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nor is 
1 
but, obviously, Epstein and his criminal associates have 
on 
1 
intended to be a direct quote? 
11101/0 
2 
had the ability to — to destroy the evidence that's 
00034 2 
MR. SIMPSON: Back up. 
010721 3 
been — that we have been trying to gather. 
nu 
3 
BY MR. SIMPSON: 
010711 4 
Q. 
And in -- in your answer a couple of 
nom 4 
Q. 
What is your understanding of Judge Marra's 
own 5 
questions -- 
031041 5 
ruling with respect to these allegations about Professor 
non 6 
A. 
I - I'm sorry. I shouldn't say "destroyed." 
01144. 6 
Dershowitz and Prince Andrew? 
run 
7 
They have been able to conceal would probably be a more 
0)0344 7 
A. 
That they were premature. 
03 0/ 30 
8 
accurate term, the — the evidence that we are trying to 
mins 8 
Q. 
That's your understanding of his order? 
030733 9 
gather. 
onoa 9 
A. 
Yes. 
030733 10 
Q. In my answer -- in my answer -- 
mono 10 
Q. 
Okay. 
wen, 11 
A. 
Yeah. 
anew 11 
A. 
And I — maybe I should — I see some 
030733 12 
Q. 
-- in the question and answer, your answer to 
mod 12 
skepticism there, so let me explain why I think those 
030131 13 
my question a couple ofquestions 
o 
ou talked about 
03100) 13 
allegations —
03 07 0 14 
whether Mr. Epstein a 
have the 
03 100. 14 
Q. 
Yeah. Well, we can pull --
worm 15 
same or equal ability to disc ose -- 
031001 15 
A. -- are appropriate. 
wane 16 
A. 
Right. 
011001 16 
Q. -- we will pull out the order itself --
wen, 17 
Q. -- what these prominent politicians, 
031.01 17 
A. 
Sure. 
03010 18 
et cetera, had done, correct? 
on 18 
Q. -- at the appropriate time, but first, your 
ono 34 19 
A. 
Correct. 
ea loos 19 
understanding Is that the Judge didn't find that those 
03 OSS 20 
noir 21 
a 
Without attempting to make any comparison, 
you would agree, would you not, that as of December 
03 low 20 
031013 21 
allegations, at the time they were made, were so 
irrelevant to the case, that they should be stricken 
030401 22 
30th, 2014, Miss Roberts had the ability to name the 
03101S 22 
from the public record? 
roam 23 
names of the people who are referenced in this document? 
wren 23 
A. In that pleading at that time, remember, we 
0300,0 24 
A. Physical ability, yes. 
ea nn 24 
had in our — our brief — let me explain the — the 
one I, 25 
Q. 
And -- well, let me ask this: You say a 
co an 25 
nine reasons why we thought that those allegations were 
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weer-known prime minister. Is that Prime Minister 
town 1 
relevant to the case, since I think your question calls 
010022 
2 
Barak? 
colon 2 for that. 
010022 
3 
ow, 4 
MS. McCAWLEY: I'm gonna instruct you not to 
rev 
communications you had 
in 4121 3 
03 1031 4 
Q. 
Are those the nine reasons you gave 
yesterday? 
030024 
5 
an 
6 
Wit 
e specifics of her 
cou 
e Individuals. 
031031 5 
neon 6 
A. No, I didn't have a chance to. 
Q. 
Are they the nine reasons that are set forth 
030031 7 
BY MR. SIMPSON: 
oi SO >A 
7 .in your -- in your brief? 
one rz 8 
Q. Is one of the other -- one of the powerful 
011.36 8 
A. 
They are. Those are the nine reasons that 
0300 34 9 
business executives, Les Wexner? 
wax 9 
are set forth In the brief. 
NOB )7 10 
MS. McCAWLEY: Again, same instruction. 
031031 10 
Q. Okay. And -- and Judge Marra had that brief 
Ince a 11 
BY MR. SIMPSON: 
*ion 11 in front of him when he held that, these allegations 
omen 12 
Q. 
Okay. Now, you mentioned yesterday -- well, 
w.0 .s 12 
were so not relevant to the issues before the court, 
Gm n 13 
a moment ago, you testified that these -- In your view, 
0110.. 13 
that they would be stricken and not part of the public 
0301.11 14 
these allegations about other powerful men furthered 
noon 14 
record? 
03004 15 
Miss Roberts' legal position in the case, correct? 
woo 15 
A. 
At that time, In that particular pleading — 
anew 16 
A. 
Yes. 
roNS4 16 
I think you're mischaracterizing Judge Marra's ruling In 
omen 17 
Q. 
And it's also your position, I assume, that 
wilco 17 
its entirety. He specifically said that the allegations 
030310 18 
the allegations regarding Professor Dershowltz and 
03 ,+01 18 
could be reasserted, If they were relevant to issues 
030014 19 
Prince Andrew furthered Miss Roberts' legal position; is 
03 330. 19 
that are — that were coming up. And so, in following 
norm 20 
that right? 
031107 20 
that ruling, we went to the U.S. Attorney's Office, 
030111 21 
A. 
Absolutely. 
on lo 21 propounded discovery requests and said, look, we believe 
nor PI 22 
Q. 
Does the fact that Judge Marra struck those 
03 t113 22 
you're sitting on information that Dershowitz was, you 
030124 23 
allegations as impertinent, scandalous, and completely 
rums 23 know, connected with the -- with the criminal 
030930 24 
Irrelevant to the case, cause you to reassess? 
031'17 24 
trafficking here; we would like you to produce those 
01032 25 
MR. SCAROLA: Excise me. Is that -- is that 
031110 25 
documents. 
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021120 
1 
And rather than say, My, we don't have any 
031341 1 
the United States Attorney for the Southern District of 
sally 
2 
such documents, the U.S. Attorney's Office gave us the 
Oen 46 
2 
Florida to represent victims, correct? 
rens 
3 
response indicating, to our view, that there were such 
0)1344 
3 
A. 
Yes. Through the — through the NPA, yeah, 
031122 
4 
documents, and as you know, since you're one of 
until 
4 
there was an apparatus that led to his selection. 
011124 
5 
Mr. Dershowitz's attorneys, we have drafted a pleading 
0113S4 
5 
Q. 
