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01:52:54 01:52:54 01:52:56 01:52:58 01:53:00 01:53:02 01:53:05 ON Oa bk WN — 01:53:07 ic] 01:53:09 01:53:11 1 0 04:53:13 1 1 orate 12 01:53:19 1 3 64:53:21 14 01:53:22 1 5 01;53:26 1 6 01:53:34 1 7 ors3.c2 18 01:53:33 1 9 01:53:36 20 o2z0743 24 0207.43 22 02:08:03 23 02:08:06 24 02:08:08 25 02:08:12 02:08:12 02:08:14 02:08:16 02:08:18 02:08:23 02:08:27 ON Oa hb ON = 02:08:28 02:08:28 9 02:08:34 10 02:08:37 11 o20s40 12 o2z08a4 13 o2osae 14 ozeas: 15 oz08ss 16 ozoess 17 ozos01 18 ozo903 19 ozos0e 20 o209:09 21 020912 22 o20014 23 ozoeis 24 ozos21 25 10/20/2015 01:07:28 PM 101 identified Alan Dershowitz as someone who had 020923 1 information relevant -- and let's be clear, that o20825 2 this is not a lawsuit about some contract dispute 020928 3 or something -- that he was someone who had o20923 4 information relevant to the sexual abuse of o2030 5 underage girls and, indeed, they were asking oz0s32 § questions about what information -- what o20934 7 information he might have. o20e38 8 Another -- I know, I remember now, there's a ozoo38 9 whole other line of things that -- that I had in ozoaa: 10 mind at the time, and I think since you want to ozosa3 11 test my memory -- I'm not -- let me be clear. orooas 12 I'm not claiming I have a superb memory. I have ozosaa 13 an average memory, but this is a subject that's 020052 14 very important to me, and so I've worked, you ozossa 15 know, very hard to get all the information. ozoes7 16 I would like to take a break. ozoess 17 MR, SCAROLA: Sure. Take a break. ozi001 18 THE VIDEOGRAPHER: We are going off the video | oz100 19 record, 3:27 p.m. o21007 20 (Thereupon, a recess was taken.) o210:11 21 THE VIDEOGRAPHER: We are back onthe video | oz1014 22 record, 3:41 p.m. oztors 23 THE WITNESS: I want to continue my answer. ozto21 24 I'm sorry. I got emotional there for a moment. oz1023 25 ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 102 I want to do a good job for Virginia Roberts oz1027 1 on -- on representing all the -- the evidence o21028 2 that is available to support her. oz1031 8 The next thing that I was thinking of was, oz1038 | 4 all right, then the question is: Well, what does ozto38 6 Mr. Dershowitz have to say about all this? So I ozto1 § started to look at the information on that as o2to4s | 7 well. oie |= 8 In 2009, there had been a deposition request oz1048 9 sent to Mr. Dershowitz, and I -- I saw a document o2z10580 10 showing that that had actually been served on -- oztoss 11 on him, and, you know, to the extent that what I o21101 12 saw was a -- I think a receipt from the process o2t101 13 server, or something along those lines, so I saw o21108 14 attempt to contact him in -- in 2009. ozi07 15 And then I saw an additional attempt to oni 16 contact him in 2011. Mr. Scarola had sent him a oz11ts 17 note and there was, you know, some back and ozt 18 forth. The -- the one note that -- that jumped oz 19 out to me was one in which Mr. Scarola had o2tr21 20 written to Mr. Dershowitz, I think the phrase ozi21 24 was: Multiple witnesses have placed you in the ozti23 22 presence of Jeffrey Epstein and underage girls; I o21126 23 would like to depose you about those subjects. ois 24 And the answer that came back was not, well, 02:11:31 25 ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 103 let me clear all of that misunderstanding up. You know, that's -- frankly, if I had gotten something like that, that's what I would have said. The answer that came back was -- from Mr. Dershowitz was something along the lines of, if I remember correctly, well, tell me what you -- you -- tell me what you want to know and I'll decide whether to cooperate, was I think the phrase that was used. And -- and so there was an attempt, you know, a 2009 attempt, a 2011 attempt to get information from Mr. Dershowitz. Then there was another subpoena without deposition for -- for documents. You know, we have heard a lot about records in this case that could prove innocence. There was a records request to Mr. Dershowitz in 2013. And, again, my understanding was that there was no -- you know, no documents were provided on that. And so those -- I had that information. Another bit of information that I had was that in 2011, I believe in early April -- this is not attorney/client privileged information from Virginia Roberts. This is a telephone call that she placed from Australia where she had been ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 104 essentially forced into hiding by Jeffrey Epstein. She managed to escape and was hiding out in -- in Australia, and that she would -- that somehow, you know, Mr. Scarola and Mr. Edwards were able to reach her and there was a telephone call that was made. And in that telephone call she identified Alan Dershowitz as someone who would have relevant information about Jeffrey Epstein and the sexual abuse of underage girls. And so I had that information as well. So that, as I understand, the question was: What could I recall off the top of my head with regard to the factual basis for information connecting Mr. Dershowitz with the sexual abuse of minor girls, plural, and that, sitting here at this moment, is the best that I can recall for the information along those lines. BY MR. SIMPSON: Q. Was that answer -- MR. SCAROLA: Excuse me. Before -~- before you go on to another subject, Professor Cassell is entitled to refresh his recollection to give you a complete response. So why don't you go ahead and do that now. Make sure you've covered ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 Page 101 to 104 of 151 26 of 38 sheets HOUSE_OVERSIGHT_010835