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wo MT DA MO FF WN OC CR CE Cn Ce St uk WY HF OO OANA OM FW dKd FE OO A. Lhave ~- Q. -- during the course of the deposition, 1 am permitted to examine if. A. Ihave lawyer-client privileged information in here, so | can't give it to you. I can give it to you ina redacted form. I have a quote from David Boies in here, which I'm sure -- MR. SCOTT: Don't ~ A. - nobody is going to want to sce -- MR. SCOTT: We'll make a copy and give it to you. MR. SCAROLA: Thank you. Would you hand it to your counsel, please? MR. SCOTT: On that note, hold on to that. THE WITNESS: But I need that back. MR. SCOTT: Of course. Don't worry. MR. SIMPSON: Hold on to it. MR. SCOTT: That's why 1 gave it to him because I'd lose it. BY MR. SCAROLA: Q. Before January 21, 2015, what information did you have regarding what Bradley Edwards and Paul Cassell had gathered in the course of investigating the accuracy of Virginia Roberts' accusations against you? oO Omri nm FP WN NM NM NN NF PP FP BP HP FE He m FW NF Oo Oo Oo NT Di Be WN FF Oo Cassell had done in the course of their investigation of the credibility of the accusations made by Virginia Roberts against you? A. Well, first and foremost, the most important piece of information I had was my firm and complete knowledge and memory that I had never had any sexual contact with Virginia Roberts ever under any circumstances or any other underage girls. So I knew -- Q. The question I'm asking, sir -- A. -~ this information -- Q. ~~ focuses on what knowledge you had regarding what Bradley Edwards and Paul Cassell did in the course of their investigation of the credibility of the accusations against you made by Virginia Roberts? A. That was the first and most important bit of information; namely, that | couldn't have done it and didn't do it. So knew for sure that they could not have conducted any kind of valid investigation. Second, 1 knew from -- that they also had a letter from Mr. Scarola that said that multiple witnesses had placed me in the presence of Jeffrey Epstein and underage girls and | knew that ow eA AU e® WH NNNNN NPE HB HP BP BP BP PE WP WN OK ANAM Bw NPE OO A. Well, first, 1 knew that anything they gathered -- MR. INDYKE: Objection to the extent that requires -- MR. SCOTT: Whoa. MS. McCAWLEY: -- you to disclose anything you gave -- THE COURT REPORTER: I can't hear. I'm sorry, Mr. Indyke, can you repeat your objection? MR. SCOTT: Can you say that a little louder? MR. INDYKE: Darren Indyke. I would object to the extent that your answer would disclose anything you -- you obtained or learned or any knowledge you gained in connection with your representation of Jeffrey Epstein. MR. SCOTT: Do you understand that instruction? THE WITNESS: I do, yes. Could you repeat the question? BY MR. SCAROLA: Q. Yes, sir. | want to know what information you had regarding what Bradley Edwards and Paul oO OAI KUM PF WN NNNNNN EF PH PP PP PPB WP WN OO OIA Pe YW NP Oo 272 Mr. Scarola's Icttcr was a patent lic. And they had access to that letter and that information. I also knew they were relying on depositions of two house people of Jeffrey Epstein. And I've read these two depositions. And I'm sure I knew of other -- other information as well. I knew that they had stated -- I knew that they had stated publicly, or you had stated publicly on their behalf as a witness, that you had stated publicly that you had tried to depose me on these -- on this subject, I knew that that was a blatant lie and uncthical conduct because nobody ever tried to depose me on this subject. [ had never been accused, nor did I have any knowledge that anybody had ever falsely accused me of having any sexual cncounters. And [had a great deal of information about the paucity or absence of any legitimate investigation. And Lalso knew that they hadn't called me, they hadn't tried to call me, there was no record of an attempt to call me or c-mail me. My e-mail is available on my website. My phone number is available on my website. The most basic thing they could have done, as courts have said, when you're accusing somebody 24 (Pages 269 to 272) www.phippsreporting.com (888) 811-3408 HOUSE_OVERSIGHT_010806