And does that answer reflect holding the U.S. 
nun 
6 
now to try and collect that information, that law 
031401 
6 
Attorney for the Southern District of Florida in that 
Gall a 
7 
enforce — federal law enforcement agencies have 
Num 
7 
office in high regard? 
Gan,. 
8 
collected, and — and to figure out the appropriate way 
031404 
8 
A. 
Sure. 
031142 
9 
to litigate that so that we can get that information and 
031401 
9 
Q. 
Do you contend that at the time the United 
011144 10 
move forward with the case. 
011411 10 
States Attorney for the Southern District of Honda 
031116 11 
That's just one example of -- of how the 
rotor 11 negotiated the NPA, they knew that Professor Dershowitz, 
or Jr,. 12 
allegations, if they were premature at that point, are 
031420 12 
himself, had been involved in abuse of minors? 
iniru 13 
no longer going to be premature as the case moves along. 
0314n 13 
A. 
I don't know exactly what Information they 
own 14 
Q. 
Is It or is it not your understanding that 
031427 14 
had. I do know that we have been propounding discovery 
031201 15 
Judge Marra ruled that the allegations in this pleading 
roux 15 
requests on all of these subjects, including 
011204 16 
in front of you were so irrelevant to the pleading in 
., ,.n 
16 
Professor 
Dershowitz's involvement, when the U.S. 
03, 04 17 
which they were stated, that they should be stricken 
031435 17 
Attorney knew. They are asserting privilege over that. 
0.1217 18 
from the public record? 
031437 18 
I would wish they would waive the privilege or at least 
Dun 19 
A. 
In that particular pleading at that 
021430 19 
provide the information to pro bono crime victims' 
was 20 
particular time, that's right. 
43314o 20 
attorneys that they have, so we can get to the bottom of 
031221 21 
Q. 
Does that cause you to reassess, in any way, 
routs 21 
this. 
aux. 22 
having filed this document? 
01 ,..1 22 
But there have been, you know, a nonstop 
011223 23 
A. 
Well, I think certainly as a tactical matter, 
031447 23 
series of assertions of privilege and other barriers 
031224 24 
we should have reserved the — the allegations for -- 
0314441 24 
Interposed against us in this case, and I think 
011231 25 
for another motion. I - I think that's -- you know, 
eau>, 25 
Inappropriately 
so, and — and we have been arguing that 
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certainly, with the — you're -- now, we are now sort of 
aims 1 
now for a number of years. 
03 In. 
2 
speculating, 
would we have done something different if 
03,4m 
2 
Q. 
Would you agree with me that if the United 
0312M 
3 
we knew that? And the answer to that is, sure, we would 
0313011 
3 
States Attorney's Office had been aware that Professor 
Nun 
4 
have tried to do something that Judge Marra thought was 
ii nu 
4 
Dershowitz had engaged in sexual misconduct with minors, 
031244 
5 
the appropriate way to handle it, so... 
0 no 
5 
or himself had observed Mr. Epstein do so, that it would 
031216 
6 
Q. 
And Judge Marra also reminded counsel of 
OD 44 .2 
6 
have been improper and unethical for them to let Mr. — 
05120 
7 
their Rule 11 obligations; didn't he? 
031312 
7 
Professor Dershowlez negotiate the terms of the NPA with 
011251 
8 
A. 
That's right. Yeah. 
ran io 
8 
them? 
011253 
9 
Q. 
And did it cause you to question, not 
wan 
9 
A. If they had direct personal knowledge of 
co use 10 
tactics, but whether you were acting properly in filing 
oa nxi 10 that, sure. I mean, the — the -- but the realities are 
cal3.00 11 
this? 
021423 11 a little bit more complicated in that Professor 
031340 12 
MR. SCAROLA: Excuse me. I -- 
nal. 12 
Dershowitz, over the last couple of days as 
031302 13 
MR. SIMPSON: I'm just asking if it caused 
03027 13 
frequently -- has frequently used the word "continuum," 
011303 14 
him to reassess. 
ouzo 14 
and so if they were certain of that, it absolutely would 
011304 15 
MR. SCAROLA: I understand what you're 
031031 15 
have — would have been unethical. 
won 16 
asking, and you're asking him about his mental 
vain, 16 
The question Is: Well, what if they had a 
min, 17 
processes in connection with pending litigation. 
0 ISIS 17 
suspicion or what if — you know, a reasonable suspicion 
Ingo 18 
That's work product. I instruct you not to 
03 ID as 18 
or a possible suspicion. Those are the kinds of 
031313 19 
answer that question. 
co iss 19 
dimensions that you've got to, you know, take into 
anti 20 
BY MR. SIMPSON: 
in isu 20 
account in the real world about, you know, what they .11.
won 
21 
Q. 
All right. You testified yesterday that one 
',nu 21 
what they would have done. 
to 1719 22 
reason that you found the filing of the complaint on 
03 IS SO 22 
I mean, 
it seems pretty dear, for example, 
in ill? 
23 
behalf of Jane Doe 102, who is-03 
VS S2 23 
that at some point, you know, later on, they got a black 
a I> 56 24 
the -• Bob Josefsberg and -- and why that was 
Gann 24 
book in which Professor Dershowitz's name had been 
oaun 25 
significant was that Bob Josefsberg had been selected by 
to is se 25 
circled. Now, what they did with that information, I --
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enteco 
1 
I don't know. 
03 140 
2 
Q. 
And what they did with the fact that Courtney 
03 1404 
3 
Love and Donald Trump were circled, you don't know also, 
03 403 4 
correct? 
o tea 
5 
A. 
That's right. Fair point. 
01 'sw 
6 
Q. 
But somehow It's suspicious as to 
one to 
7 
Mr. Dershowitz, but not as to anyone else? 
Oa lea 
8 
MR. SCAROLA: Objection. Argumentative. 
co xi, 9 
THE WITNESS: And I'm -- I'm glad to argue on 
Olt , 4 10 
that point, let me, because they --
Cl lc '4 11 
MR. SIMPSON: I'll withdraw the question. 
man 12 
THE WITNESS: All right. Because I would 
(*tea 13 
have a --
oleic 14 
MR. SIMPSON: Let 
Oatc$: 15 
THE WITNESS: -- a substantial argument on 
mare 16 
that. 
Omni() 17 
MR. SIMPSON: I -- I will withdraw the 
war, 18 
question. 
03 16 n 19 
BY MR. SIMPSON: 
01%24 20 
Q. 
