not providing financial advice or something else. 
man 22 
I understood that Mr. Epstein was a 
inn u 23 
billionaire who was heavily involved in financial 
441x.7 24 
issues. I knew that Tatiana was on a plane with 
01x0 25 
Mr. Dershowitz, and then there was also, if I recall 
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4121n 
1 
there. So I mentioned the Palm Beach Police Department 
a 24 14 
2 
report. 
23.x.1 3 
The next thing that I want to mention is the 
on. Is 4 
Jane Doe 102 complaint. In August of 2009, Bob 
012427 5 
losefsberg -- who is, from what / understood, a very 
012432 6 
well-regarded lawyer here in Florida; in fact, a lawyer 
01:431 7 
that was selected by the United States Government to 
01x30 
8 
represent a number of the --of the girls that had been 
0124 40 9 
sexually abused by Jeffrey Epstein. He was 
he was 
part of the procedure that was including the 
non prosecution agreement 
behalf 
that 
Flori 
,a 
he filed a complaint on 
t complaint indicated 
n sexually abused in 
in -- in other places, as I 
recall. The thing that -- that I pa 
was that Mr. )osefsberg had said 
as 
abused by -- and he gave some ca egor es o peop e. 
He mentioned, I think, business people. He 
mentioned royalty, and he mentioned academicians. And 
so to tie into your question, I knew that Professor 
Dershowitz was an academician. And so what I was seeing 
now was, that according to a very, very respected 
attorney here in Florida, he had found 
to be credible, and had filed a lawsuit 
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oi nru 1 
correctly, working from memory as -- as you were 
O1270 2 
wondering about, there was a notation that 
Orr... 3 
Mr. Dershowitz was on a plane with one female. 
one 4 
And so I was — when I looked at that, I'm 
omit 5 
seeing Mr. Dershowitz on a -- on a flight with a woman 
rune 6 
who doesn't seem to be there for, frankly anything other 
en is 7 
than sexual purposes or something along those lines with 
a,2721 8 Mr. Epstein, with Mr. Epstein, who Is a sex trafficker, 
at 2721 9 
and with one female which seemed to me to be a potential 
01 0 30 10 
entry for disguising international sex trafficking. So 
that was of concern. 
I then began to look at, well, I wonder, how 
would I find out if Mr. Dershowitz had been abusing 
other girls/ Let's see. I knew the 
had been forced to — to — to -- to 
thing.. 
MS. lecCAWLEY: you're Okay as long as 
You're -- if you're revealing something that's in 
an affidavit --
THE WITNESS: That's right. 
MS. McC.AWLEY: -- that she submitted, you're 
012733 11 
012734 12 
012723 13 
012734 14 
012142 15 
• 1741 16 
012754 17 
01 2241 18 
012744 19 
01771,1 20 
o1»34 21 
0$2,“ 22 
212 123 23 
inn os 24 
01210 25 
fine. 
THE WITNESS: Right. So -- so what... 
Let's see. What did I want, at this point --
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012105 
1 
BY MR. SIMPSON: 
012114? 
1 
MS. McCAWLEY: Yeah. 
si :ea 2 
Q. Do you want the question back? 
MOO 
2 
MR. SCAROLA: -- who keeps jumping up and 
on* 3 
A. No. I'm just trying to remember what I was 
012010 3 
down and distracting everybody in the room? 
012.12 4 thinking about with -- with regard to -- 
012•12 4 
MS. McCAWLEY: And there was also profanity 
0211s 
5 
MR. SCAROLA: Do you need the response read 
•,nu 5 
used earlier. I mean, we just have to settle 
mnir 6 
back up to the point -- 
•, no 6 
down on this side, and take a deep breath, and 
01211. 7 
THE WITNESS: Yeah, if you would do that, 
a me 7 
let him answer his questions. 
012420 
8 
yeah. I just -- 
Maw 8 
MR. SIMPSON: Look, I mean, the same thing 
a74.20 9 
MR. SCAROLA: -- about privilege arose. 
awn 9 
was happening on the other side. 
012130 10 
THE WITNESS: Yeah. Let's just see what that 
01300 10 
MR. SCAROLA: No, sir. 
auto 11 
one -- 
013000 11 
MS. McCAWLEY: There was no profanity on this 
042121 12 
MR. SCAROLA: Just read the last couple of 
ow® 12 
side of the table. 
012102 13 
sentences back, or the last two sentences. 
mato 13 
MR. SCAROLA: No, no, no. There was never 
012.31 14 
THE WITNESS: Oh, I'm sorry. Now I remember 
a ea 14 
anyone who jumped to their feet at any time 
a NM 15 
exactly what I was thinking. 
a via 15 
during the course of the last two days. The only 
012132 16 
How would we go find out whether Mr. Epstein 
a mg 16 
person who keeps jumping up is Alan Dershowitz. 
0.2/35 17 
e.2/,. 18 
was lending women, or in this case, underage 
girls, to Mr. Dershowitz for sexual purposes? 
013013 17 
0130 SI 18 
Have him pass you a note quietly, if you would, 
please. 
0:2/41 19 
Well, the first thing I want to do was ask -- you 
013011 19 
MR. SIMPSON: I will disagree with your 
01214$ 20 
know, I'd -- I'd go ask Jeffrey Epstein. 
cilia. 20 
characterization, but let me say the 
012147 21 
And so what I discovered when I started to 
013020 21 
argumentation --
alma 22 
look at the transcripts, there were a number of 
013021 22 
MR. SCAROLA: Excuse me. Are you -- are you 
012452 23 
transcripts where Mr. Epstein was asked about 
x3027 23 
making the representation --
a MS 24 
Alan Dershowitz. And rather than say, well, no, 
013027 24 
MR. SIMPSON: No, I'm not. 
0.200 25 
he wasn't involved in any of these illegal 
013023 25 
MR. SCAROLA: -- that somebody on this side 
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ei a ® 1 
activities, Jeffrey Epstein took the Fifth as the 
in was 1 
of the room jumped up? 
012903 2 
phrase, you know, to be more precise. He 
013023 2 
MR. SIMPSON: No, no, no, I'm not. 
