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01:49:39 04:49:40 01:49:42 01:49:44 01:49:46 01:49:46 01:49:48 ON OO hm WD - 01:49:48 01:49:48 9 04:49:51 1 0 01:49:57 1 1 01:50:02 1 2 04:50:04 1 3 01:50:06 1 4 01:50:07 1 5 04:50:10 1 6 04:50:12 1 7 01:50:15 1 8 01:50:15 1 9 01:50:17 20 01:50:19 21 04:50:19 22 01:50:22 23 015024 24 04:50:25 25 04:50:28 1:50.30 04:50:33 01:50:34 07:50:37 01:50:39 04:50:43 ON Aah WH = 07:50:46 01:50:48 9 04:50:52 10 ovsosa 14 01:57:00 12 04:54:00 13 01:54:00 14 01:54:04 15 04:51:03 16 orvsio0e 17 01:51:08 18 04:54:06 19 04:51:07 20 04:54:16 21 04:51:14 22 04:54:14 23 04:51:16 24 O451:18 25 23 of 46 sheets MR. SCAROLA: Could I ask for a clarification? Are you looking only for direct evidence and you want to exclude the circumstantial evidence? Is that the way you want to -- MR. SIMPSON: I'm asking. You can object to the form. BY MR, SIMPSON: Q. My question is: What was -- what were you -- what did you have in mind as supporting your conclusion or belief that he -- that Professor Dershowitz visited three to five times during that relevant period? MS. McCAWLEY: And I'm sorry. Can I just place an objection on the record. I'm going to object to the extent that -~ so that you do not reveal attorney/client privileged communication, unless it's something that's already public that she's revealed. THE WITNESS: Okay. Right. So I'm going to just exclude -~ I take it your question isn't asking about any communications, BY MR. SIMPSON: Q. = My question is asking about that, but I understand you're going to refuse to provide it. MS. McCAWLEY: Unless it's already public. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 241 THE WITNESS: Okay. So as of December 30th, I'm going to exclude any communications from Virginia Roberts from -- MR. SCAROLA: Except to extent that they have already been made public. That is, if she has given express permission to make disclosures, these were not confidential communications, but communications intended to be communicated to third parties, then you are permitted to include information from Virginia Roberts in your response to that extent. And 1-- go ahead. THE WITNESS: Okay. BY MR. SIMPSON: Q. As of December -- A. Right. Q. -- 30th, 2014 -- A. Right. Q. -- correct? So -- A. Yeah, that's right. QQ. -- any -- any public statements by her after December 30th, 2014 would not be included in the answer. A. Okay. MS. McCAWLEY: But let me be clear. Let me be clear about my objection. To the extent that she revealed something to you in a nonprivileged ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 04:54:23 04:51:25 01:51:26 04:54:28 04:54:30 01:54:32 01:51:36 01:51:39 Oo nN HM A Rh WwW DH a 01:51:45 01:51:49 10 04:51:52 1 1 01:51:55 12 01:52:00 13 o1s200 14 01:52:03 15 01:52:04 16 04:52:06 17 01:52:09 18 01:52:09 19 OS2:14 20 04:52:14 21 04:52:19 22 04:52:20 23 01:52:21 24 01:52:22 25 04:92:23 04:52:28 O152:34 01:52:34 04:52:35 04:52:37 01:52:41 01:52:43 Oona kh WR wa 01:52:45 o1s249 10 01:52:51 11 01:52:54 12 04:52:58 13 04:53:04 14 04:53:03 15 01:53:04 16 01:53:07 17 01:53:08 18 04:53:13 19 04:53:16 20 04:53:19 21 04:53:21 22 04:53:28 23 ovsase 24 04:53:35 25 Page 240 to 243 of 335 242 context, in other words, information that was going to be disclosed, not for advice, but factual information that she intended to disclose, that's no -- that's not privileged. But if it's something that she communicated to you in confidence with respect to getting legal advice, then that would be privileged. THE WITNESS: Right. Okay. So Juan Alessi's deposition, Alfredo Rodriguez's deposition, and then considerable circumstantial evidence which we don't have to rehash here involving the close personal association between Epstein and Dershowitz. I mean, again, we can rehash all of that, but those were -- those are -- that's kind of a quick -- because I know you want to get to a lot of questions -- that's a quick sort of highlight film, if you will. BY MR, SIMPSON: Q. Mr. Cassell, isn't it true that Mr. Rodriguez was not hired until several years after the Summer -- A. 2004. Q. Let me ask it again. -- until well after 2002? A. Yeah, about 2004. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 243 Q. And Mr. Rodriguez would have no personal knowledge of how often Professor Dershowitz visited during a period two years or three years before he was hired; isn't that true? A. So, look, this is -- this is why I was trying to speed up the answer to the question. We have a sex trafficking organization that is running a common scheme and plan that is continuing on until it was interrupted by law enforcement about 2005 and 2006. So what the -- the criminal organization is doing in 2004, unless I have some significant evidence that it's different than what was going on in 2002, 2001, 2000, 1999, I think it's reasonable to conclude that the same sort of criminal activities are going on later. So if -- if you want -- if you want me to get into the -~ the full scope of the criminal organization, we can get into it. But the fact that somebody in 2004 sees this going on, leads me to conclude that it’s probably the same thing going on in the absence of other information in 2001. Q. So from Mr. Rodriguez's testimony about what was going on, so to speak -- and my question related, what was going on the number of times that Professor Dershowitz visited. That's the topic. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:08:15 PM HOUSE_OVERSIGHT_010863