With respect, again, to the 
$6 le 21 
MR. SCAROLA: And I'll withdraw the 
Or. 12 22 
objection. 
03 16)2 23 
MR. SIMPSON: Thank you. 
03 1.1.3 24 
BY MR. SIMPSON: 
was 25 
Q. 
At the time that you filed this joinder 
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03 I/ 50 
1 
certainly believe I have a good-faith basis, along with 
nay 
2 
my co-counsel, to explore that subject, and try to see 
oi leo 3 
how someone who is fifth in line to the British Throne 
03 IOW 4 
might have been able to use the contacts and power that 
roam 5 
he has to influence a -- a -- a disposition in this --
es nis 6 
in the Crime Victims' Rights Act case that it would have 
awe 7 
been favorable to one of his friends and potentially 
colon 8 
favorable to himself. 
men 9 
Q. 
And -- and you have that view, 
mesa 10 
notwithstandng that the government had represented they 
non 11 
have no record of that? 
wino 12
A. 
They didn't -- no, no, no, no. Let's not — 
nun 13 
not -- let's not slip and try to get me to admit 
nee 14 
something that is not what the record reflects. The 
tattle 15 
government said they did not have documents. They did 
SI WO 16 
not say that they didn't have any information along 
pea 17 
those lines. 
$111441 18 
To the contrary: They asserted a whole 
03 110 19 
series of privileges every time we tried to got 
nun 20 
information along these lines. So the fact that they 
031440 21 
didn't have a letter, signed Prince Andrew, saying, 
num 22 
please do the best you can for this convicted sex 
031134 23 
offender is one thing. That's the request for 
loins 24 
production of documents. 
coup 25 
But they never said that they - they --that 
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nem 1 
something along these lines had never happened and, to 
03 1903 
2 
the contrary, we were faced with assertions of privilege 
now 3 
over roughly, if 1 remember correctly, about 10,000 
cones 4 
pages of documents where a whole host of privileges were 
nun 5 
being asserted. 
Oiler/ 
6 
Q. 
Do you think it's credible that the United 
03 1111 7 
States Attorney's Office would be discussing an /IPA with 
03 1120 8 
a member of the British Royal Family? 
cairn 9 
A. 
Not directly, but there certainly are 
now 10 
possibilities of surrogates. I -- my -- somebody who is 
own 11 that powerful certainly wouldn't go out at it directly. 
mita 12 
What they would probably do Is try to find the best 
wen 13 
lawyers they could around the United States and -- and, 
0/1913 14 
you know, and some of the, you know, big-named lawyers 
coins 15 
and try to bring them in there to — to work a deal. 
0119 34 16 
That's, I think, how, you know, we're -- you're 
wee 17 
asking -- your question is asking for speculation and 
ono 18 I'm saying that -- that based on, how would you 
wires 19 Influence a deal In an American criminal justice system? 
nun 20 
You go try to get the best defense lawyers you could and 
most 21 see -- you know -- you know, figure out which political 
0x,44. 22 
party was in power; and try to get people who are 
mew 23 
well-connected to that political party, things like 
warm 24 
that. 
mere 25 
305 
03 so 1 
motion, Exhibit 2, you knew that the United States 
a)* u 2 
AttOrney'S Office had denied having any contact -- any 
w an 3 
documents reflecting any contact with Prince Andrew; 
mall 4 
isn't that In*? 
03%0 
5 
A. 
They had - there were — there were various 
irs. 6 
discovery requests that had been propounded, and I think 
was 7 
with regard to one, they had denied, and my recollection 
a art 
8 
Is with regard to another, where there had been an 
co ma 9 
assertion of privilege. 
aim 10 
Q. Is it not true, that before December 30th, 
min 11 2014, in response to a request asking the government: 
03 17.,s 12 
Are there any documents reflecting contact with -- by 
mum 13 
Prince Andrew regarding the NPA, the government 
anti 14 
represented, there were none? 
tome 15 
A. 
That 
with regard to the -- you're talking 
roux 16 
about RFPs, request for production of documents, I 
03 
12 17 
believe that's -- I believe that's correct 
wan 18 
O. 
And on December 30th, 2014, knowing that, you 
la IT 36 19 
named Prince Andrew in this motion, correct? 
03 17 40 20 
A. 
Correct. 
mini 21 
Q. 
And is it your testimony that you believe 
03 11 40 22 
that Prince Andrew somehow attempted to influence the 
aria 23 
negotiations of an NPA in the United States as to 
souse 24 
Mr. Epstein' 
otos, 25 
A. 
I don't have direct evidence of that, but I 
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have gone about trying to — to put pressure for a — a 
favorable plea deal. 
Q. 
And that's what you Just referred to as 
speculation, correct? 
A. Well, your question said: Well, how would 
they go do this? And I -- I -- I gave you my answer as 
to how I think somebody could well do that, yes. 
Q. And -- and your pleading doesn't allege how 
someone would do it; it alleges that they did it; isn't 
that correct? 
A. Did what? 
Q. Let me -- let me rephrase it. 
A. No. I - I - the — 
Q. 
I -- I withdraw the question. 
A. Yeah. 
Q. 
We only have about ten minutes here. There 
are a couple of things that I --
A. Sure. Absolutely. 
Q. -- wanted to get before we -- we will come 
back to these when we resume. We have a lot more 
questions. 
A. Great. I look forward to it. 
MR. SIMPSON: I'm going to ask the reporter 
to mark as Exhibit -- what are we up to -- 6, 
Exhibit 6, a document bearing Bates stamp numbers 
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032200 3 
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037242 
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03724/ 
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032260 10 
03 2204 11 
ay.. 12 
carte 13 
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ware. 16 
on% 17 
032304 18 
onto 19 
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11) 23 01 22 
0321n 23 
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310 
know — I can't recall sitting here today whether 
Nightline, is that an ABC program or NBC or -- or some 
other network 
Q. If you look at the exhibit, the e-mail in the 
second -- the bottom half of the first page, it has her 
e-mail address. Does that -- eabc.com? 
A. 
Yeah, yeah, yeah. That's good. Thank you. 
Q. 
So ABC. So in this e-mail on January 4th of 
2015, you told Miss Jesko of CBS News (sic] that --
MS. McCAWLEY: ABC. I'm sorry. You said 
CBS. 
