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ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 236 238 ov4s:14 1) the company of his grandchildren, among other family o1az08 =f ~~ scene of ongoing criminal abuse of minors, and who oraste 2 members? ovaz12 2 himself, has engaged in that criminal abuse, would bring orasig 3 A. I'msorry. Which residence? Which Epstein o1a716 «3 his grandchildren to stay there for a week? o4s23 4 residence? ovarzis «4 A. It would depend on the circumstances. oraz 5 Q. Palm Beach. oraz21 5 Q. When you say that Professor Dershowitz was a ovasas 6 A. Can you -- can you restate? ova7z33 § regular guest at the mansion, at the Palm Beach house, onas2s 7 Q. Yes. oars «7 it's correct, is it not, that you're referring toa 014527 8 A. I mean that's kind of a compound question. I o1a7a3 «8 ~~ operiod after Virginia Roberts had left for Thailand? ov4s30 «9 meanne ovaza? 9 A. No. or45:30 10 Q. Well, let me rephrase it. I will be clear. 047-49 10 Q. Are you aware of any evidence -- let me back orasiat 14 A. Yeah. ovarss 11 that up. orasi32 12 Q. Were you aware as of December 30th of 2014 -- ovars7 12 Are -- during the period that Virginia 014536 13 let me back up a moment. ovazs9 13. Roberts contends she was sexually abused, which I oraear 14 A. Sure. ovas02 14 understand to be middle of 1999 to middle of 2002 -- is ovass7 15 Q. You indicated yesterday that part of the o14a09 15 that consistent with your understanding? orasao 16 basis for your conclusion that this pleading -~ it was oraato 16 A. Approximately, yes. o4s:44 17 appropriate to file this pleading accusing Professor orvaata 17 Q. -- how many times did Professor Dershowitz ov4sae 18 Dershowitz of misconduct was that he was a guest at the orate 18 visit the Palm Beach mansion during that period? o145s3 19 Palm Beach house, correct? oraei7 19 A. My understanding is in the neighborhood of -- orasss 20 A. No. It was more than that. He was a o14a21 20 what was it? Three to five times a year, staying two to ovass7 21 frequent guest, a frequent overnight guest. oraa2s 21 three nights at a time. orago1 22 Q. My question is: As of December 30th, 2014, oraa2s 22 Q. And was that your understanding as of orasos 23 Were you aware that Professor Dershowitz had spent a otaa.22 23 December 30th of 2014? or4e10 24 week at the Palm Beach house with family members, ones 24 A. Yes. 014613 25 including his grandchildren? oraas2 25 Q. What was the basis for your understanding, ESQUIRE DEPOSITION SOLUTIONS ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 (954) 331-4400 237 239 oars 4 A. No. otaeaa 4 what pieces, what documents, or testimony? ovasis = 2 Q. Okay. Do you think it's reasonable -- would oraaas 2 A. Right. The information, you know, I gave a o14620 3 it be reasonable to believe that someone who is or4aa 3 «long presentation yesterday. So it was that o4e23 4 committing criminal sexual abuse of minors at a home o4ce 4 information. or4e2a ~5 where such abuse, as you understand it, is a daily ora | 5 Q. I want to focus now specifically -- I'm not oi4e33 § occurrence would bring his grandchildren to stay for a 014850 6 {ooking for a full answer on your entire views -- oreas «7 week? or4s:so | 7 A. Yeah, right. ovess 8 A. It would depend on the circumstances. I vasa 8 Q. -- on the case. o4e37 9 mean, you know, so -- you know, it would depend on the | 012053 9 A. Il appreciate that. o14s4o 10 circumstances. oraasa 10 Q. I just want to say, you've testified that you orzeao 11 MR. SCAROLA: Are you representing that o148:57 11. understood as of December 30th, 2014, that Professor ore 12 Jeffrey Epstein was there at the time? o1ag03 12 Dershowitz had -- was a visitor at the Palm Beach oraea2 13 MR. SIMPSON: I'm not answering questions. 014904 13 mansion three to five times during this relevant period ores 14 I'm asking questions. oras09 14 of 1999 to -- middle of 1999 to the middle of 2002. ovaeas 15 MR. SCAROLA: Oh, okay. oao14 15 What was the basis on December 30th of 2014, for just ovaeas 16 BY MR. SIMPSON: o14920 16 that fact? ovaea? 17 Q. So, in your view, you can -- let me -- let me oraoar 17 A. Right. I mean, I will take about a minute orasso 18 rephrase that. aiaa23 18 here because there are a few things I want -- orses2 19 You say it would depend on the o14925 19 Q. Okay. And I want to make sure my question is o1assa 20 circumstances -- ov4g28 20 clear. orsess 21 A. Sure. Sure. or4o28 21 A. Sure. oraess 22 QQ. -- that's your answer? or4g29 22 Q. I'm not asking you about any of your onaess 23 A. Yes. 014930 23 inferences about anything else. Just, what's the basis orssss 24 Q. Okay. So that you don't find it incongruous or4a3a 24 for your belief that he visited three to five times or4700 25 that someone who knows that a particular home is the o+4e32 25 during that two-year period? ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:08:15 PM Page 236 to 239 of 335 22 of 46 sheets HOUSE_OVERSIGHT_010862