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07:58:01 04:58:05 04:58:06 01:58:08 01:58:10 04:58:43 04:58:16 Ont og h Wn «a 04:58:18 © 01:58:24 o1:sa24 10 ovss27 11 ousa32 12 ors 13 orseaa 14 orseaas 15 orsea7 16 ovsea? 17 orsaas 18 01:58:51 19 oxses: 20 07:58:53 21 07:58:55 22 01:58:56 23 orses7 24 orssse 25 04:59:03 01:59:04 01:58:06 01:59:08 01:59:10 04:59:43 04:59:15 ON oa & OH =A 04:59:18 01:59:22 9 04:58:26 1 0 01:59:26 1 1 01:59:27 1 2 04:59:34 1 3 01:59:34 1 4 01:59:37 4 5 01:59:42 1 6 orsoas 17 orsoa? 18 01:59:48 1 9 01:59:53 20 01:59:53 21 ovsess 22 01:59:59 23 02:00:04 24 02:00:07 25 25 of 46 sheets 248 A. Not -- you know, let's break that down ina couple pieces. The fact that his name is circled, if I were running an FBI investigation, I'd go send somebody to see what he knew about it, but no, it would take a fot more for me to become suspicious that somebody is involved in -- in sexual activity like that. Q. Okay. So you would agree with me then, that the fact that a person often visited the mansion, the person -- the fact that a person was a friend of Mr. Epstein for 15 years, the fact that the person had stated publicly that: "Mr. Epstein liked young women almost as much as I do myself,” and the fact that the name is circled in the address book is not sufficient to raise a Suspicion that that person engaged in sexual misconduct? A. So... Q. Yes or no. It's a yes or no question. A. It requires -- MR. SCAROLA: You're not required to answer yes or no, if a yes or no response alone would be misleading. THE WITNESS: The problem is the word "suspicion." I'm not particularly suspicious on those facts, but it -- you know, what do you mean ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 249 by "suspicion"? If 1 -- if I were running an FBI investigation and somebody circled a name as -- as saying, look, this fellow may have some information, I'd go follow up on that. If you say that's suspicion, then the answer would be, yes. But I -- you know, based on that information alone, no. I mean that -- that wouldn't -- wouldn't be enough for me to, you know, invest time and energy into that particular possibility. BY MR. SIMPSON: Q. Okay. So none of those facts are sufficient even to justify spending time and energy, correct? A. Unless -- if I'm running -- this is -- again, what do you mean by "suspicion"? Time and energy in the context of somebody who is running a pro bono case with limited resources to try to figure out what the sex trafficking ring's going to do, I'm not going to chase after that rabbit. It seems farfetched. I'm going to focus my efforts on the people who appear to be more directly involved. Q. Okay. So based on the facts that I gave you a moment ago, you think it's farfetched that Donald Trump was engaged in abusing minors? A. If that's all I had, I would not invest time ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 02:00:44 02:00:12 02:00:16 02:00:24 02:00:24 02:00:26 02:00:28 On Oa hk &® NY «a 02:00:29 ts] 02:00:33 02:00:33 1 0 02:00:34 1 1 02:00:36 1 2 020037 13 o20038 14 oz00-41 15 020044 16 020046 17 020047 18 oz0048 19 ozoo4e 20 020050 21 020051 22 020051 23 ozo0s3 24 o2o0ss 25 02:00:56 02:00:57 02:00:58 02:01:04 02:01:02 02:01:03 02:01:05 On oak WH = 02:01:09 ve] 02:01:08 ozo109 10 ozo110 11 ozo 12 02:00:47 13 ozo: 14 020113 15 ozo113 16 ozoris 17 ozorts 18 20120 19 020122 20 ozo124 21 ozor2e 22 o2z0128 23 ozo129 24 o20132 25 Page 248 to 251 of 335 250 and energy in that, right. And you referred to your pro bono case. What is your best estimate of how much money you have made representing victims of Jeffrey Epstein? In which case are we talking about now? Any -- any case representing a victim of Jeffrey Epstein. I need to confer with -- MS. McCAWLEY: Yeah. I'm going to object. BY MR. SIMPSON: And that -- that's a fact -- that's not a privileged question. That's a factual question. Factual. Well, there are -- there are -- Just how much money? You don't have to tell me who the clients are. Just how much money? A. Okay. I need to -- MR. SIMPSON: There's a question pending. I object to a break. There's no possible privilege. MR. SCAROLA: He has a privilege -- he has a privilege question. He wants to consult with counsel, MR. SIMPSON: Well, really? My question is how much money, and that's privileged? MR. SCAROLA: It may be. I don't know. We ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 need to talk. THE WITNESS: That's why I need to -- MR. SCOTT: There's no federal law or state law that supports that financial information and fees is privileged. MS. McCAWLEY: We can argue about that because that's in my motion, so we can argue about that. MR. SIMPSON: Well, can ~- can -- MR. SCOTT: That one, I know all about. MR, SCAROLA: You're objecting to our taking a break -- MR. SIMPSON: I am objecting -- MR. SCAROLA: -- while this question is pending? MR. SIMPSON: That's correct. MR, SCAROLA: It is our position that the witness has a legal question about privilege. We are going to take a break. We are going to talk about it. It may turn out that it’s not a problem at all. I don't know. THE VIDEOGRAPHER: We are going off the video record, 10:38. MR. SIMPSON: With my note, we are taking a break over my objection. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:08:15 PM HOUSE_OVERSIGHT_010865