MR. SIMPSON: I'm sorry. 
THE WITNESS: There you go. 
MS. McCAWLEY: Now, we are really confused. 
MR. SIMPSON: I'm sorry. Let me start again, 
and thank you. 
MS. McCAWLEY: Sure. 
BY MR. SIMPSON: 
Q. In this e-mail on January 4th, 2015, you told 
Miss Jesko of ABC News, quote: I represent, along with 
Brad Edwards in Florida, the young woman who was 
sexually abused by Prince Andrew and Alan Dershowitz, 
period, close quote. Have I quoted that correctly? 
A. 
Q. 
You have. 
So is it fair to say that in this e-mail, you 
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03 21 01 
I 
BE-510 through -514. 
032101 
2 
(Cassell's I.D. Exhibit No. 6 - series of 
0121 01 
3 
e-mails, Bates numbered BE-510 - -514 was marked for 
032115 4 
identification.) 
win 5 
BY MR. SIMPSON: 
032119 
6 
Q. 
I will give that to the witness. And to 
033130 
7 
identify the document further, It's a series of e-mails, 
0321 30 
8 
the most -- the latest one in date being at the top, 
03 23 .0 
9 
which appears to be an e-mail from Paul Cassell to 
Jacqueline S. Jesko on Sunday, January 4th, 2015 at 
can 4s 11 12:48 p.m. 
0321 5412 
A. Right 
022151 13 
Q. 
My first question is whether you, in fact, 
032137 14 
sent this e-mail that -- that this -- had this exchange 
032202 15 
of e-mails with Miss Jesco? 
onza 16 
A. 
Yes. 
onyx 17 
O. 
And Miss Jesko -- who is Miss Jesko? 
032201 18 
A. She works for -- which -- which — oh, 
o 19 
Nightline. She works for Nightline, yes. 
0372.5 20 
Q. 
So she's with ABC News? 
ci322., 21 
A. I believe that's right, yes. 
fa II I, 22 
Q. And --
cans 23 
A. I mean, I — I can't remember. The network 
10 an 24 
wasn't significant to me, but she's with the Nightline 
03 2221 25 
program. I knew that was a major program. I don't 
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ono 8 
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have told ABC News that Mr. -- Professor Dershowitz, in 
fact, had abuser 
A. 
No. I think it says that I'm the lawyer who 
Is representing someone who has — has made those 
allegations. 
Q. That's how you read this e-mail? 
Yes. 
In the e-mail you identified Miss Roberts as: 
A. 
Q. 
"The young woman who was sexually abused by 
03%51 10 
Prince Andrew and Alan Dershowitz." 
That doesn't read to you as a statement that 
she was abused? 
A. In context, I think it was understood that I 
was the attorney representing her with that claim. 
MR. DERSHOWITZ: Move on. 
BY MR. SIMPSON: 
Q. Who --
THE WITNESS: I'm sorry. What was that? 
Who -- who was that? 
MR. SIMPSON: Who is speaking? 
THE WITNESS: I heard somebody say "move on" 
or something. Could somebody identify 
themselves, please? Did I --
MR. SIMPSON: In any event, I -- I will move 
on. 
03%% 11 
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03 74 14 16 
03 34 14 17 
a2.15 18 
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03 34 16 20 
03 24 15 21 
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012420 24 
03 24 27 25 
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1 
THE WITNESS: Well -- well, who — I'm sorry. 
032007 
1 
MR. SIMPSON: Okay. I --
onto 2 
Who was that? The speaker? I want to know who 
ono 2 
THE COURT REPORTER: I can't hear. 
032432 
3 
is on the line here. Could somebody identify 
032102 
3 
MR. SIMPSON: I heard It and IT -- 11i 
CO 204 4 
themselves, please? 
ono 4 
repeat it. 
032434 
5 
If somebody is eavesdropping in my 
ono 5 
MR. SCAROLA: 'It was me who said IL' 
02.32 6 
deposition, I would like to know who it is. 
032646 6 
MR. SIMPSON: "And I thought my mute 
032440 7 
MR. SIMPSON: No one has the call-in number 
oin 
7 
button" -4 
032447 
8 
other than counsel and parties. 
032440 8 
MR. SCAROLA: "I thought my" --
032.44 
9 
THE WITNESS: So -- 
032303 9 
MR. SIMPSON: -- "was on." 
03)445 10 
MR. SIMPSON: To my knowledge. 
ores 10 
MR. SCAROLA: -- "mute button was on." 
030146 11 
MR. SCAROLA: Yeah, but that -- 
on 11 
And that was Mr. Dershowitz making that 
0324144 12 
THE WITNESS: But who is that person? 
032409 12 
comment? 
032447 13 
MR. SCAROLA: -- that doesn't preclude 
03239 13 
MR. SIMPSON: Yes, it was. 
032470 14 
someone from sharing that call-in number. And 
03 AM 14 
MR. SCAROLA: Okay. Thank you. 
032.10 15 
it Is appropriate that anybody on the line 
012412 15 
MR. DERSHOWITZ: I was trying to instruct my 
slog 16 
identify themselves. 
0171314 16 
attorney. 
woo 17 
And if the people on the line refuse to 
0)2614 17 
MR. SCAROLA: Then we are ready to move on. 
02101 18 
Identify themselves, then it's our intention to 
me .4 18 
BY MR. SIMPSON: 
cant. 19 
cut off the line, and the people who are 
on,. 19 
Q. 
Have you told any -- all right. 
012407 20 
authorized to be on the line can call back in. 
cnn 20 
Putting aside counsel who are working with 
0339,e 21 
MR. SCOTT: I agree with that. 
0)2629 21 
you, and putting aside those who you identified as being 
ono 22 
MR. SIMPSON: Could -- could the people on 
0)3632 22 
within the common-Interest privilege — 
MI/2 23 
the line identify themselves? 
no 23 
A. Right. 
ens n 24 
MR. SCAROLA: Okay -- 
inns. 24 
Q. -- so not those people --
03251? 25 
MR. DERSHOWITZ: Alan Dershowitz. 
on. 3. 25 
A. Right. 
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315 
on,, 1 
MR. SCAROLA: -- cut it off. 
no 
1 
Q. -- have you told anyone that Professor 
0323 ir 
2 
MS. McCAWLEY: He Just -- he Just -- 
oleo 2 
Dershowitz abuse 
any other minor? 