01 Oa 
3 
exercised his right against compelled 
0, 3036 3 
MR. SCAROLA: Okay. Thank YOU. 
.ma 4 
self-incrimination and refused to answer the 
013036 4 
MR. SIMPSON: I'm not. 
an ma 5 
mail 6 
question, which since these were civil cases, 
Indicated to me, since he was being represented 
01302? 5 
a an 6 
MR. SCAROLA: And I appreciate that. 
MR. SIMPSON: And I - 
0/ POO 7 
by very experienced legal counsel, that there was 
oi ma 7 
MR. SCAROLA: And you do acknowledge that 
(1/21 MI 8 
more than an insignificant risk of incriminating 
013610 8 
Mr. Dershowitz has repeatedly been jumping up in 
a a a 9 
himself if he answered that. 
'Inn 9 
the middle of testimony, correct? 
01.2120 10 
And so Jeffrey Epstein now had taken the 
01 VIC 10 
MR. SIMPSON: That's -- he just got up and 
earl 11 
Fifth. And one of the things that I was aware of 
0131431 11 
came over to me. That's the only time I'm aware 
0, 2124 12 
ei 2ow 13 
having been involved in, you know, civil 
litigation and criminal litigation in other 
an 12 
013011 13 
of, because I'm -- Em looking at the witness, 
but he did Just do that, and I will pass notes. 
an 14 
cases, was that once somebody refuses to answer a 
413044 14 
We won't get up. 
0405 33 15 
question like, you know: Do you know 
013046 15 
MR. SCAROLA: Okay. Well, I will tell you --
01213S 16 
cii am 17 
Mr. Dershowitz? And they take the Fifth on that, 
that you're then entitled to draw what's called 
s$3045 16 
0130/7 17 
MR. SIMPSON: I'm not going to take time from 
this. 
012/ 40 18 
an adverse inference. You can -- you can infer 
01300 18 
MR. SCAROLA: I will -- I will, for the 
012342 19 
that, well, if they answered that question, they 
con 19 
record, as an officer of the court, represent 
01 21,14 20 
would have -- 
oivao 20 
that there have been multiple times during the 
0 20 14 21 
MR. SCAROLA: Excuse me. 
a asi 21 
course of Professor Cassell's deposition when 
012/44 22 
MS. McCAWLEY: Yeah, I want to make an 
soars 22 
Alan Dershowitz has jumped up in the middle of 
012114 23 
objection here -- 
013101 23 
the testimony and excitedly whispered in your 
strw. 24 
MR. SCAROLA: Pardon me. Could you please 
013121 24 
ear. 
012147 25 
try to control your client -- 
013107 25 
You may not have realized it because you were 
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0131 C0 
i 
on,“, 
2 
013113 
3 
a n • 
4 
81 
focusing on the witness, but everybody on this 
side of the room has been distracted by his 
unprofessional conduct. 
MR. SIMPSON: I'm not going to argue with 
an» 1 
m-an 2 
017064 
3 
011317 4 
83 
review, in which he took the Fifth when asked questions 
about Dershowitz. 
So, at that point, in trying to figure out, 
you know, whether Mr. Dershowitz was involved in 
Ot 3110 
5 
you. And I -- 
013120 5 
sexually abusing, not onl 
in 
03114 6 
MR. SCAROLA: Thank you. 
OT Us 
6 other girls, then you go d 
I, next 
*nu, . 
7 
MR. SIMPSON: -- I disagree with that 
Our 7 
layer of the criminal conspiracy. 
013120 
8 
characterization. There is another attorney 
fin 
8 
Epstein is at the top, so you go to the next 
CI 3172 
9 
sitting between us. We will pass notes. 
a a» 9 
layer. These are, you know, basically the -- the women 
ail» 10 
MR. SCAROLA: Thank you. 
a »13 10 
who, from what I could gather, were — were older than 
Ot111. 11 
MR. SIMPSON: And we -- and I believe, 
a a* 11 the ago that Epstein wanted to sexually abuse. I think 
.313170 12 
Ms. McCawley, were you instructing not to answer 
a a 0 12 
these were 22 and 23-year-old girls, so they had, you 
013130 13 
or what was happening? What did you -- what were 
ol um 13 
know, essentially aged out of being his sexual abuse 
01.31 34 14 
you raising? 
a no 14 
victims, but they continued to — what they would do is 
Ot 3134 15 
MS. McCAWLEY: No. There was a lot of 
ens 15 
collect girls for him under the age of 18, that I guess 
*tales 16 
yelling going on here, so I was trying to make 
013333 16 
was in his target range. 
03137 17 
sure that everybody was quiet -- 
areas 17 
And so what — so the next person I 
18 
MR. SIMPSON: All right. 
a am 18 
nwn 
t information from wa 
19 
20 
MS. McCAWLEY: -- so that the client could 
answer. 
oi mo. 19 
01 Mel 20 
on a lot of these flight logs 
„ 
irls that -- or women and with 
21 
MR. SIMPSON: All right. Let me back up. 
013407 21 
Epstein and others, and so I wanted to talk t 
22 
BY MR. SIMPSON: 
013407 22 
era,., 23 
Q. 
Professor Cassell, I think you were in the 
on» 23 
But what I discovered there was that, when 
01'041 24 
middle of an answer? 
034u 24 
s asked about Alan Dershowitz, she took 
0330 25 
A. 
I was. Yes, If I could conclude -- 
a mi, 25 
the Fifth, and there was — she wasn't the only one. 
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a 3, 0 
1
MR. SIMPSON: All right. Could the court 
013421 1 
There was Miss Mucinska, who also took the Fifth when 
013144 
2 
reporter read me the last two lines of your 
a ins 2 
asked questions about Alan Dershowitz. 
013146 3 
answer? 
