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wo or nn FP WN NNNNNN HH BE BP ee ee Oe OP WN FP Ow OID BWN HO wo OI Hoe why NNN NN NB BB ee Oe eee oe Oe WN H OCH OYA MPRWNHO A. The ongoing issues -- MR. SCOTT: But nothing about communications. A. Right. The ongoing issues relating to the NPA, which continue to this day. And I regard myself as his lawyer basically on all those -- all those issues. BY MR. SCAROLA: Q. So, when the pleadings were filed in the Crime Victims Rights Act regarding your conduct in relationship to Virginia Roberts and Jeffrey Epstein, you were and still are his lawyer in the Crime Victim's Rights Act case; is that correct? A. Ll certainly am bound by lawyer-client privilege and communications, yes. Q. Okay. You go on to say in that same interview: "Only once in my life have I been In that area," referring to New Mexico. A. Yes. Q. "Only once in my life did my travel records show I was in New Mexico.” A. Uh-huh. Q. Is that an accurate statement? A. To the best of my knowledge. | have no recollection of being in New Mexico other than oO OID OF WD NNN NNN PPP BE BP Pe BP op Oo Bwndkr ow OIA UU BWNE OO - the last 10 years? I would say 15 -- Last 15 -- -- years. -- how about the last 20 years? I have -- 1 don't think so. Okay. As I stand here today, I have no recollection of ever being in New Mexico except to visit the Ashes in January of 2000. I'm 77 years old. I've lived a long life. It is certainly possible that at some earlier point in my life -- I mean, I've been in most of the states. But I have no recollection of ever being in New Mexico. And I can tell you unequivocally the only time I was ever at Jeffrey Epstein's ranch was that one time with my wife with the Ashes, with my daughter. And we only stayed there for an hour and the house was not completed. it was under construction. And I certainly did not have any sexual encounter or any encounter with Virginia Roberts during that visit. MR. SCAROLA: Move to strike the unresponsive portions of the answer. POPOPOPO 258 during that visit to the Ashes, which was not during the -- the narrower timeframe. The narrower timeframe, remember, is Virginia Roberts meets Jeffrey Epstein in the late summer, the summer just before she's turning 16, of 1999. She says she didn't comunence having sexual activities with any of Epstein's friends until nine months later. That would put it in March or April of 2000. This visit occurred in January of 2000. It's the only time I recall having been in New Mexico. Q. Okay. I want to be sure now. You're not just saying that you were only at Jeffrey Epstein's ranch in New Mexico once; you are confirming your statement on national television that you have only been in New Mexico one time? A. My recollection right now is that | was only there once. I have no -- no other recollection of -- it's conceivable when I was a very young man, I could have been there. But I have no recollection of having been there. It certainly -- certainly I haven't been there recently. And during the relevant time period, | know [ haven't been there. Q. "Recently" means —- A. Fifteen -- to ON DU PF WD NNNNDKD NPRPP RP HE BH BR HB OU PWN HF OW MAYA HU BW NP OO 260 MR. SCOTT: We don't agree on that point, so let's go ahead. MR. SCAROLA: It's of any help, I can agree that you don't agree to any of my objections. MR. SCOTT: No, that's not true. I mean, I'm trying to work with you, sir. I have to tell you, this -- this is obviously one of the most acrimonious depositions I've sat through in my 40 plus years because of the personalities involved here and because of the personal issues. And it's quite difficult for everybody in this room. MR. SCAROLA: | agree. MR. SCOTT: And all I'm saying, and my client is -- who's 77, is trying to defend his life. And I understand you're trying to vigorously -- and you're a great lawyer -- represent your clients. And it's -- this is not the typical deposition. And we're trying our very best, both ofus. MR. SCAROLA: Thank you. And you're right, you and | do agree on something. MR. SCOTT: As you said yesterday, more 21 (Pages 257 to 260) www.phippsreporting.com (888) 811-3408 HOUSE_OVERSIGHT_010803