092317 
3 
THE WITNESS: So he -- 
no 
3 
A. 
No. I've — what I have tried to say is that 
owe 4 
MR. SIMPSON: Alan Dershowitz. Anyone else? 
no 
4 I'm representing a young woman who has made those 
022424 
$ 
MR. SCAROLA: So the only person on the line 
.,n.. 5 
allegations. As an attorney, I'm proud to represent 
042527 6 
is Alan Dershowitz, and it was Mr. Dershowitz who 
iniii 6 her, proud to present her case in court, proud to 
ens2, 7 
made the comment "move on"; is that correct? 
on 
7 
present arguments to whoever will listen that she's been 
.,a 
8 
MR. SIMPSON: Well, he's the only one on the 
aurae 8 sexually abused by various people. 
092534 
9 
line. I know -- I've only got three minutes left 
on 
9 
Q. 
Okay. And you have spoken with 
on u 10 
here. 
032749 10 
representatives of the News Media on the record and off 
ensr 11 
MR. SCAROLA: Weil, I'll give you three more 
tens. 11 the record about this case; Isn't that -- is that not 
032139 12 
minutes. I want to know: Was it Mr. Dershowitz 
on a 12 
correct? 
032341 13 
who made that comment "move on" because Nit 
03230 13 
A. 
Well, on the record, yes; with regard to off 
anso 14 
wasn't, there's somebody else on the line -- 
032/21 14 
the record, there have been some communications that I 
ans.. 15 
MR. WEINBERG: I -- I -- 
43224 15 
think now have been turned over to the — to the 
032342 16 
MR. SCAROLA: -- that refuses to identify 
on 16 
defense. So I don't -- I'm not sure if there still 
*ma 17 
themselves. 
on 17 
remain any off the record — I suppose probably there 
ono 18 
MR. WEINBERG: Marty Weinberg for Epstein. 
012732 18 
are a few, but I would -- I think most of the — what 
onsi 19 
I've been on the line on occasion. I have a mute 
032736 19 
were originally off-the-record communications have now 
on se 20 
button and have said nothing and Lust kept on 
032/36 20 
been provided to -- to the defense time. 
on ts 21 
going with no statements on my end. 
032241 21 
Q. 
Mr. Cassell, Is it not true -- true, that you 
ax se 22 
MR. DERSHOWITZ: It was me who said it. I -- 
032/44 22 
have spoken with reporters on what you referred to as 
(4)2636 23 
I -- I thought my mute button was on. 
032749 23 
quote, background, dose quote? 
ono 24 
THE COURT REPORTER: I can't hear. I can't 
032,40 24 
A. 
Yeah. I mean that's different than — your 
woo 25 
hear. 
03V 34 25 earlier question was off the record and on the record. 
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03n. 
2 
316 
There Is an intermediate category of 
background information as well, and I have spoken to 
03301? 
1 
on 
2 
318 
your client, my client, or any Joint defense 
communications. You can't reveal that. 
ono 3 
some reporters in that capacity, yes. 
01*74 3 
THE WITNESS: All right. So I'm going to 
rang 4 
Q. 
And -- and -• and background means that it's 
awn 4 
follow that instruction and not answer. 
canoe 
5 
not for attribution, correct? 
wan 5 
BY MR. SIMPSON: 
CM i0 6 
A. 
Right. The background means the reporter can 
03)44 6 
Q. 
With respect to the -- what's now still 
wan 7 
use the information, but shouldn't attribute it to a 
own 7 
Exhibit 2, the motion for limited Intervention --
on u 8 
particular person. 
wow 8 
MR. SCAROLA: Let me lust observe for the 
COX II 9 
Q. 
And, in fact, you have -. 
03304 9 
record that it's 12:02. I don't think we used 
032•10 10 
A. 
Or let me -- let me just clarify. Some 
0,3101 10 
the three minutes that I said I was going to give 
on,' 11 time — well, background, I think, you know, we are now 
0100 11 
you, but we will go to 12:03 anyway. 
onn 12 
talking about sort of — when I use the term 
o,, 'o 12 
MR. SIMPSON: This line of questioning will 
row ;4 13 
"background," it would generally mean that this is 
rain, 13 
take a little -- a little time, so --
on n 14 
ran, 15 
something maybe that you want to investigate and see if 
you can confirm in other ways, but it shouldn't be 
Oahu 14 
mil. 15 
MR. SCAROLA: Well, what's a "lithe? Oh, 
so you •-
wnu 16 
sourced to — that I shouldn't be quoted directly 
03111S 16 
MR. SIMPSON: five minutes. 
CONS 17 
because they are going to have to find other — other 
NJ.* 17 
MR. SCAROLA: So you prefer to wait then? 
0324.4) 18 
sources that confirm that same information. 
033120 18 
MR. SIMPSON: Let me ask -- I can ask you a 
an., 19 
Q. 
Okay. And so my question is that it is true 
4)).22 19 
few questions here. 
ono 20 
that you have spoken with a number of reporters on 
03123 20 
THE WITNESS: Sure. 
0324.9 21 
background abo 
. dons in this 
0) 3, n 21 
BY MR. SIMPSON: 
0320.03 22 
case, correct? 
02 3124 22 
Q. I'm going to keep going. On the -- this is 
03214 23 
A. 
Well, a number — a few, I would say, is 
0) 32 24 23 
your brief actually --
conks 24 
probably a more accurate characterization. 
won 
24 
A. 
Which--
oara 25 
Q. 
And in any of those background conversations, 
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Q. 
-- Exhibit 1. 
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319 
032t 04 
1 
did you ever identify Miss Roberts as someone who had 
033,30 1 
A. 
Which — let me just make sure which one Is 
032101 2 
been sexually abused by Mr. -- Professor Dershowitz? 
033133 2 it. I have Exhibit 2, but I don't think I have 
Ginn 3 
A. 
I tried to Identify myself as the attorney 
023,30 3 Exhibit 1. 
rani. 4 representing someone who said that she had been sexually 
(Jinn 4 
Q. 
Oh, I probably have Exhibit 1. Let me give 
cowl. 5 
abused by Dershowitz. I think you've received — you 
ono 5 
you Exhibit 1. I will give you 2 back so we don't lose 
032020 
6 
know, we can go through — you know, we have produced, I 
01214. 6 
it •-
ow,. 7 
think, 2,500 pages of discovery. Many of those pages 
0131u 7 
A. 