034 
34,7 
3 
And then there wa 
Iss 
013145 4 
THE WITNESS: Okay. 
man 4 
who also took the Fifth. Sow 
we -- what 
nein 5 
(Thereupon, a portion of the record was read 
Ginn 5 
this point was Jeffrey Epstein's international sex 
on,* 6 
by the reporter.) 
el um 6 trafficking organization. I had the next echelon, and 
01040 7 
BY MR. SIMPSON: 
013.10 7 
both the top kingpin of the sex trafficking 
max 8 
Q. 
Okay. Can you pick up then? 
man 8 
organization, and the next echelon had taken the Fifth, 
mar 9 
A. 
Sure. I'll pick up — pick up the — 
0.0463 9 had refused to answer questions about Alan Dershowitz. 
01370 10 
Q. 
Okay. 
013440 10 
And so, at — at that point, I was drawing an 
01373, 11 
A. 
So I was beginning to draw an adverse 
0 mil 11 adverse inference, not just from one person, but from 
an ii 12 
inference when Jeffrey Epstein, who is at the heart of 
0 340 12 
four persons, and that adverse inference was being 
a 12 34 13 
the sexual abuse of, not only Virginia Roberts, but 
01.310 13 
strengthened by the surrounding circumstances, some of 
013230 14 
dozens and dozens and dozens of -- of girls literally 
,in.. 14 
which we have already talked about. 
a1.040 15 
scattered across the globe, takes the Fifth, refuses to 
et MO 15 
One of the things that -- that really 
mac 16 
answer the question, off the top of my head, I can't 
013302 16 
bolstered the adverse inference that I was drawing in 
ono 17 
recall exactly, but something along lines of: Do you 
0 )003 17 
this case was that I've mentioned those three girls, 
sin.. 
18 
know Alan Dershowitz? And he says, I take the Fifth. 
a, 330 18 
They were all covered 
019 to 19 
That sort of, frankly, startled me, that — that this 
013312 19 
by a nonprosecution agreement. And the nonprosecution 
el St 35 20 
international sex trafficker was taidng the Fifth now 
a is ii 20 
agreement was highly unusual. 
sins/ 21 when asked about Mr. Dershowitz. 
on If 21 
I -- I had been a federal prosecutor for 
at nal 22 
And so I was stymied in trying to get 
a x.i, 22 
about four years, I had been a federal judge for about 
0313 04 23 
Information from Mr. Epstein at that point. I think 
el Sill 23 
five-and-a-half years, so I had seen a lot of -- of, you 
013307 24 
there were two depositions, if I recall correctly off 
a 15 >3 24 
know, nonprosecution types of arrangements. And one of 
a sew 25 
the top of my head, that -- that I had an opportunity to 
mars 25 
the things that was very unusual in this one is, it has 
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013679 
1 
what I'll refer to as the blank-check immunity 
01.3533 2 
provision. 
013014 
3 
There was a provision In the nonprosecution 
0155 40 4 
agreement that said, this agreement will prevent federal 
01.3510 5 
prosecution for international and interstate sex 
or 45 43 6 
trafficking, not only of Jeffrey Epstein, and not only 
sinus 7 
of the four women who were identified, but — and this 
mans 8 
is a direct quote: Any other potential co-conspirator, 
01)553 9 
close quote. 
m. ass 10 
And so that was unusual because what It — 
or so 11 
what it seemed to be doing was that somehow this 
01.n14 12 
agreement was quite out of the normal and had been 
013100 13 
designed to extend immunity to other people that might 
en au 14 
have been associated with Epstein. 
sines 15 
And I knew that that category included the 
014303 16 
people that were involved in negotiating this highly 
011x11 17 
unusual provision included Mr. Dershowitz, who had been 
0'3414 18 
heavily involved, not only in the drafting of the 
ova sr 19 
agreement, but had also been involved remarkably In 
oram 20 
attacking the credibility of these girls and saying 
nix 21 
things like, you know, it was — Epstein wasn't 
Ot3120 22 
targeting minor girls, which just struck -- you know, I 
033433 23 
was -- I don't want to use a technical term, 
413035 24 
gob-smocked, that a defense attorney with an obligation 
sus y 25 
to tell the truth was making a factual representation 
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1 
044/44 2 
01.37.47 3 
• 37s1 4 
013755 
013714 6 
013741 7 
neo 8 
O13403 9 
013401 10 
otsan 11 
elan 12 
0141115 13 
elan 14 
soils 15 
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man 17 
O1.31141 18 
ova* 19 
elan 20 
o,,. 21 
014137 22 
oleo 23 
01100 24 
013041 25 
87 
that are said there, but Alessi puts Mr. Dershowitz at 
the nest of this international sex trafficking 
organization. Let's see. I think he said four or five 
times a year, two or three -- you know, two or three 
days when he goes there. 
And let's be clear, I know Mr. Dershowitz had 
said at some points like, I'm an attorney, and that's my 
client and so forth. And Alessi said, no, but this was 
not in a — in a lawyer/client capacity; this is in a 
friend capacity. 
And so now we have Alessi putting him there 
at the same time when young girls were there. And one 
of the -- the — the things that I picked up, so is 
Alessi — you know, is he able to figure out who these 
girls are? 
A photograph 111- 
shown to 
Juan Alessi in the deposition, and he I.D.s the 
photograph as, you know, V.R., so he -- he had, you 
know, put two and two together. 
So now I've got V.R. coming to the house at a 
time when Mr. Dershowitz is also in the house, and 
apparently spending, you know, two to three nights there 
and doing this four or live times a year. 
Now, Alessi wasn't the only one. There was 
Alfredo Rodriguez who was there in about 2004 to 2005, 
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01 0144 
elf 47 
0121 VI 
013114 
013457 
011414 
011/141 
013701 
013703 10 
owes 11 
0137.4 12 
0137» 13 
014411 14 
warn 15 
0137 le 16 
elan 17 
014771 18 
01'3774 19 
ern 211 20 
01:3749 21 
wales 22 
033733 23 
0337)3 24 
41 55 25 
1 
2 
3 
4 
5 
6 
7 
8 
9 
86 
that Jeffrey Epstein was not targeting minor girls, when 
the Palm Beach Police Department had collected, you 
know, 23 of them that had all given essentially 
interlocking stories about how they had all gone over to 
this house, you know, the mansion, to give a massage and 
when they had gotten there, they had been sexually 
abused. 
