HOUSE_OVERSIGHT_010847.jpg

00:21:57 00:21:57 00:21:57 00:22:02 00:22:06 00:22:08 00:22:08 on OH hm WG NH a 00:22:08 oO 00:22:10 00:22:12 10 oo214 14 oo2220 12 002225 13 oo2220 14 oo2231 15 oo22:35 16 ooze 17 002240 18 oo:2245 19 oo2zas 20 oozes 21 oo2249 22 oo2250 23 oo2251 24 oo2253 25 00:22:54 00:22:55 00:22:57 00:23:00 00:23:07 00:23:10 00:23:42 on Oa & GH = 00:23:12 oo231s 9 00:23:15 10 oo231a 11 00.2319 12 oo2319 13 00.2323 14 o2323 15 on2325 16 002325 17 on2328 18 oo2320 19 oo.2335 20 00.2338 21 oa2330 22 oo2340 23 ooza 24 002383 25 7 of 46 sheets 176 MS. McCAWLEY: Yes. MR. SIMPSON: Okay. BY MR. SIMPSON: Q. Did you discuss former Prime Minister Barak with Mr. Boies? MR. SCAROLA: Same objection. MS. McCAWLEY: Objection. MR. SCAROLA: Same instruction. BY MR. SIMPSON: Q. Yesterday, you mentioned that one of the reasons that supported your conclusion that it -- you had an adequate basis to allege in the joinder motion that the allegations against Professor Dershowitz was that Mr. Boles was representing Virginia Roberts -- yes, Virginia Roberts; do you recall that testimony? A. Yes. Q. And you said that because of how highly regarded Mr. Boies was, I think you mentioned the Bush v. Gore case; is that right? A. Yes. Q. 1 used to work for his opponent in Bush v. Gore case. They are both very good. A. I'm trying -- I was trying to remember. I'm sorry to take time, but who was the other lawyer? Q. Ted Olson. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 00:23:58 00:24:07 00:24:14 00:24:14 00:24:18 00:24:18 00:24:18 On OO hm WG NH «a 00:24:24 00.2430 9 00:24:32 10 oo24:32 11 oo2ass 12 002639 13 oo2443 14 oo2ase 15 oo2as: 16 oo2a55 17 oo2s00 18 oo2s03 19 00-2504 20 00:25:07 21 00:25:10 22 oo2s12 23 oo2512 24 002515 25 178 discussed Virginia Roberts’ allegations of sexual misconduct against Professor Dershowitz with Bob Josefsberg? A. Me personally? Q. Yes, you personally. A. No. Q. After December 30th of 2014, had you -- did you discuss with Mr. Josefsberg Ms. Roberts' allegations against Professor Dershowitz? A. Not personally, no. Q. You say not personally. Are you aware of someone else who had those discussions of -- with Mr. -- had any discussions on that topic with Mr. Josefsberg? MR, SCAROLA: To the extent that that question would call for any information that was communicated to you in the context of the common-interest privilege, you should not answer. THE WITNESS: All right. I'm not going to... MR. SCAROLA: So you -- you can answer it if any such communication came to you outside the context of the common-interest privilege, but you may not include in your response any information derived from the common-interest privilege. BY MR. SIMPSON: Q. And my question right now is not the ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 177 A. Ted, that's right. That's... Q. But that's a side note. My question is: Given your high regard for Mr. Boies, would you -- would his views as to the credibility of Virginia Roberts be something that would be important to you in evaluating the case? MS. McCAWLEY: Objection. MR. SIMPSON: Are you instructing him not to answer? MS. McCAWLEY: I mean, is it a hypothetical? MR. SIMPSON: No. I'm just asking whether his views -- those views -- I'm not asking what the views are. I'm simply asking whether those views would be important to him. MR. SCAROLA: You may answer that question. THE WITNESS: Yes. BY MR. SIMPSON: Q. And if I -- I may have asked this already, but did you discuss with Mr. Boies his views as to the credibility of Miss Roberts? MS. McCAWLEY: Objection. MR. SCAROLA: Same objection. Same instruction. BY MR. SIMPSON: Q. Prior to December 30th of 2014, had you ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 00:25:17 00:25:19 00:25:24 00:25:26 00:25:32 00:26:35, 00:25:36 On OO hm WH «a 00:25:39 © 00:28:43 oo28as 10 oozsas 11 oozsas 12 00.2550 13 00:25:52 14 002554 15 00:25:57 16 00:26:01 17 00:26:04 18 oo2607 19 oo2600 20 ooz614 21 002617 22 0026-20 23 00:26:20 24 002624 25 Page 176 to 179 of 335 179 substance. We will get to that. But, to your knowledge -- put -- let me rephrase that. Did someone tell you that they had discussed with Mr. Josefsbergs -- Josefsberg, the allegations made by Miss Roberts against Professor Dershowitz? MR. SCAROLA: You may only answer that question to the extent that you had any communication regarding that subject matter with someone outside the common-interest privilege, or the attorney/client privilege for that matter. BY MR. SIMPSON: Q. I'm simply -- I'm not asking for substance, just the name if you did. MR. SCAROLA: Well, I understand that, but following along the same lines as before, you are asking us to identify the subject matter of a communication that is privileged. We won't answer questions regarding the subject matter of privileged communications, but if Professor Cassell had a conversation with Sam Smith standing on the street corner about Bob Josefsberg, he can answer that question. BY MR. SIMPSON: Q. Did you have a conversation with anyone -- just narrow question: Did you have a conversation with ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:08:15 PM HOUSE_OVERSIGHT_010847