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wow ony nm ® WN NNN NNN B&H BB Bb bbe bet be “ne WN OL OAI KRU FWN EO 241 (Discussion off the record.) JHE WITNESS: What's Number 6 then? I'm confused, there were two. BY MR. SCAROLA: Q. Have you ever seen Exhibit Number 6 before? A. Exhibit Number 6. I don't believe so. It doesn't look familiar to me. Q. No? A. It does not look familiar to me. Q. Did you bother at any time to review discovery that was produced by Bradley Edwards and Paul Cassell responding to requests for information that supported the allegations of Virginia Roberts? A. I'm not clear what you're asking. Q. Iwant te know — A. In which case? In which case are we talking? Q. This case. This case. A. Right. Q. Did you ever bother to review the discovery produced in this case responding to requests for all of the information that supported their belief in the truthfulness of Virginia Roberts' allegations against you? wo Ory nM ® WN NNNNNN PP RP PPP ee ee Ue WN HOW AIHA H &®wWNH OO 243 exonerated by any flight logs that were innocent -- that were complete and accurate, of course. Q. So you made the public statements repeatedly that the flight logs would exonerate you without having examined the flight logs to see whether they were accurate or not; is that correct? A. Well, I knew -- I knew that -- Q. Did you say those things without having examined the flight logs? A. I said those things having looked at some of the flight logs at some point in time. ButI knew for sure that the flight logs would exonerate me because I knew I was never on Jeffrey Epstein's plane with Virginia Roberts or any other young underage girls. So, I knew that to an absolute certainty. And I was prepared to say it. I'm prepared to say it again under oath here. And if your clients had simply called me and told me they were planning to do this, we wouldn't be here today because I could have shown them in one day that it was impossible for me to have had sex with their client on the island, in the ranch, on the airplanes, in Palni Beach. And they would have, if they were decent and ethical lawyers, not filed that. pw on nM ® WN NNNNN NFP RPP PPB eB PR ue WNEF OW OAYH UM ABWNRO A. I don't know if T reviewed everything. But I certainly, in preparation for this deposition, reviewed some of the documents that were produced in discovery. But I can't say I reviewed them all. Q. Well, having placed such substantial emphasis during the course of your public appearances on the flight logs exonerating you, it would certainly seem logical that one of the things that you would want te review would be all of the available -- all of the available flight logs, right? A. No. MR. SCOTT: Objection, argumentative. A. No. BY MR. SCAROLA: Q. No? A. No. Look, I knew I was never on a plane with any underage females under any circumstances. I knew that. I knew that as certainly as I'm sitting here today. So, | knew absolutely that if the manifests and the flight logs were accurate, they would, of course, exonerate me because I am totally, completely, unequivocally innocent of any of these charges. So of course | knew that I would be owv WN TH HF WN 244 And there are cases, legal ethics cases that say that lawyers are obliged to make that phone call. Lawyers are obliged to check if it's easy to check. Lawyers are obliged to, particularly when they're making extremely heinous charges against a fellow lawyer, do very, very, detailed investigations. And they didn't do that in this case. Q. I will represent to you that | have handed you all of the available flight logs produced in the discovery of this case. Could you show me, please, which of these flight logs exonerates you? A. The absence of evidence is evidence of absence. None of the flight logs have me on an airplane with Virginia Roberts. None of the flight logs have me on an airplane during the relevant period of time when Virginia Roberts claims that she had sex with me in the presence of another woman. So, the flight logs clearly exonerate me. There's absolutely no doubt about that, Q. Well, the flight logs, in fact, confirm that you were in the same places at the same time as Virginia Roberts, don't they? A. No, they do not. Q. Do you -- do you deny that they confirm 17 (Pages 241 to 244) www.phippsreporting.com (888) 811-3408 HOUSE_OVERSIGHT_010799