So the kingpin wouldn't talk. The next 
echelon of the trafficking organization wouldn't talk. 
So the next step was to say, okay, let's see if we can 
find somebody, you know, lower level in there, you know, 
a household employee or something like that; maybe they 
will have some information about, you know, what this 
criminal organization is doing. 
Now, let's -- let's understand, you know, 
given the pervasiveness of the -- of the criminal 
activity, I -- I wasn't convinced that they were going 
to be able to get in there and start saying exactly what 
was going on because they might well be exposing 
themselves to criminal — you know, criminal 
culpability. 
But I -- I was able to read a sworn 
deposition from Juan Alessi, and Juan Alessi -- I 
think -- I don't know. Maybe Just to speed things up 
today, I won't go through all the things that are —
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01 J. 54 
01s101 
01 mw 
ono 
01 NY 
0.01-14 
00519 
88 
1 
after the time period of 
ut it's part 
2 
of the common scheme or plan that we've been discussing 
3 
here. 
4 
And so in 2005, Alfredo Rodriguez says, yeah, 
5 
again, Mr. Dershowitz is there at a time when these 
6 
massages are going on. When you start to look at Alessi 
7 
and Rodriguez's statements in context where they're —
8 
they're saying he's there at the same time the massages 
9 
are occurring, and with the West Palm Beach Police 
orlon 10 
Department reports showing that massages are of a sexual 
main 11 nature, again, it started to put two and two together. 
or me 12 
One of the things that was particularly 
ol yin 13 
important about Rodriguez's situation was that Rodriguez 
013434 14 
had an access to what's been called the lithe black 
al nu 15 
book, or I think he referred to it as the holy grail. 
01n40 16 
This was Jeffrey Epstein's, you know, telephone book 
o: nu 17 
where he had telephone numbers in it. 
oi no 18 
And so Rodriguez had that and, you know, I 
ran 19 
guess thought that this would be worth a lot of money 
013. so 20 
because it would -- you know, it would identify all of 
tans, 21 the people that have been sexually abused by -- by 
013054 22 
Jeffrey Epstein. And so he tried to sell it. The FBI 
sine 23 
busted him for that. 
stun 24 
And when the FBI busted him, now he's got 
014003 25 
this book. And so the book went to Alessi, and 
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034121 3 
01,133 4 
014134 
5 
014136 
6 
014130 
7 
01410 
8 
014145 
9 
014140 10 
89 
01.430S 
1 
according to a 
ton later FBI report, Alessi 
014301 2 
identified information that was pertinent to the FBI's 
014007 
3 
investigation. 
014011 4 
And so when I look at the little black book 
014014 
5 
that I have seen copies of, there are a handful of names 
o,40 
6 
in that black book that have been circled, apparently by 
ono,: 7 
Mr. Rodriguez, and one of the names that's -- that has 
014025 
8 
been circled is Alan Dershowitz. And so that, to me, 
014030 
9 
was suggesting that Mr. Rodriguez had identified, you 
01 4036 10 
know, Alan DershowItz as somebody who had information 
non 11 about this 
this international sex trafficking ring. 
era 12 
But just as a side note, but an important 
eto 13 
note, when the -- the thing that was circled on the Alan 
014466 14 
Dershowitz page was not a single phone number 
e, 400 15 
Indicating, you know, somebody had bumped -- you know, 
coos, 16 
Epstein had bumped into at one point. I believe there 
0140 36 17 
were 10 or 11 phone numbers that were associated with 
u 18 
Mr. Dershowitz that had all been circled and an e-mail 
014100 19 
address as well. 
DI 41174 20 
So that started to corroborate my sense that 
0, no: 21 
Mr. Dershowits was, indeed, a very close friend of 
0141'0 22 
Jeffrey Epstein. Now, I had then continued to do 
014114 23 
there's been reference today to, you know, using Google 
oin ol 24 
to do research and so forth. So I Googled Jeffrey 
otn,o 25 
Epstein and one of the things that pops up rather 
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014232 
1 
a lot of money. I mean, Epstein was identified as a 
01 402 2 
billionaire in this article, billionaire with -- with a 
in on 3 
8, so the record is clear. 
014234 4 
But he said, look, if Epstein lost all his 
Oleo 5 
money -- I'm paraphrasing here -- I would be, you know, 
el coo 6 
happy to walk down, you know, the Coney Island Boardwalk 
oleo 7 with him and discuss things with him, as -- you know, 
oleo 8 
even if he didn't have any money. 
°lose 9 
So now I'm seeing Dershowitz is a very close 
personal friend of Jeffrey Epstein. And then 1 started 
to look at flight logs. There were -- there were some 
very interesting things that I noticed on the flight 
logs. 
014204 10 
mass 11 
014301 12 
014301 13 
o'.,oi 14 
One of the things I noticed was when I began 
014107 15 
to, you know, get into this, that, you know, I was 
014113 16 
wondering, well, what -- well, how do these flight logs 
0143114 17 
come into the possession of, you know, law enforcement 
more 18 
agencies? And the answer turned out to be that they had 
014330 19 
been provided by Epstein's defense attorney and -- and, 
014373 20 
you know, coincidentally, I suppose, or in my mind, 
slur 21 suspiciously, they were not provided by Just any defense 
034130 22 
attorney on this rather large defense team. They were 
woo 23 
provided by one attorney according to Detective Recarey. 
0143.36 24 
Detective Recarey testified under oath that the flight 
01a30 25 
logs were provided to him by Alan Dershowitz. 
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non 
1 
rapidly Is an article in Vanity Fair. 
And what you see In that article is, you 
know, discussion about Mr. Epstein, but when you're 
trying to do a profile of someone, you try to figure out 
who that person's closest friends are. 
And so the Vanity Fair author had gone to 
Alan Dershowitz, you know, our -- Mr. Dershowitz here, 
and had asked him, hey, what do you know about Jeffrey 
Epstein? 
