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02:15:21 02:18:25 02:15:29 02:15:31 02:45:33 02:15:35 02:45:39 ON OO” hb & NH «a 02:15:41 ass 9 ozrsas 10 02:15:51 11 oz1ss2 12 o21608 13 ozte14 14 ozter7 15 02:48:18 16 ozte23 17 o2te2s 18 oz1631 19 021634 20 oz1635 21 02:16:37 22 ozte4a 23 ozteas 24 cztese 25 02:16:48 02:16:50 02:16:52 02:16:55 02:16:59 02:17:02 02:17:05 On Oak G&G Dw = 02:17:07 © 02:47:14 02:17:44 1 0 02:47:18 1 1 02:17:21 1 2 02:47:23 1 3 02:17:25 1 4 02:17:28 1 5 02:17:32 1 6 02:17:34 1 7 02:17:38 1 8 02:47:41 1 9 02:17:43 20 02:17:48 21 02:17:47 22 02:17:49 23 021752 24 02:17:55 25 10/20/2015 01:07:28 PM 109 people who would have relevant information in the civil cases, but when asked in deposition about Mr. Dershowitz, he took the Fifth. So I -- I found it significant that for some people, he was willing to answer questions, but with regard to Mr. Dershowitz, he took his -- he invoked his Fifth Amendment right against compelled self-incrimination presumably because revealing what he knew about Mr. Dershowitz would, you know, cause criminal -- criminal charges potentially to be filed against him. There was a common scheme or plan, and I'll elaborate on that in a moment, but yeah, one of -- so this was another point. I mentioned that -- that there had been three efforts to get information from Mr. Dershowitz by way of a 2009 deposition request, a 2011 deposition request, and further follow-up correspondence from counsel on that, and a 2013 document request all propounded to Mr, Dershowitz that had not gone answered. Yeah, and this was -- yeah, I'm sorry, this slipped my mind at the time -- but when -- when we saw Mr. Dershowitz not responding to these answers, you know, maybe the mail didn't get delivered to him or something like that. I don't -- I suppose that's, you ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 know, a theoretical possibility. But -- but the reason I ruled out that possibility, first, it didn't seem likely; but secondly, there was a pattern of Mr. Epstein's associates evading efforts to get information from them. And so let me just go back to the earliest instance of that. According to the Chief of Police in the Palm Beach -- of the Palm Beach Police Department, Mr. Dershowitz had said that he would make available Mr. Epstein for questions about the -- the sex, you know, abuse that was going on. And, you know, Mr. Dershowitz had said to the Palm Beach Police Department, yeah, we will make him available; no, we got to reschedule it; you know, and then another time, reschedule, another time. And so there were multiple -- according to the Chief of Police, there had been multiple, you know, requests to interview Mr. Epstein and Mr. Dershowitz had repeatedly said: Oh, yeah, we will schedule that, and then it hadn't happened. Now, obviously, there could have been a situation there where, you know, an emergency had come up for Mr. Epstein and he wasn't able to make a schedule or something like that. But what I saw was a -~ was a pattern of offers to -- to meet and then withdrawals, and that seemed to me to be a deliberately calculated ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 Page 109 to 112 of 151 111 o21a00 1 strategy to sort of stall the investigation to say: aie03 2 Well, we will get you Epstein; oh, we can't meet now; 02:18:03 3 oh, we will get it now -- and then -- and so forth. ozte04 | 4 And one of the things that I noted from all cece § that was that Mr. Dershowitz, as Mr. Epstein‘s attorney, ozis00 6 never ultimately produced Epstein for a meeting with the oz1e14 7 Palm Beach Police Department, having made another offer. oni = 8 Now, obviously, something could have happened owwi2 9 there, I mean, I don't -- you know, I don't know what 021821 10 was the communications and so forth, but as an attorney oz1824 11. trying to get information and unable to do that, I had 21822 12 to make some reasonable inferences. o21820 13 And so one of the inferences I began to draw 021631 14 was that this was a stall tactic by Mr. Dershowitz, and 021834 15 in my view, potentially, an unethical one, but I o21837 16 don't -- I don't think we need to get into that in this o2is3e 17 ‘litigation. ozta4o 18 What I saw was a stall tactic going on, 2184419 and -- and the reason I think it was a stall tactic, as o21a46 20 we are sitting here now in, what is it, October of 2015, e151 21 and Mr. Epstein has never been willing to answer 021884 22 questions about his sexual abuse of these girls. oz1ess 23 And this was back in around -- what was it? 021901 24 I quess it would be 2005, 2006, you know, roughly a oz1906 25 decade ago, Mr. Dershowitz was offering to make Epstein ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 112 oz1007 1 available. And then that never happened, and given the o2te11 2 ten-year pattern that -- that developed -- I guess I 21912 3 should go back. I'm sorry. Let me correct my answer. ont = 4 We should go back to December 30th, 2014. So ota7 § there -- there appeared to be about an eight-year period 21921 § of time during which Mr. Epstein had refused to answer o2z1924 Y any questions about his sexual abuse of girls and yet, 21322 8 Mr. Dershowitz said, oh, it’s just a scheduling issue oz1¢30 9 and -- and we will get the Palm Beach Police Department oz1933 10 to -- to, you know, to meet and ~- and learn all this. oztea7 14 The other thing that I'm -- that I'm seeing ozte30 12 here, so now there's -- there's -- Mr. Dershowitz had 021942 13 been involved in concealing Mr. Epstein from the Palm ozte4s 14 Beach Police Department, but there were others that had o2te47 18 done similar sorts of things. ozre4e 16 So one of them was a Ghislaine Maxwell. I oz1955 17 will just call her Glenn Maxwell, I think that's kind o2z58 18 of the nickname I understand she goes by. oztese 19 So Glenn Maxwell -- remember, she is -- she 21959 20 is the one, you know, I think the record is clear, in ~~ o200 21 in--in litigation that, you know, an allegation has 22006 22 been made that she was the one that -- that brought o22008 23 Virginia Roberts into the -- into the sex trafficking, o22012 24 and was heavily involved with -- you know, on all the -- o22015 25 not all the flights, but on many of the flights with ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 28 of 38 sheets HOUSE_OVERSIGHT_010837