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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 20 of 27 A: I believe it is. Q: Based on him -- assuming he’s a frequent visitor to Mr. Epstein’s home, and that he’s a friend of Mr. Epstein’s, and that his name is circled in this book, do you infer that he was engaged in criminal sexual abuse of minors? A: No. Ex. O at 233. The Allegation That I Engaged in a “Pattern of Deception” 45. The Cassell Declaration asserts that “[a]ttempts had been made to depose Dershowitz or otherwise obtain information from him about his knowledge of Epstein’s sexual abuse in 2009, 2011, 2013, and January 2015, and he had avoided all those efforts.” Cassell Decl., § 21(0). Mr. Cassell also claims that I did not make Epstein “available to answer questions about sex abuse of underage girls.” Jd. 4 21(p). Mr. Cassell describes this as “a pattern of deception” that was “consistent with a pattern of other persons involved in Epstein’s international sex trafficking organization.” Jd. | 21(p)-(q). Again, these assertions are false or misleading, and absurd in equal measure. 46. During my representation of Jeffrey Epstein, I was a member of an extensive legal team, which collectively decided how Epstein should interact with law enforcement during their investigation. Together with other members of the legal team, I, among others, communicated with the Palm Beach State Attorney’s Office—including scheduling meetings to depose Epstein—at the behest of the client. This behavior does not constitute a “pattern of deception;” instead, it reflects a legal strategy, devised by a team of defense lawyers aiming to secure the best possible result for their client. 20