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01:16:44 01:16:44 01:16:47 01:16:48 01:16:48 01:16:52 01:16:57 Ont Oonh © NH = 01:17:00 ovsos 9 orszos 10 01:17:09 11 ort709 12 ora 13 O117:14 14 01:17:16 15 ois 16 ours 17 ore 18 ovi727 19 ovr31 20 otr7aa 21 o173s 22 o1730 23 ona 24 oniras 25 04:17:46 04:97:55 04:17:58 01:18:01 01:18:04 01:18:04 01:18:06 On Doak ON = 01:18:08 © 04:48:18 orss22 10 orte23 11 orta2s 12 orias1 13 orta32 14 orvta3s 15 ores: 16 orssas 17 ovtass 18 ortoo3 19 04:19:07 20 01:19:09 21 orro1s 22 01:19:15, 23 arias 24 orto1s 25 17 of 46 sheets lines, correct? A. That's right. with the law; is that correct? Q. And so you wouldn't -- Attorneys cannot make, for example, false things. with the law and legal ethics, correct? A. That's correct. would have been acting unethically, correct? A. That's correct, negative about an attorney because the attorney represented someone accused of heinous crimes? Q. Yes. everyone is entitled to a defense. reviewed the Palm Beach Police report? A. Portions of it, yes. think I've gone through it page by page. Q. When did you do that? report here with -- I don't know if I can... anything. 216 218 Q. In fact, I think you testified yesterday ovtore «1 MS. McCAWLEY: The location is fine. about your duty with respect to Miss Roberts along those ovie2 2 THE WITNESS: The location, once oni922 3 personaily -- once here in Florida, and then in oit925 4 my office in -- while in Salt Lake City. Q. And so with respect to Professor Dershowitz's ovte23 5 BY MR. SIMPSON: representation of Jeffrey Epstein, he would have been ovis2. §=§ Q. And are you able to place in time when you acting unethically if he didn't attempt to negotiate the orie22 YF reviewed these portions of the police report, other than best resolution for his client that he could, consistent o19:35 8 before December 30th of 2014? oria37 9 A. Not precisely, no. A. Right. Consistent with the law, yes. orts40 10 Q. And do I understand correctly from your extea2 11 testimony yesterday that that police report is one of A. I'msorry. Let me just -- consistent with oiea7 12. the things you relied on to support making the the law and with the ethical obligations of attorneys. ovi9s1 13 allegations against Professor Dershowitz that are otas4 14 included in the joinder motion? representations when they are negotiating those kinds of | o11956 15 A. That's right. ortoss 16 Q. It's also true, is it not, that that police Q. Right. The duty as a defense counsel, 012001 17 report includes an interview with an adult woman who was Professor Dershowitz's duty was to attempt to obtain the 012007 18 retained to provide massages at Jeffrey Epstein's best resolution he could for Jeffrey Epstein consistent or2011 19 residence for guests, among others; isn't that correct? or201 20 A. I believe that's correct. orzo1e 21 Q. And based on that, is it your testimony that Q. And, in fact, if he had not done that, he 012020 22 it's fair to presume that a reference that a guest got a 012024 23° massage is a code word for abusing a minor sexually? 012031 24 MR. SCAROLA: I'm sorry. Are you -~ are you Q. And would you agree that it would be o120:33 25 isolating -- ESQUIRE DEPOSITION SOLUTIONS ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 (954) 331-4400 217 219 inappropriate, totally inappropriate, to infer anything 012033 41 MR. SIMPSON: I don't -- I don't wanta 012034 2 speech, Mr. Scarola. If you object to the form, 012036 3 object to the form, and I -- if it's not a proper A. Just the fact of representation alone? or20:38 4 question -- or2038 & MR. SCAROLA: I want a clarification of the A. Yeah, that's right. Sure, of course, orzo3a 6 question, please. Are you isolating only that o12030 «7 piece -- Q. As -- before December 30th of 2014, had you or2039 8 MR. SIMPSON: I -- the question -- o12041 9 MR. SCAROLA: -- of information? or2042 10 MR. SIMPSON: I'm -- Iam asking a question Q. Had you reviewed the entire report? orzoas 14 that's perfectly clear. If you think it's A. I think I reviewed most of it, but I don't arzose 12 objectionable, it won't ~~ it will stand. or2049 13 MR. SCAROLA: I'm going to object on the or20s0 14 basis that it is vague and ambiguous. It is A. Well, let's see. Before December 30th, 2014, or20s3 15 unclear whether you're asking for him -- Brad and I filed the case in about July 2008, so it was or2055 16 MR. SIMPSON: Please don't coach the witness. about a six-year period of time, and I remember I'd been | 012056 17 MR. SCAROLA: -- to isolate -- to isolate his to Florida a couple of times on this case, once in 2010 o12050 18 focus to that single piece of evidence. and I think another a year or two later. And I 012059 19 MR. SIMPSON: I object on the coaching of the remember, at least on one of those times, reviewing the or2101 20 witness. o1:2101 21 +BY MR. SIMPSON: MS. McCAWLEY: Yeah. I wouldn't go into or2t02 22 Q. My question is: Is it reasonable, otzi06 23 considering that the police report on its face shows THE WITNESS: To the -- right. So we just -- o12i11 24 evidence -- let me back this up. Ask another question orzi1e 25 to you. we just want to know -- ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 Page 216 to 219 of 335 ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:08:15 PM HOUSE_OVERSIGHT_010857