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232 234 ov4os7 1 are circled is, I would say, you know, 5 to 10 percent ovat 1) BY MR, SIMPSON: oraroa «62 ~—«OOf the -- of the names ball-parking in the dark. ona 2 Q. But based on your testimony previously, you orang 3 Q. Do you know whether this address book was o14320 3 would consider all of those facts to be evidence that he oato7 4 Jeffrey Epstein's address book or Glenn Maxwell's oa2e 4 may have been? ovaitt 5 address book? oraa2s 5 A. They are, you know, certainly things that I oraz 6 A. I’mnot certain exactly whose book it is. I o14331 6 would want to follow up on. ois YF actually thought it was Alfredo Rodriguez maintaining a | o1332 7 QQ. And -- ois 8 copy of records in case he was worried that Epstein oraazs «8 A. If I were running an -- we were in the o4122 9 might try to have him killed at some point, and so this o1a3a3e 9 context, I take it, of your question, you know, if 014125 10 was his insurance policy, I think he said, against that oraz 10 somebody is running an investigation into the ovat28 11 happening. ovazaz2 11° organization, so... orat2a 12 MR. SIMPSON: Object to the nonresponsive 014343 12 Q. ‘Did you, in the course of your representation orar31 13 portion of the answer. o14a47 13° of Miss Roberts or any of the other Jane Doe clients you ov431 14 BY MR. SIMPSON: oaass 14 have had who have had claims against Mr. Epstein, make orarae 15 Q. Is the answer to my question: You don't know o143ss 15 any effort to find out whether Mr. Trump had abused any ovaiaa 16 whether it was Jeffrey Epstein's or Glenn Maxwell's oraao2 16 of them? oar38 17 address book? oraaog 17 MR. EDWARDS: I would just object to this oratza 18 A. Idon't know. And the reason I don't know orasca 18 being work-product privilege as it relates to oai41 19 that is because I actually believe it is neither -- orate 19 other cases that I’m working on with Paul that oaiaa 20 neither of their -- that's -- is it one or the other? oraaiz2 20 Jack is not involved in. ovias 21 Actually, I think it's a third possibility. I think orsai2 21 MR. SIMPSON: Okay. oraiag 22 this was Alfredo Rodriguez's insurance policy against o14ats 22 MR. EDWARDS: With respect to what we did o4s1 23 getting knocked off by Jeffrey Epstein. oraats 23 during our investigation on behalf of other orvaiss 24 Q. So that's the view you have of the oraets 24 clients. ora20s 25 — significance of this document? oraaia 25 MR. SIMPSON: Okay. ESQUIRE DEPOSITION SOLUTIONS ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 (954) 331-4400 233 235 orazcs 1 A. Yes. In part. I mean, there are other orae20 4 MS. McCAWLEY: Right. And I object on that oiaz08 «492 reasons it's significant, as we have been talking about, orag2o 2 to the extent that it reveals anything you did on ovato 3 mames are circled who appear to have relevant ores 3 behalf of Virginia Roberts. oa213 4 information on Jeffrey Epstein's criminal activities. oraaza 4 MR. EDWARDS: I don't think Jack would know onan? 5 Q. Donald Trump was a friend of Jeffrey Epstein; orvaazs 5 to object to this, but because I know of another orazze 6 is that not correct? oragos 6 case that we work on, that’s protected by our ovanaa 7 A. Treally don't -- my understanding is, yes, oras30 | 7 work-product privilege, who I talked to and who I oraz2e 8 but I -~ I don't have a lot of information about Trump. orsas2 § did not. arazze 9 Q. It's true also, is it not, that Mr. Trump was o14g32 9 THE WITNESS: I'd like to -- 4234 10 a frequent visitor to Mr. Epstein's residence? oraa32 10 MR. SCAROLA: In that case, I instruct you ovaaas 11 A. 1I-~I know that he visited frequent. I -- I oragza 14 not to answer. oraz 12. don't have a lot of information about Trump. oraaza 12 THE WITNESS: All right. orazaa 13 Q. And his name is circled in this book; is it oraz? 13 MR. SIMPSON: All right. You're here, os2a7 14 © not? oraa39 14 Mr. Edwards, as a client, not an attorney, orazar 15 A. I believe it is. orvaaar 15 correct? orazss 16 Q. Based on him -- assuming he's a frequent oraaaa 16 MR. EDWARDS: Yes. That's my primary role in orazs2 17 visitor to Mr. Epstein’s home, and that he's a friend of orvaaae 17 being here, but I'm going to protect the o4300 18 Mr. Epstein's, and that his name is circled in this orsass 18 privilege to the extent that it’s not being 4303 19 book, do you infer that he was engaged in criminal orvaaar 19 protected by others who don't recognize that the oraz0a 20 = sexual abuse of minors? orsaso 20 privilege needs to be protected on other matters. over 21 MS. McCAWLEY: I'm going to object to the oraas2 24 MR. SIMPSON: Okay. 014313 22 extent that your answer would reveal anything oraass 22 BY MR. SIMPSON: orsare 23 that my client has told you. o14ase 2S Q. Mr. Cassell, as of December 30th of 2014, ovate 24 THE WITNESS: No. oras03 24 were you aware that Professor Dershowitz had visited oar 25 or4s09 25 Mr. Epstein's home and stayed as a guest for a week in ESQUIRE DEPOSITION SOLUTIONS ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 (954) 331-4400 21 of 46 sheets Page 232 to 235 of 335 10/20/2015 01:08:15 PM HOUSE_OVERSIGHT_010861