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00:43:54 00:43:55 00:44:00 00:44:00 00:44:02 00:44:04 00:44:08 On OO hb WO NH = 00:44:08 oosat2 9 coat? 10 ooaata 141 ooaae1 12 004425 13 00:44:29 14 coz: 15 00:44:34 16 oo-aa:37 17 oo-aa:38 18 cosaan 19 ooaaaza 20 00:44:47 21 00:44:50 22 00:44:53 23 00:44:86 24 onaass 25 00:45:03 00:45:06 00:45:06 00:45:12 00:45:14 00:45:18 00:45:18 CNOA RW ND 00:45:20 is) 00:45:23 onas2e 10 oo:45:20 14 oosssz2 12 oo4s:as 13 ooasiss 14 00:45:38 15 ooas:30 16 oo-4sa2 17 ooasas 18 ooasae 19 aoasso 20 oo45s1 21 00:45:52 22 ooasss 23 coasse 24 onasss 25 10/20/2015 01:08:15 PM 196 Virginia Roberts. I knew Josefsberg was an attorney who had represented Miss Roberts based on public information, and I knew that that would be a gross violation of Mr. Josefsberg's attorney/client obligations. And as a result of that, it seemed to me that, once again, Mr. Dershowitz was giving false information under oath In an effort to exculpate himself from the sex trafficking that he had been involved with. In addition to that, I learned during the deposition on Thursday that it had, quote, not crossed my mind, close quote -- I believe that's a direct quote from Mr. Dershowitz -- to record a conversation with a woman allegedly named Rebecca who had allegedly made certain statements. That was on Thursday. And then yesterday, Friday, I learned that Mr. Dershowitz, not only had it crossed his mind to make a recording, he had, in fact, made such a recording; and in fact, had it transcribed; and in fact, turned it over to his attorneys. So, once again, I had what appeared to be a false statement under oath by Mr. Dershowitz in an attempt to exculpate himself from the -- the sex ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 197 trafficking that we -- we have evidence he has been involved with. The false statements or certainly misleading statements continue. I suppose, some of these could be a matter of judgment. The -- they raise grave concern to me. One of them was that we had propounded an interrogatory requesting the basis for Mr, Dershowitz's statements that Virginia Roberts had a criminal record. And he said that, well, she's admitted that she had sex with various people, so that renders her a criminal, and something along those lines, which I didn’t think was very accurate. But in any event, that was the answer he gave. And then I learned during the deposition in the last two days, that Mr. Dershowitz had received information that he says shows that Virginia Roberts had stolen money from a restaurant and had been criminally charged with that, That was not produced to us during discovery, even though it would have been obviously relevant, and it was directly called for in the discovery that we were provided with. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 00:46:02 00:46:05 00:46:10 90:46:10 00:46:12 90:46:42 00:46:15 SON OOH hk WOH = 00:45:16 is) 00:46:17 00:46:20 10 00:46:21 11 00:46:23 12 00:46:27 13 ooe27 14 00:46:28 15 00:46:29 16 ooaea2 17 00:46:34 18 00:46:35 19 oossaz 20 00:46:46 21 00:46:50 22 90:46:52 23 00:46:55 24 00:46:59 25 00:47:02 00:47:05 00:47:07 00:47:11 00:47:14 00:47:17 00:47:20 oN OO bh WN = 00:47:21 is) 00:47:25 00:47:28 10 ooa7an 11 oo:a734 12 004737 13 ooa7a: 14 ooaraa 15 onaras 16 ooa7as 17 ova7s2 18 ooa7ss 19 coarse 20 onas02 21 ooas0s 22 00:48:08 2d cosets 24 ooas1a 2D Page 196 to 199 of 335 198 You know, I also have -- I would like to refresh my recollection and if ~~ if counsel -- that's -- MR. SCAROLA: You can refresh your recollection on anything you need to. THE WITNESS: All right. I'd like to refresh my recollection by looking at -- MR. SIMPSON: Actually, I -~ I object to this answer as nonresponsive. I haven't heard anything about flight logs once. MR. SCAROLA: You can continue. THE WITNESS: These -- you know, these all go to the statements. BY MR. SIMPSON: Q. You're looking at a document? A. Yeah. Let's mark it as an exhibit if you'd like. This is a memory aid to me. Q. Did you prepare it? A. Yes, I did. All right. Let's see. At page 114 of a rough transcript that I saw prepared of Thursday's testimony, Mr. Dershowitz was asked. Quote: You know that Virginia Roberts is not the only person who has sworn under oath that you were present at Jeffrey Epstein's Palm Beach home with young girls, right? Answer: No. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 199 That seemed to me to be false or at the very least misleading testimony given that Mr. Dershowitz knew that Juan Alessi, among potentially other people, had identified him as having been in the presence of Jeffrey Epstein and young girls at the Florida mansion and, indeed, had identified a photograph of Virginia Roberts. At page 164 of the transcript, Mr. Dershowitz was asked, quote: All of the manifests that have been produced in this litigation, the ones that you say corroborate your testimony and exonerate you, demonstrate that you never flew on Jeffrey Epstein's plane in the company of your wife, correct? Answer: No, that's not true. I don't know that. And, again, in the context of this litigation where the flight logs have been, as this question that I'm answering tends to show, are so central for Mr. Dershowitz to testify under oath that he didn't know whether his wife was depicted on the flight log, struck me as, at the very least, misleading information, but I concluded in my opinion was actually deliberately false information, particularly, given this litigation where he has produced, not only his own personal travel record, but all of his wife's travel records for the relevant period of time. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 12 of 46 sheets HOUSE_OVERSIGHT_010852