And, again, off the top of my head, you want 
sr 4117 11 
to know what 1 can remember right now. What I can 
014140 12 
remember right now Is that in the Vanity Fair article, 
01411.) 13 
the -- in the Vanity Fair article, Mr. Dershowitz said, 
014114 14 
I've written 20-some odd books; there's only one person 
*too 15 
outside my immediate family with whom I share drafts, 
moos 16 
and that's Jeffrey Epstein. 
enter 17 
So I took that as indicating a -- a very 
01010 18 
close personal association that -- you know, among the 
*ion 19 
people that 
that obviously he's sharing this -- these 
(non 20 
kinds of things that he wants evaluated before he shares 
woo 21 
them with the broader world, there's his immediate 
no,' 22 
family and then there's -- there's Jeffrey Epstein. 
*ton 23 
There was also another similar quote in the 
wow 24 
article that indicated that — that Mr. Dershowitz said 
ran 25 
that he wasn't interested in Epstein just because he had 
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01.4341 
1 
So one of the things that was -- was 
014343 
2 
interesting is, Dershowitz has had access to these 
014341 3 
flight logs, and now I'm beginning to wonder, well, has 
014346 4 there been an opportunity to sanitize those flight logs 
OS 43411 5 
or remove any incriminating information? 
OS 4111 6 
And — and one of the things that was 
014144 
7 
interesting about the flight logs that were produced --
0143$11 8 
I believe just so the record is clear, that was Exhibit 
034402 
9 
1 that -- if we could -- if I could refer -- I need to 
01404 10 
refresh my recollection as to -- well, I don't -- you 
01407 11 may not want me to look at documents. 
014404 12 
It was either Exhibit 1 or 2 this morning 
0i«1, 13 
during Dershowitz's deposition which was covering a time 
014415 14 
period of January to, I believe, September 2005. These 
on 15 
were flight logs that were produced by Mr. Dershowitz to 
e41.23 16 
the Palm Beach Police Department. 
014426 17 
And you wonder why did they stop in 
nun 18 
September -- you know, why stop in September 2005? 
ei errs 19 
What's the significance of that? Well, later on, 
01406 20 
additional flight logs were obtained, and sure enough, 
nos 21 
who shows up on an October 2005 flight log with Jeffrey 
014446 22 
Epstein? Mr. Dershowitz. 
en 444 23 
So that led to a suspicion that 
mass 24 
Mr. Dershowitz had provided to the Palm Beach Police 
at 44.1 25 
Department flight logs that, the time period of which 
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1 
for the production had been carefully crafted to keep 
II 440 
2 him out of it; in other words, to not produce the 
0,4411 3 
October 2005 version. 
014603 4 
The other thing I - I began to discover as I 
oi.ssos 
5 
started going through some flight logs, Dave Rogers, who 
014103 
6 
is one of I think about three pilots that — that 
01010 7 
Epstein regularly relied on to fly his — you know, he 
010 0 
8 
had very fancy — to use the technical term -- Jets. 
...sir 9 
There were about -- there were about three pilots there. 
.).42, 10 
One of them had some flight logs and that — 
co 4324 11 that was Pilot Dave Rogers, if I'm recalling his name 
Men 12 
correctly. And so later on in the litigation, the sex 
oven 13 
abuse litigation against Epstein, flight logs were 
°Ina. 14 
obtained from Dave Rogers, and it was possible to -- to 
O1450 15 
compare 
I'm sorry. I don't mean to — I want to make 
01040 16 
sure I get -- you know, the question is: How much can I 
01 40 17 
remember and I'm trying to make sure I get — get it all 
In. 
01410 18 
CO 4145 19 
04144 20 
And so the flight logs were produced from 
Dave Rogers. And so Dave Rogers produced some flight 
onssi 21 
logs, and some of the flights that he produced logs for 
DI 
64 22 
coincided with the logs that Mr. Dershowitz had provided 
m.sso 23 
to the Palm Beach Police Department, and there were 
ol.rol 24 
inconsistencies. And so that, again, aroused my 
04.0 25 
suspicion that maybe Mr. Dershowitz when he had — 
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0100 
2 
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0100 
5 
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8 
01060 9 
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oven 11 
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env 13 
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0044 16 
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O. OD 21 
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04721 23 
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95 
THE WITNESS: Right. No, I mean, I want to 
make -- I want to make clear that there was a lot 
of information that I was relying on in filing 
this pleading, and -- and, of course, the later 
pleading. So we are on the subject of flight 
logs. 
Flight logs showed that the flight logs 
Mr. Dershowitz had produced to Detective Recarey 
were incomplete and inaccurate. And so that led 
to concern on my part that Mr. Dershowitz had had 
an opportunity to sanitize the flight logs, 
had -- had -- had provided incomplete production, 
you know, obviously, very important production 
that the Palm Beach Police Department was looking 
at. 
Then we got some additional flight logs from 
Dave Rogers. And what those flight logs 
showed -- first off, lees talk again about 
the -- the production of those flight logs. 
My recollection is that Dave Rogers's flight 
logs were provided by Bruce Reinhart who was a 
former Assistant U.S. Attorney who had been 
inside the Southern District of Florida Office at 
a time when the Epstein case was the subject of 
regular discussion in that office. 
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MR. SCOTT: I Just got a call from a lawyer 
0144 01 2 
on the screen. His -- his phone is not working, 
014610 
3 
Epstein's lawyer, Darren Indyke. 
0146.0 4 
MR. SIMPSON: Why don't --
0,«,0 5 
MR. SCAROLA: Do you want to take a break for 
nee 6 
a second? 
O1460 7 
MR. SIMPSON: Well, why don't -- well, why 
olio.; 8 
don't we let him finish his answer? 
noon 9 
MR. SCAROLA: Let him finish the answer. 
010N 10 
MR. SCOTT: Yeah, let's do that. You're 
olog 11 
right. 
04621 12 
MR. SCAROLA: Although it may take a while. 
THE WITNESS: It -- it's, I mean, the 
question --
MR. SCAROLA: Yeah. But let's --
MR. SCOTT: I don't care. 
MR. SCAROLA: Okay. Let's -- let's go ahead 
and finish. 
