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04:26:07 01:26:12 01:26:17 04:26:18 04:26:21 01:26:21 04:26:25 ON OA PR WN | 01:26:28 © 01:26:33 ot2630 10 or2641 14 01:26:44 12 or2e47 13 or26s1 14 04:26:54 15 orz6se 16 or2700 17 01:27:02 18 ora7os 19 04:27:08 20 oraroe 21 or27a2 22 O827:15 23 oars 24 arte 25 01:27:20 01:27:24 04:27:26 01:27:28 O1:27:32 01:27:37 01:27:41 On Oo Ah OND = 0127-44 oz |= 9 orazaa 10 oars: 11 04:27:54 12 012785 13 or27se 14 orza0r 15 01:28:02 16 01:28:02 17 or2806 18 01:28:09 19 01:28:10 20 01:28:13 21 01:28:15 22 012822 23 0128.28 24 or2829 25 224 226 Q. Would it be a reasonable inference, or a possible reasonable inference to draw, that Mr. Rodriguez was trying to highlight people who would be of interest to the Press for purposes of selling the book? A. No, because he was not talking to the Press. He was talking to an FBI agent who had busted him for criminal activity. And so I was assuming that what he was trying to do, as many criminals do when they are apprehended, was give information to law enforcement agency that would be helpful so that they can catch other "bigger fishes" is the phrase that's sometimes used, so that the little fish would -- would get off or get a cooperation deal from the law enforcement agency. He was talking -- let's be clear. He was talking to somebody he understood was an FBI agent at the time, and so that was the context of the conversation. Q. Do you have any personal knowledge that it's in the context of talking to the FBI that Mr. Rodriguez circled those names? A. Ihave reviewed -- I know I could refresh my recollection here, but there's an FBI 302, a report of interview of the circumstances surrounding Mr. Rodriguez's arrest, and I believe I reviewed that ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 in your testimony yesterday as the holy grail, an or2820 1 address book of Mr. Epstein? on236 | 2 A. Pieces of it, yes. arzezg «3 Q. Did you review the entire document? otzea2 4 A. No. orzeas «= 5 Q. Did I understand yesterday that you orzess 6 testified -- did I understand correctly yesterday, that orze4g 7 you testified that the fact that names were circled or2es2 8 indicated that those persons likely engaged in illegal orzess 9 sexual contact with minors? otzess 10 A. My-- my impression is the names that were or2e01 11 circled were circled by Alfredo Rodriguez when he was orze03 12 busted by the FBI for involvement, and he was asked to or2006 13 identify those who would have information about the sex | 012000 14 trafficking organization. And my -- based on all the oraa12 15 evidence I have, I believe the names that were circled or2a14 16 were those who would have that kind of information. o12017 17 Q. So is it your testimony that if the name is or2018 18 circled, it indicates that they have information, or i219 19 that they are criminals? or2022 20 A. That they would have information about the or2025 24 sex trafficking organization, and that would probably o1202 22 mean that they were part of the organization. It may o120:30 23 mean that they were witnesses to what the organization | 012923 24 was doing. or2g3s 25 ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 225 But they would have information that the FBI, or2038 1 among other law enforcement agencies, should be one3s9 «2 following up on, if they are trying to piece together or2a «3 what the sex trafficking organization was doing. or2sa 4 Q. Would you agree that a fair-minded person, orzese = 5 with that background that you just described, would not otaes7 6 go to the conclusion that the fact that a name is orzesa 7 circled indicates that that person has engaged in orz001 8 criminal conduct? osoos | 9 A. They -- what it would indicate is that they 01:30:08 10 had information relevant to criminal activity. Now, or3012 11 would they on the -- just the fact that a name was arz016 12 circled, standing alone, reach that conclusion? orzo19 13 Well, that's a hypothetical question because o1:3021 14 obviously in this case, there's lots of other 01:30:25 15 information, ors026 16 Q. Did you understand -- it is true, is it not, o13027 17 that Mr. Rodriguez was trying to sell that book? orsoae 18 A. That's true. 01:30:33 19 Q. And is it not also true that the people who ov3033 20 are circled are famous people? 01:30:38 21 A. I'd have to refresh my recollection as to or30-40 22 exactly who was circled, but I know that some famous or3040 23 people were circled and some famous people were not ors040 24 circled, 01:30:42 25 ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 19 of 46 sheets Page 224 to 227 of 335 227 302. Q. Do you know whether the FBI, at any point, contacted Professor Dershowitz to discuss any evidence he might have after his name was circled on this document? A. Idon't have personal knowledge of what the FBI did to follow up after that. Q. Okay. One of the names that's circled in the book is Courtney Love. Do you know who she is? A. Not off the top of my head, no. Q. If I mention to you or if I represent that she's a famous actress, any reason to question that? A. No. Q. In your view, was Courtney Love involved in sex trafficking? A. I don't know. Q. In your view, was Courtney Love a witness to sex trafficking? A. If -- is there a way -- are you representing her name ts circled? Q. Her name is circled on the book. In fact, we can show it -- A. Okay. Yeah. Q. It is circled on the book. A. Okay. Sure. Yeah, I mean, my -~ my ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:08:15 PM HOUSE_OVERSIGHT_010859