Okay. 
CO2120 
8 
are media communications. And, you know, we can go 
0111 43 
B 
Q. 
-- or keep it in front of you with the 
rozixi 9 
through, and I think you know that there are a number of 
on.. 9 
others. 
011923 10 
examples, many examples, where I have said, I represent 
032144 10 
A. 
Okay. So, now, let's set. Okay. Yeah. I 
es n M 11 
a woman who has alleged that... Some verbal formulation 
ouzo 11 have it. 
ono 12 
along those linos. 
0300 12 
Q. 
In preparing this brief, did you personally 
wan. 13 
I mean, attorneys represent victims all the 
03 n.e 13 
review the citations to the record that were given to 
0244 14 
time and — and I don't think people generally 
ono 14 
support the factual assertions? 
*Inn 15 
understand when an attorney makes a statement, that the 
*moo 15 
A. 
As opposed to somebody else on the legal 
200 0, 16 
attorney is adopting and vouching for that statement 
ran„ 16 
team? 
ons3, 17 
They are — they are serving In a representative 
an,: 17 
Q. 
Yes. I'm trying to ascertain whether you, 
MOH 18 
capacity. 
ow. 18 
yourself, reviewed citations -- Pm going to be asking 
an V! 19 
Q. 
Have you finished your answer? 
can le 19 
you about a deposition transcript -- citations to the 
rirah)o 20 
A. 
I have. 
o nn 20 
record evidence that are cited as representing to the 
tam 21 
Q. 
Okay. Do you -- are you a party to any fee 
0332a 21 
court as supporting the factual assertions? 
MOO 22 
agreement of any kind that would relate to a possible 
OM 2$ 22 
A. 
I moan, I reviewed some, and others. You 
OM* 23 
recovery from Les Wexner? 
nun 23 
know, maybe I need to — this is starting to get into 
ono 24 
MS. McCAWLEY: Objection to the extent that 
on,. 24 
work product If you're asking, you know, what did Brad 
snaps 25 
it reveals any confidential communications with 
033:38 25 
do, what did you do, what did the paralegals do --
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03 WV 1 
Q. Let -- let me ask you a different question 
033434 1 
visiting? 
032243 
2 
then. 
033414 2 
"Uh-huh. Answer. 
03 1343 
3 
A. Okay. 
033456 3 
"Question: How often did he come? 
no 
4 
Q. By -- by submitting this brief with your name 
<flaw 4 
"Answer: He came pretty -- pretty often. I 
(01746 
5 
signing it, you were representing that the factual 
033330 5 
would says as least four or five times a year.' 
m300 6 
allegations, factual assertions, were support — are 
oak. 6 
And that's what Is cited as the support for 
03 pr.. 7 
supported by the record citations that are given for 
033.02 7 
the proposition --
sputa 
8 
those, correct? 
033300 8 
A. I'd -- I would like to look at the document. 
corm 9 
A. Yeah. I mean, obviously, when you write a 
0333 14 9 
Q. I'm going to give you the document before I 
ropot 10 brief, you're -- you're -- you know, you're trying to 
0333„ 10 
ask you to comment on it. 
ono 11 represent that this is the best product I can come up 
OM 16 11 
A. Sure. 
03304 12 
with. 
on.. 12 
Q. I will -- I will go beyond what was cited to 
031306 13 
Now, you know, in a 40-page brief did -- 
on it 13 
the court --
03107 14 did — is there some, you know, error in citation or 
*34,4 14 
A. Okay. 
031110 15 something like that? I have to -- I'm not perfect. I'm 
031314 15 
Q. -- to put it in context. 
033317 16 sure that's a possibility, but, you know, I worked hard 
033320 16 
A. But I mean, there's — this is a large — 
Nun 17 to try to ut t 
ether the best product that I could on 
013623 17 
well, that's what I'm saying. I would like -- my 
033322 18 
behalf o 
en I filed this brief. 
012324 18 
recollection is that there are number of parties to the 
012111 19 
Q. 
n -- an n genera , when a lawyer signs a 
013521 19 
Alessi depo --
ens 20 
brief, it's a representation to the court that the 
*rap 20 
Q. No. My -- my only question is in this brief, 
0311711 21 citations to the record support the factual -- 
0)3511 21 the lawyers signing it represented to the court that 
on,,. 22 
A. Yeah, to the - 
nee 22 
this citation supported that factual assertion. 
con 23 
Q. -- propositions given to the court? 
0322 33 23 
A. But that's true, yes. 
033) 3 24 
A. Yeah, that's right. To the best of, you 
0133/1 24 
Q. Okay. I will read it. 
wan 25 
know, your ability, sure. 
cm. 25 
"Do you have any recollection of V.R., 
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323 
0333)1 1 
Q. Take a look if you would at page 29 -- 
011343 
1 
ming to the house when 
033140 2 
A. Okay. 
nisei 2 
Prince Andrew was there? Question. 
033341 3 
Q. -- the top of the page -- 
123140 3 
"Answer: It could have been, but I'm not 
03 22.7 4 
A. Okay. 
0343. 4 
sure. 
033342 
5 
Q. -- the statement: 'lane Doe number 3 came to 
0313W 5 
"Not sure. When Mr. Dershowitz was visiting? 
02 32 50 6 
the house when Dershowitz was there.' And then It's 
0) 36 21 6 
"Uh-huh. 
03 2113 7 
"Id." which is a citation to the Alessi deposition, page 
03 33 34 7 
"How often did he come? 
.3333,3 8 
73, line 18 to 20. Do you see that? 
oasis 8 
"He came pretty -- he pretty often. I would 
oanso 9 
A. I do. 
03a14 9 
says at least four or five times a year." 
roam 10 
Q. So that sentence if I -- do you agree with me 
pato 10 
A. Okay. 
031403 11 that sentence Is representing to the court that Virginia 
031601 11 
Q. Do you want to take a look at that? 
pure 12 
Roberts came to the Palm Beach house when Professor 
oin: 12 
A. 
Yeah. 
031412 13 
Dershowitz was there? 
033604 13 
MS. RICHARDSON: Page 73. 