MR. SCOTT: Let's go ahead and finish the 
answer. We heard this much. 
MR. SCAROLA: Good. Thank you. 
THE WITNESS: Okay. So there --
MR. SCOTT: I don't want to break him on a 
014021 13 
014621 14 
014621 15 
0.4621 16 
014625 17 
man 18 
014427 19 
614421 20 
0,4601 21 
man 22 
014631 23 
ern 24 
men 25 
roll. 
MR. SCAROLA: Thanks. 
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mon 1 
And Men he had gone to week for some kind of 
mos 2 
a -- a law firm or private operation that was 
0.4701 3 
located adjacent to Mr. Epstein's business. And 
01044 4 
so, now, Reinhart, who appeared to be being paid 
o14744 
5 
by Mr. Epstein, and certainly was adjacent to 
014741 6 
Mr. Epstein's business office, was producing 
01051 7 
these flight logs. 
8 
So that, again, aroused suspicion that the 
flight logs that were being produced would have 
been sanitized or inaccurate. 
But even — I mean, you know, I think the 
problem with -- you know, you can't sanitize 
everything. That would be too suspicious. And 
so what -- what was -- was -- what was evident on 
these fight logs was, for example, approximately 
ten flights by Mr. Dershowitz with Tatiana has --
has been discussed; with Maxwell; with Jeffrey 
fu en 18 
Epstein. One of them had one female, which, 
01 on 19 
again, in the context that I was looking at, 
014021 20 
seemed to be a potential code word for 
camon 21 
underage -- underage girl. 
Of 4412 22 
And so those flight logs showed, you know, 
main 23 
again, close association and travel with --
014440 24 
with -- with — with Mr. Dershowitz, and 
0,4047 25 
Mr. Epstein. 
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elms, 
1 
Another thing that I had, and I will not 
010116 1 going Into any confidential communications or 
Gin 2 reveal any privileged communications here or any 
onion 2 trying to waive in any way, I knew that David 
011.1. 3 confidential information, but on December 30th, I 
01 531,1 3 Boles had agreed to repres-
ihai. 4 was aware that one of the preeminent lawyers in 
oiwn 4 which gave me additional confidence in the fact 
014007 5 the Unites, 
had agreed to 
015030 5 that I was also representing this young woman in 
014410/ 
6 represen 
nd given the vast 
ci,om 6 her effort to bring sex traffickers to Justice, 
01011 7 amount of business that -- that, you know, tries 
015037 7 and those who had sexually abused her to justice. 
01411 8 to get in the door -- 
01 tO 41 8 
And so those are things that come to mind 
mais 9 
MR. SIMPSON: Could I interrupt? I mean, I 
.,w. 9 immediately as -- let me just take a second and 
moo 10 think we are going towards a waiver here. 
oin 10 see if there were other things regarding 
0,.01. 11 
MS. McCAWLEY: Yeah. No, no, no, I do not -- 
015010 11 Dershowltz that -- that come Immediately " 
01.4020 12 
MR. SIMPSON: We can't have testimony 
41 3141 12 immediately to mind. 
014911 13 about -- 
el sun 13 
Oh, one of the things was in the Jane Doe 102 
014021 14 
MS. McCAWLEY: Yeah. 
0.310, 14 complaint, which alleged academicians that had --
014022 15 
MR. SIMPSON: -- this is one of the most 
01”14 15 that had abused -- sexually abused Jane Doe 3, 
01011 16 
respected people in the country, or lawyers In 
013110 16 there -- there were -- so that raises a question, 
014931 17 the country, and then you won't answer the 
elm. 17 obviously, of who were the academicians that Bob 
01.4020 18 questions -- 
015130 18 Josefsberg had Identified? 
014024 19 
THE WITNESS: Okay. 
401111 19 
I can't recall, actually. Let me -- the 
01024 20 
MR. SIMPSON: -- you said not to answer. 
01 6113 20 record should be dear, I can't recall 
m 492, 21 
MS. McCAWLEY: Oh. Well, describing David 
015114 21 Immediately whether it was singular or plural. 
°two 22 Boies in general -- 
011130 22 It may have been plural, but if it's singular, I 
°tam 23 
MR. SIMPSON: I agree with the description. 
iiI51,6 23 don't want to suggest that there were other 
014031 24 
MS. McCAWLEY: -- doesn't constitute a 
oisio 24 academicians, but at least one academician had 
01403) 25 waiver. 
015141 25 sexually abused Jane Doe 3, according to the 
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100 
O. 4032 
i 
MR. SIMPSON: He's a distinguished lawyer. 
01510 1 complaint that had been filed by Bob Josefsberg. 
0143:1 2 
MR. SCAROLA: And I don't think we are 
oi si 4, 2 
There were two things that were of interest 
014031 3 getting beyond anything that is a matter of 
015140 3 to that: One was that Mr. Epstein, the man that 
014037 4 public record. 
416161 4 I wasn't able to get information from because he 
014031 5 
MR. SIMPSON: I just -- I -- 
016134 5 was invoking the Fifth, had refused or declined 
014.3. 6 
MS. McCAWLEY: But I appreciate you -- 
01$157 6 to file an answer to that complaint. 
014034 7 
MR. SIMPSON: Be aware of waiver. 
oi raw 7 
Rather than deny the allegations, he had, 
014050 8 
MS. McCAWLEY: -- letting me know that. 
01$241) 8 ultimately, it's my understanding -- I don't have 
moo 9 
THE WITNESS: All right. I will be -- I will 
01006 9 inside information and I'm not trying to waive 
014011 10 
not waive anything, and if I start to do that, I 
01 6101 10 any information, but my understanding is that 
01400 11 would certainly request the opportunity to -- to 
01670 11 rather than answer the complaint, he settled the 
in ..s 12 retract what I'm doing, but I was aware -- since 
0,52ii 12 
case through the payment of some kind of 
014.4 13 the issue is, well, what's in the public record, 
015113 13 compensation that Jane Doe 102 found desirable 
014060 14 I was aware that, you know, probably the most 
*Inn 14 for dropping her claim. 
