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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 21 of 27 47. Moreover, Mr. Cassell’s claim that I dodged a subpoena or systematically avoided providing information to his and Mr. Edwards’ lawyer, Jack Scarola, is demonstrably false. 48. Although a legal assistant for Bradley Edwards, one of Ms. Giuffre’s lawyers, once claimed that I was served with a subpoena in 2009, this was not true; I was never served with a subpoena, and contemporaneous documentary evidence proves as much. 49. In August 2011, another attorney representing Ms. Giuffre, Jack Scarola, called me to ask that I provide information on Mr. Epstein’s alleged abuse of minors, and particularly young women. I responded on August 15", in writing that, if Mr. Scarola were to provide me with a more detailed request, I would try to provide any relevant non-privileged information. See Ex. S at SCAROLFA 016566 (Scarola Correspondence, August-September 2011). Mr. Scarola wrote back to me on August 23, stating that “We ... have reason to believe that you have personally observed Jeffrey Epstein in the presence of underage females, and we would like the opportunity to question you under oath about those observations.” Jd at SCAROLA 016567. I replied that “If you in fact have such testimony it is perjurious. I have never seen Epstein in the presence of an underage female.” Jd. at SCAROLA 016570. 50. Despite this unambiguous answer, Mr. Edwards and Mr. Scarola attempted to subpoena me in 2013. This time, they left a subpoena with an assistant to another faculty member at Harvard Law School—an improper form of service. I again made it clear to them that I had no relevant non-privileged information to provide, and that I had been instructed by my client not to volunteer any information. There was no follow up by Mr. Scarola and no attempt to serve me properly. 21