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04:19:15 01:49:18 O119:24 01:19:24 04:19:27 04:49:30 04:19:94 On OO Bh WH = 01:19:36 oiaaa «9 or941 10 orntoas 14 ortoss 12 orgs: 13 ortess 14 04:19:55 15 otsose 16 02002 17 or20s 18 ot2005 19 or2007 20 o12008 21 or2010 22 04:20:15 23 ov2017 24 or2019 25 01:20:22 04:20:26 04:20:28 01:20:31 01:20:34 01:20:39 04:20:42 On Oa h WN = 01:20:45 04:20:47 9 04:20:50 10 04:20:54 11 01:20:56 12 01:20:58 13 04:21:04 14 04:21:04 15 04:24:07 1 6 On2110 17 OF 2114 18 O27 19 04:24:19 20 ON24:25 21 01:21:28 22 Ona 23 04:24:33 24 O124:35 25 10/20/2015 01:07:28 PM 69 other powerful persons. For example, Ghislaine Maxwell is there with him on all of these flights and apparently being involved in the abuse. Indeed -- and so you -~ you have -- you have that. You also start to see on the flight logs, what to my mind are some very sinister things, suggesting that the pattern is not just confined to sort of, you know, the girls that are there in Florida, but it -- it is extending more broadly. Like one of the -- to my mind, sinister and scary things on the flight logs is, we see, you know, Virginia Roberts, who we know has been sexually abused, and we see Jeffrey Epstein, and then we see on the flight logs one female. That's kind of an odd notation for a flight log because, you know, typically, I understand the flight logs, the purpose is, well, if something happens with the flight, or there's some question about who was on it, you want to know who -- who the person was who was on the flight. So, to my mind, when I started to see on these flight logs entries like one female, I viewed that as a potential device for obscuring the fact that there was interstate trafficking of underage girls for purposes of sexual activity. Serious federal offenses. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 70 But then that evidence extended, you know, more broadly than that. The evidence also started to show, again, if we talk just about flight logs, that the -- that underage girls such as Virginia Roberts were being flown internationally from, for example, Teterboro in New York to -- to locations, just to pick one, you know, for example, in London, where again sexual abuse was occurring. And so you started to put together this pattern of criminality that was started in this -- you know, I don't know what the right word is here. I don’t want to -- I don't want to -- you know, you've heard discussions of hyperbole and things like that, but we have got this nest of -- of -- and I won't say snakes, but we have this nest of criminals in Florida, but it -- it seems to be spreading to Epstein's mansion in New York; it seems to be spreading to Ghislaine Maxwell's flat in London, and -- and -~ and it goes on. So those are the kinds of things that would have formed the -- the -- the basis, particularly when you -- when you start to add in this fact: What the Palm -- going back now te Florida with the Palm Beach Police Department. What the Palm Beach Police Department has -- had discovered was not a one-off kind of event, you know, on one particular day, one ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 64:24:37 04:21:40 04:24:42 04:21:46 O121:48 O4:21:51 04:21:54 On Oa bh wh = ot2487 orzz0 9 or2202 10 orz0s 14 or2z08 12 ora 13 oz 14 otzeit 15 orate 16 o12222 17 012224 18 or2228 19 o2232 20 or2232 24 orzas 22 or2239 23 onze: 24 or2244 25 01:22:48 O122:51 04:22:53 04:22:54 04:22:57 04:23:00 01:23:00 On Oa hk wh = 01:23:02 04:23:05 9 or2307 10 or2a10 11 O24 12 ora 13 orzai4 14 orzaie 15 O24 16 16 or2321 17 or2323 18 04:23:26 19 or2326 20 ovesze 21 or231 22 012335 23 or23s3e 24 or2340 25 Page 69 to 72 of 151 71 particular girl had been sexually abused. What the Palm Beach Police Department had discovered was brazen, notorious, repetitive activity sometimes occurring as often as three times ina particular day. And so that led me to believe that the sexual activity that was going on in Florida was such that someone who was a regular house guest there would have immediately come to the conclusion that, well, look, gee, there are these underage girls coming in here and they -- they seem to be -- you know, they don't seem to be here to be doing, you know, business activities; they ~- they might be here doing other kinds of activities. So those would be the kinds of things that would -- would have formed the factual basis. There are other things as well, but I'm sure you want to ask other questions in addition to that. So I'll stop there, but those -- that's -- I think gives you a small flavor of the kind of evidence that, you know, was form ~~ undergirding the allegations that were being presented here. Q. ‘It sounds like you quite passionately believe that there was strong evidence that Mr. Epstein had engaged in sexual misconduct; is that right? A. I think "strong" understates it. Q. “In the course of that long answer, you didn't ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 mention Professor Dershowitz's name once. A. I said flight logs. And let's talk about flight logs. Q. Let me back up. You didn’t answer his name -- mention his name once; is that -- is that your recollection as well? A. That's correct. We were talking about a factual basis, and I'll be glad -- I told you that there were other things if you want, factual basis for -- for Mr. Dershowitz. I'll be glad to add that in. Let me -- let's -- let me -- let me -- I would like to supplement my answer then if I could. Q. Do you want to look at a document? A. Yes. Q. Let me first -- have we exhausted your recollection without documents of all the evidence that you would refer to to support the allegation that Professor Dershowitz abused other minors? A. No. MR. SCAROLA: And let me say that you have a right to refer to whatever documents you choose to refer to, to be sure that you give a complete response to the question that has been asked, as long as you understand that whatever you refer to is going to be available to the other side, and ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 18 of 38 sheets HOUSE_OVERSIGHT_010827