01 052 15 significant United States Supreme Court case 
eislo 15 
The other thing that I found interesting is 
014135 16 argued in the last 20 years was Bush versus Gore, 
015111 16 that Josefsberg's partner, I believe it is, 
0105. 17 which was a case that essentially determined who 
01 US 17 
Miss Ezell, had been to some of the depositions 
01 500i 18 was going to be President of the most powerful 
01970 18 of, for example, I believe Juan Alessi and 
*ism 19 country in the world. 
awn 19 Alfredo Rodriguez. And I believe at least one of 
oi soei 20 
There were two attorneys who argued that case 
0,034 20 those, and perhaps both of those. And she had 
015005 21 in front of the United States Supreme Court, and 
oin 21 asked questions about Alan Dershowitz in those 
inn 22 arguing for the Democratic Presidential 
015713. 22 depositions, but had not asked questions about 
eiwo 23 
Candidate, Al Gore, was David Boies. 
01510 23 other academics in those depositions. 
41 01,7 24 
He had put his credibility on the line in 
Gino 24 
So that led me to conclude that Bob 
ti son 25 arguing the Bush versus Gore case, and without 
013231 25 Josefsberg and his outstanding law firm had 
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015214 
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Sluts 
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05 007 
015303 
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0101$ 12 
stun 13 
etsni 14 
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masa 18 
um 33 19 
011130 20 
ciao 21 
02010 22 
020103 23 
eons 24 
ware 25 
101 
1 
identified Alan Dershowitz as someone who had 
2 
information relevant -- and let's be dear, that 
3 
this is not a lawsuit about some contract dispute 
4 
or something -- that he was someone who had 
5 
information relevant to the sexual abuse of 
6 
underage girls and, indeed, they were asking 
7 
questions about what Information -- what 
8 
information he might have. 
9 
Another -- I know, I remember now, there's a 
whole other line of things that -- that I had in 
mind at the time, and I think since you want to 
test my memory -- I'm not -- let me be dear. 
I'm not claiming I have a superb memory. I have 
an average memory, but this is a subject that's 
very important to me, and so I've worked, you 
know, very hard to get all the information. 
I would like to take a break. 
MR. SCAROLA: Sure. Take a break. 
THE VIDEOGRAPHER: We are going off the video 
record, 3:27 p.m. 
(Thereupon, a recess was taken.) 
THE VIDEOGRAPHER: We are back on the video 
record, 3:41 p.m. 
THE WITNESS: I want to continue my answer. 
I'm sorry. I got emotional there for a moment. 
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02525 
03 Of 
020112. 
02000 
02002 
02034 
020114 
03001 
030341 10 
0040 11 
mot« 12 
020140 13 
anew 14 
war. 15 
cows: 16 
arm. 17 
*flora 18 
ciarci 19 
021407 20 
0
,011 21 
ann. 22 
°nag 23 
071031 24 
21021 25 
103 
let me clear all of that misunderstanding up. 
2 
You know, that's -- frankly, if I had gotten 
3 
something like that, that's what I would have 
4 
said. 
5 
The answer that came back was -- from 
6 
Mr. Dershowitz was something along the lines of, 
7 
If I remember correctly, well, tell me what 
8 
you -- you -- tell me what you want to know and 
9 
I'll decide whether to cooperate, was I think 
the phrase that was used. And -- and so there 
was an attempt, you know, a 2009 attempt, a 2011 
attempt to get information from W. Dershowitz. 
Then there was another subpoena without 
deposition for -- for documents. You know, we 
have heard a lot about records in this case that 
could prove Innocence. There was a records 
request to Mr. Dershowitz In 2013. And, again, 
my understanding was that there was no -- you 
know, no documents were provided on that. 
And so those -- I had that Information. 
Another bit of information that I had was that in 
2011, I believe in early April -- this Is not 
Ieged information from 
Is Is a telephone call that 
she placed from Australia where she had been 
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awn 1 
I want to do a good job fo 
04412 
2 
on -- on representing all t 
ma,. 3 
that Is available to support her. 
02100 4 
The next thing that I was thinking of was, 
ram I. 
5 
all right, then the question Is: Well, what does 
021423 6 
Mr. Dershowitz have to say about all this? So I 
0140 2? 
7 
started to look at the information on that as 
021424 
8 
well. 
ran 9 
In 2009, there had been a deposition request 
inn 10 
sent to Mr. Dershowitz, and I -- I saw a document 
024:13/ 11 
showing that that had actually been served on - - 
am do 12 
on him, and, you know, to the extent that what I 
one« 13 
saw was a -- I think a receipt from the process 
one 4. 14 
server, or something along those lines, so I saw 
eras, 15 
attempt to contact him in -- in 2009. 
010053 16 
And then I saw an additional attempt to 
mess 17 
contact him in 2011. Mr. Scarola had sent him a 
ono' 18 
note and there was, you know, some back and 
oimii 19 
forth. The -- the one note that -- that jumped 
nom 20 
out to me was one in which Mr. Scarola had 
mom 21 
written to Mr. Dershowitz, I think the phrase 
020•12 22 
was: Multiple witnesses have placed you in the 
ow. 23 
presence of Jeffrey Epstein and underage girls; 
rain 24 
would like to depose you about those subjects. 
tams 25 
And the answer that came back was not, well, 
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0021 
2 
onI 3 
izirof 4 
02.102. 5 
au, 41 6 
woo 7 
oakum 8 
021044 9 
an. 10 
nu 11 
*met 12 
nloi 13 
021116 14 
gene; 15 
021112 16 
02114 17 
021”. 18 
0311 11 19 
021111 20 
021121 21 
021123 22 
02 1120 23 
021124 24 
01131 25 
104 
essentially forced into hiding by Jeffrey 
Epstein. She managed to escape and was hiding 
out in -- in Australia, and that she would --
that somehow, you know, Mr. Scarola and 
Mr. Edwards were able to reach her and there was 
a telephone call that was made. 
And in that telephone call she Identified 
Alan Dershowitz as someone who would have 
relevant information about Jeffrey Epstein and 
the sexual abuse of underage girls. 