03141) 14 
A. Yes. 
01)601 14 
BY MR. SIMPSON: 
cosi, 15 
Q. I'm going to read you what's cited for that 
ones 15 
Q. Page 73, line -- It's right here (indicating) 
033615 16 
proposition. I can show it to you if you like. 
ono 16 If it helps you find it. 
or t. ir 17 
A. I would like to see it because, you know, 
033011 17 
A. Yeah. Okay. MI right. That's what those 
0 14 10 18 It's possible I'm off. 
02)311 18 lines say, yes. 
WU 2) 19 
Q. Let me read it for the record. 
0)3014 19 
Q. Okay. So my -- my question is: In your 
0.3422 20 
A. Sure. 
.,an 20 
view, as an attorney, does that quotation -- does that 
0334» 21 
Q. And I will read what is cited. It's page 73, 
03302) 21 
testimony support the assertion that Professor 
um 31 22 
lines 22 to 25. 
03132/ 22 
Dershowitz and 
in the house at the 
0341. 23 
Actually -- I'm -- yeah, I'm sorry. 73, 18 
032610 23 
same time? 
013444 24 
to 20. Une 18: 
03»30 24 
A. Those -- those lines 18 to -
03x1, 25 
"Not sure. When Mr. -- Mr. Dershowitz was 
wan. 25 
Q. 
And if you want to put it in the context of a 
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03,130 1 
couple of lines above it that do refer to Virginia 
now 1 
A. The lawyer — look, this is not the first 
CO 10311 
2 
Roberts, put it In the context 
can 2 
time --
waist 
3 
My question is: Does that, fairly read, 
en 
3 
Q. 
Urn not asking the 44
0110/ 
4 
constitute testimony th•d 
Professor 
mmari 4 
A. -- a lawyer has cited the wrong line number 
03364 5 
Dershowitz were in the house at the same time? 
03 x11 5 
on a transcript or something, and if you're suggesting 
maw 
6 
A. Those three sentences, three lines. 
emu 6 
that — you know, I will concede that I cited the wrong 
mans 7 
Q. 
What -- yes, what the brief cites. 
nun 7 
line number for that particular assertion. 
011017 
8 
A. Those -- those three lines: "Not sure. When 
03364 
8 
Q. 
And this is what I want to clarify: When you 
031703 
9 
Mr. Dershowitz was visiting. Uh-huh. How often did he 
031143 
9 
say the wrong line number, if you look at the quotation, 
nos 10 corner Those -- those three lines, I agree, that looks 
03,e.• 10 
there is, up above -- you cited 18 to 20 -- 22 to 25 .-
033/10 11 like a miscitation there. I agree with you on that. 
owe 11 no, 18 to 20. I'm sorry. You cited 18 to 20 which is 
013714 12 
Q. And isn't it true that -- first of all, 
muse 12 -- do you see that? 
CO 3710 13 
nothing else is cited in the brief or elsewhere to 
wiry 13 
A. I do see 18 to 20, yes. 
CO 1722 14 
support -- put -- put aside. 
033430 14 
Q. And those lines don't refer to Virginia 
own 15 
Other tha 
estimony, 
0330 Of 15 
Roberts coming to the house, correct? 
03 1/743 16 
this is the only evide 
court to 
031102 16 
A. Lines 18 to 20 do not refer to Virginia 
033/10 17 
support -- 
COM ICI 17 
Roberts - oh, no, wait a minute. Now, this is --
0137 31 18 
A. 
No, no, no, no, no. That would require a 
023/12 18 
because when I look at it here, line 15: 
033734 19 
30-minute answer. 
man 19 
y recollection of V.R., 
mum 20 
Q. Okay. I won't ask you a 30-minute answer -- 
COM 20 20 
ing to the house when 
03 x.11 21 
MR. SCAROLA: How about -- how about wrapping 
033911 21 
Prince Andrew was there?" 
031730 22 
It up then because it's now 12:10. 
wan 22 
Answer: "It could have been. I'm not sure. 
03 3741 23 
MR. SIMPSON: I will wrap It up. I have one 
wan 23 
"Not sure. When Mr. Dershowitz was 
033/42 24 
more -- one more question. 
0331n 24 
visiting?" 
033743 25 
THE WITNESS: Okay. 
033930 25 
So now when I read it, actually, I'm now 
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011141 1 BY MR. SIMPSON: 
man 1 
going to withdraw my earlier answer, I would -- because 
033143 
2 
Q. And that is: I Just want to confirm that you 
013033 2 
you know, Its getting late in the day. I'm getting a 
033141 3 
do agree with me that what was cited to the court for 
0336 31 3 little fuzzy here. When Mr. Dershowlt7 was visiting, 
son so 4 the proposition that they were together, in this 
033140 4 uh-huh, could be an affirmative answer read in context 
033152 
5 
sentence, doesn't support that proposition? 
OM 43 5 to saying, I don't recall about Prince Andrew, but I do 
0337 $4 6 
A. I will agree with you that there appears to 
01104i 6 
recal 
g there. And I think when 
133 17,0 7 
be a mis citation of the line number -- of the lines 18 
nate 7 
we u 
he deposition, which we don't 
maw 8 
through 20. 
ones, 8 
have time right now, that the context that I'm 
cow* 9 
Now, you're saying that there is not 
033034 9 
suggesting now would be accurate. So I am not prepared 
ext. 10 information outside of 8 -- lines 18 through 20 to 
01300 10 
to say, as I sit here right now, that those were the 
°saw 11 support the allegation, and that's going to require a 
013•11 11 wrong line numbers. 
033411 12 much longer answer. 
034001 12 
Perhaps those are the correct line numbers, 
031112 13 
Q. 
I don't want a long answer, but I do want to 
0144103 13 
but what I think I should have done was to cite 
roan 14 
clarify. When you say "outside" -- 
cue.. 14 
additional parts of the transcript that would have, in 
man 15 
MR. SCAROLA: You also said one more 
034040 15 
context, made dear that the assertion was correct. 
0311 Is 16 
question. 
034014 16 
MR. SCAROLA: With that --
COMO 17 
MR. SIMPSON: Well, I -- let me Just finish 
non 17 
MR. SIMPSON: I -- I just need to finish this 
0334116 18 
this, so we are not going to have this hanging, 
034010 18 
one or two questions, but this is the topic, so 
033411 19 
because I want to make sure we are communicating. 
014011 19 
let me finish it. 