And so I had that Information as well. So 
that, as I understand, the question was: What 
could I recall off the top of my head with regard 
to the factual basis for information connecting 
Mr. Dershowitz with the sexual abuse of minor 
girls, plural, and that, sitting here at this 
moment, is the best that I can recall for the 
information along those lines. 
BY MR. SIMPSON: 
Q. Was that answer --
MR. SCAROLA: Excuse me. Before -- before 
you go on to another subject, Professor Cassell 
is entitled to refresh his recollection to give 
you a complete response. So why don't you go 
ahead and do that now. Make sure you've covered 
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107 
stns. 1 
everything. 
02 034 2 
MR. SIMPSON: I'm -- I think I get to ask the 
awn 3 
questions, but I was going to ask the same 
nom 4 
question. 
02 Ill. 5 
MR. SCAROLA: Wonderful. We are on the same 
ono 6 
page. 
co no 7 
BY MR. SIMPSON: 
a nn 8 
Q. 
Mr. Cassell, you -- you mentioned that you 
an:„ 9 
had something that you had prepared --
a,... 10 
A. 
Yes. 
a,... 11 
Q. 
-- that would summarize 
02016 12 
A. Right 
011140 13 
Q. 
-- your knowledge. 
otitis 14 
A. 
Right. 
sin.. 15 
Q. 
And now that you have exhausted your 
02 
SI 16 
recollection, could you produce that and let's Just mark 
02 I'S. 17 It .-
02014 18 
A. 
Yeah, sure. 
ono 19 
Q. 
-- as an exhibit? 
02 030 20 
MR. SIMPSON: We are up to Exhibit 3, I 
021110 21 
believe. Cassell 3. 
ozi?oi 22 
THE WITNESS: Right. Now, there -- there are 
olio 23 
two parts to this --
ono 24 
MR. SIMPSON: Can we mark it first and 
room 25 
then --
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moot 1 
THE WITNESS: Yeah. I just want the record 
num 2 
to be clear, that I'm only looking — there's 
02 n .1 3 
there's a pre-December 30th section and a 
az u,o 4 
post-December 30th section, so the top part is 
02 013 5 
the -- Is what I was working off of. 
moll 6 
BY MR. SIMPSON: 
nee 7 
Q. 
Okay. 
02 $713 8 
A. 
Now, underneath this is — you know, If you 
ovine 9 
have questions about what happened after December 30th. 
OZ 120 10 
Q. 
So you're -- you're prepared to produce the 
0212n 11 
entire document, but you're clanfying? I don't -- I 
oz an 12 
don't want to ask you -- If you're going to use it in 
not 13 
your testimony, then we will mark the whole thing. 
02 02) 14 
MR. SCAROLA: Mark the whole thing. You can 
can 15 
use it. 
ono 16 
MR. SIMPSON: Mark the whole thing and I'll 
nun 17 
ask you about it. 
02030 18 
THE WITNESS: That would be great. 
O2O3119 
Absolutely. 
non 20 
MR. SIMPSON: All right. I'm Jag to ask 
Ca )2 3S 21 
the court reporter to mark as Cassell Exhibit 3, 
en 22 
a one-page document that the witness has just 
01242 23 
handed to me. It's mostly typed. It has some 
ion.. 24 
handwriting on it. 
nos. 25 
(Cassell I.D. Exhibit No. 3 - one-page 
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• na 1 
document produced by the witness was marked for 
nine 2 
identification.) 
020 TO 3 
THE WITNESS: All right. So let me -- If I 
013311 4 
could look at this to see If It -- the top 
non 5 
portion of it to see if it refreshes my 
020.0 6 
recollection about 
02 $3 IS 7 
BY MR. SIMPSON: 
own 8 
Q. 
Could I Just see it for one second? 
On WI 9 
A. 
Sure. Absolutely. 
non 10 
Q. 
All right. Yeah. Let me just clarify one 
02132) 11 point before you do that. 
071322 12 
A. 
Yes, sir. 
02130 13 
Q. 
In your answer, were you referring to the 
02)32e 14 
evidence you could recall or the information you could 
ono 15 r 
II th 
u 
rt d your allegations as to both 
02 ISM 16 
other minors, or were you treating 
02nm 17 
those separately? 
021337 18 
A. 
No, I was not treating those separately. I 
oz no 19 
was — for me, there's a common — what 
what the law 
021342 20 
refers to as a common scheme or plan in a --
02110 21 
Q. 
Okay. 
nom 22 
A. 
— a criminal conspiracy for international 
no.. 23 
trafficking that Involved not just a single girl, but 
ono 24 
multiple girls. So the answer was -- was with respect 
0713 S2 25 to -- to multiple girls. 
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02 013 1 
Q. 
Okay. So I may have some questions to 
pass 2 
distinguish further between those two •-
021W 3 
A. 
Yes. 
021314 4 
O. 
-- but is it fair to say that -- and I 
021402 5 
realize you're going to refresh your recollection, but 
oznin 6 
that you had exhausted your recollection of the basis 
to °of 7 
for the allegation in this Exhibit 2, the motion to join 
nuts 8 
as to both Miss Roberts and other minors? 
02,40 9 
A. 
Yes. 
oa,ur 10 
Q. 
Okay. So then, now, take a look at that and 
021420 11 
tell me if there's anything there that refreshes your 
nun 12 
recollection as to something that you have not yet told 
ono 13 
me about. 
o no 14 
021444 15 
*2144* 16 
Rust 17 
02 II 53 18 
02,00 19 
canoe 20 
or sae 21 
nuts 22 
nu„ 23 
02 IS 1S 24 
ono 25 
A. So this refreshes my recollection. Sarah 
ante 
ere. Adrianna Mucinzka was [lac run name or [nose --
that's the second echelon of the — of the -- of the 
criminal conspiracy. 
Oh, this refreshes my recollection that 
Jeffrey Epstein had answered some questions In the civil 
litigation. He provided, for example, names of — of 
some people who were involved, but he took the Fifth 
when asked — he took -- he provided names of some 
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