CO 3011 20 
THE WITNESS: Okay. Sure. 
as. ,s 20 
BY MR. SIMPSON: 
dun 21 
BY MR. SIMPSON: 
03415 21 
Q. Did you ever watch the video --
man 22 
Q. 1 understand you're -- you're saying that 
eneir. 22 
MR. SCAROLA: Running out of tape --
03 1021 23 
there -- there may be evidence -- 
014041 23 
BY MR. SIMPSON: 
co son 24 
A. 
Yeah. 
oar, 24 
Q. -- of the transcript? 
Cl x11 25 
Q. -- elsewhere? 
014321 25 
MR. SCAROLA: We are also running out of tape 
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034011 
034020 2 
01026 3 
01402. 4 
0022 
5 
04024 
6 
034021 7 
010,1 
8 
right now. 
MR. SIMPSON: I've got --
THE VIDEOGRAPHER: Two minutes. 
MR. SIMPSON: Two minutes. All right. That 
won't take --
BY MR. SIMPSON: 
Q. I want you to look at the video of that --
that testimony. Would you play it, please, for the 
034013 9 
witness? This is from the videotape of the deposition. 
014016 10 
THE WITNESS: I do not want to watch Just 44
0100 11 
I want to watch -- what -- what I'm seeing here 
02100 12 
as I dive into this, I would -- If you're going 
014045 13 
to ask me questions about what's in these 
03400 14 
particular lines, I want to see -- I want to go 
040511 15 
back. I want all of the -- the relevant parts of 
031064 16 
mony played. And I 
ocee 17 
a iev 
ere 
proximately four points in 
03406. 18 
the transcript where she's mentioned, so can we 
04100 19 
play all four of those? 
02400 20 
MR. SCAROLA: We are not going to do that. 
non 21 
We have run out of time. Per agreement, this was 
Nee 22 
supposed to stop at noon. 
own 23 
MR. SIMPSON: Okay. 
roma 24 
MR. SCAROLA: It is now 12:12, so this 
03410 25 
deposition is ended. There were a lot of things 
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4 
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MR. SCAROLA: Right. 
THE VIDEOGRAPHER: We are going off the video 
record, 12:14 p.m. 
(Witness excused.) 
(Deposition was adjourned.) 
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0)1113 
031114 
01410 
034111 
034110 
011221 
034112 
014123 
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0) 4140 21 
329 
1 
that I would have like to have finished with 
2 
Professor Dershowitz and wasn't permitted to do 
3 
that. So by agreement, this deposition is now 
4 
over. 
5 
MR. SIMPSON: It -- it's -- It's ending over 
6 
my objection and the witness's --
7 
MR. SCAROLA: I -- I understand that. 
8 
MR. SIMPSON: -- the -- I'm going to make my 
9 
record. 
MR. SCAROLA: Okay. 
MR. SIMPSON: -- the witness's refusal to 
look at the videotape of the portion of the 
deposition that he just characterized in his 
testimony as suggestin an affirmative answer to 
the question of whethe 
Professor Dershowitz were sere at t e same time, 
and I will represent --
MR. SCAROLA: That record Is dear. 
MR. SIMPSON: -- and anyone looking at that 
videotape would know, to a moral certainty, that 
that was false. 
04140 22 
THE WITNESS: Okay. And I -- I want to make 
03410 23 
dear that I would be happy to look at 
014160 24 
everything. We will do that at another time 
orris, 25 
perhaps. 
ESQUIRE DEPOSITION SOLUTIONS 
(954) 331-4400 
331 
DEPOSITION ERRATA SHEET 
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Assignment no: 220190 
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BRADLEY I. EDWARDS and PAUL G. CASSELL vs. 
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ALAN M. DERSHOWITZ 
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DECLARATION UNDER PENALTY OF PERJURY 
I declare under penalty of perjury that I have 
read the entire transcript of my deposition/examination 
under oath taken in the captioned matter or the same 
has been read to me, and the same Is true and accurate, 
save and except for changes and/or corrections, If any, 
as indicated by me on the DEPOSITION ERRATA SHEET 
hereof, with the understanding that I offer these 
changes as if still under oath. 
2015. 
Signed on the 
day of 
PAUL G. CASSELL 
ESQUIRE DEPOSITION SOLUTIONS 
(954) 3314400 
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DEPOSITION ERRATA SHEET 
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CERTIFICATE OF OATH 
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STATE OF FLORIDA 
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COUNTY OF BROWARD 
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S 
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Reason for change: 
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1, the undersigned authority and Notary 
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Public certify that PAUL G. CASSELL personally 
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appeared before me and was duly Sworn on Saturday, the 
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17th day of October, 2015. 
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Sworn to before me this 19th day of October, 
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2015. 
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Theresa Tomaselli, RMR 
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Notary Public • State of Florida 
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My Commission No. FF 225528 
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My Commission Expires 8/27/2019 
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Reason for change: 
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220190
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_tine 
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Z1 
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SIGNATURE: 
DATE: 
2015 
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PAUL G. CASSELL 
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ESQUIRE DEPOSITION SOLUTIONS 
ESQUIRE DEPOSITION SOLUTIONS 
(954) 331.4400 
(954) 331-4400 
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IP 
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DEPOSITION ERRATA SHEET 
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REPORTER'S CERTIFICATE 
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Reason for change: 
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I 
THERESA TOPASELLI. Registered Merit 
Wailer aid Notary Public In and for the State of 
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Florida at Large. do hereptcertify that I was 
authorized to and did re 
said deposition in 
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steroptpe: and that the ocarina pages are a true and 
ere
transcription of my Shaltend notes of Said 
ct
 
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I further certify that said deposition ems 
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taken at the time end place hereinabove sot forth ard 
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that the taking of said deposition was coisenced ad 
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comPleted as heremabove set out. 
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II 
I further certify that l an not an 
attorney or counsel of any of the parties. nor a 1 a 
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relative or esployee of any attorney or panel of party 
connected enth the action. nor am I for
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in
 ested in the action. 
The foregoing certification of this 
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trarecript does not apply to my reproduction of the 
sane by any sears unless under the direct control anifor 
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direction of the certifying reporter. 
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DATED this 19th day of October. 2015. 
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Is
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220190 
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SIGNATURE: 
DATE: 
2015 
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PAUL G. CASSELL 
ESQUIRE DEPOSITION SOLUTIONS 
(954) 331-4400 
(954) 331-4400 
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