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252 254 ozo134 1 THE VIDEOGRAPHER: 10:38. 021851 ‘1 counsel of record in three cases and you were involved ozonas 2 (Thereupon, a recess was taken.) 021858 2 in another case -- at least one other case in which you oxisto 9 THE VIDEOGRAPHER: We are back on the video o2tass 3 did not appear -- ozt6a2 4 record, 10:49 a.m. oztess 4 A. That's right. oztea2 5 BY MR. SIMPSON: oatas9 | 5 Q. -- as counsel of record; is that correct? cseae 6 Q. Back on the record. My question, ota00 «6 A. That's -- that's my recollection right now, ozte4s 7 Mr. Cassell, was: Whatis your best estimate of how ow F yeah. o21es0 8 much money you have made representing victims of Jeffrey o21903 8 Q. Allright. How many of those cases have been o2tess 9 Epstein? 2108 9 resolved at this point? c216s6 10 A. In which case are we talking about? ca1a06 10 A. AH. All -- of the four, I recall all four oztess 14 Q. In -- in any case. Combined total. oz1908 11 have been resolved. cat701 12 A. Okay. With regard to the CVRA case, that's oxteos 12 Q. Okay. Without telling me the amount, did you 021708 13 ~=pro bono, no money there. With regard to the other ozte12 13 receive -- all four were settled; is that right? o21707 14 cases, I'd like to answer your question, but due to oz1e15 14 A. Correct. oi710 15 confidentiality obligations that have been imposed upon | 021915 15 Q. Without telling me the amount, is it correct 021713 16 me by Jeffrey Epstein, in the course of negotiating oz1921 16 that in all four of those cases, you received a legal o21716 17 those cases, I'm not permitted to answer that question. | 021927 17 fee? 021723 18 MR. SCAROLA: We are certainly willing to 021928 18 A. I think that starts to call for a question I oziz2s 19 respond appropriately to a court order in that 021933 19 need to consult with my attorney about. 21727 20 regard, but it requires a court order to release ozte36 20 Q. Simply the question of whether in each of czirso 24 us from the contractual confidentiality oz1939 21 them you received a fee? o21733 22 obligations that we are under. 0219.40 22 A. Ijust want to... oi733 23 +BY MR. SIMPSON: o2r1e42 23 THE WITNESS: Is -- is there any problem -- o21736 24 Q. Is it your testimony, Mr. Cassell, that there oxtea2 24 MR. SCAROLA: You can respond to that. You 21741 25 are confidentiality agreements with Mr. Epstein that orteas 25 can answer yes or no to that question. ESQUIRE DEPOSITION SOLUTIONS ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 (954) 331-4400 253 255 0217-48 ‘1 preclude you from giving the total amount paid without ozteae 1 THE WITNESS: Yes, I received something. o2i7s1 2 breaking it down into particular cases? ozieas 2 BY MR. SIMPSON: 021753 8 A. I'm sorry. I didn't understand. ozie4a | B Q. Okay. Was the fee -- and if it's different oai7sa |= 4 Q. Oh, maybe that wasn't clear. Let me do it oz1950 4 for the -- the cases, tell me, but was it a contingent oarse § this way So we avoid -- o2z1ose § fee or some kind of hourly fee? cara «=«G A. Yeah, orsess 6& MR. SCAROLA: That -- that does get into ozra00 | «7 Q. -- the confidentiality issues. oziesa 6 7 attorney/client privileged matters. The terms -- ozteor 8 In how many cases have you been counsel for a o22000 BB MR. SIMPSON: You're instructing him not to 21807 9 person suing Mr. Epstein alleging that she was a victim? o22008 9 answer? oziere 10 A. Counsel of record? 022004 10 MR. SCAROLA: -- the terms of the oatasa 14 Q. Put it this way. How -- weil, start with o22004 11 representation are attorney/client privilege. I 21817 12 that, counsel of record. oz2008 12 instruct him not to answer. ozre1a 13 A. 1 believe three. oz2008 13 MR. SIMPSON: All right. oxtare 14 Q. Okay. And in addition to those three, have 022000 14 BY MR. SIMPSON: 021826 15 you assisted other counsel in some way without becoming oz2010 15 Q. In addition to these four cases that have 021822 16 counsel of record in cases by women suing Mr. Epstein 022013 16 been resolved, are you representing any other clients o1a36 17 alleging that they had been abused? 022018 17 who are alleging, in a case seeking monetary damages, 021838 18 A. I believe there’s one other case in addition 022023 18 that they were abused by Jeffrey Epstein? 021841 19 to the counsel of record case. 022028 19 A. I-- 021842 20 Q. And without telling me -- 022028 20 MS. McCAWLEY: I'm going to object to the orseaa 21 A. I'd -- I'd have to go double-check my record. 022029 21 extent that this seeks any information related to o14 22 This is an approximate best recollection. 022033 22 Virginia Roberts that could be deemed privileged 021846 23 Q. All right. 022035 23 or confidential. oz1e43 24 A. It's about four. 02:20:38 24 THE WITNESS: So what's the... ozreaa 25 Q. To the best of your recollection, you were o22036 25 ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 26 of 46 sheets 10/20/2015 01:08:15 PM Page 252 to 255 of 335 HOUSE_OVERSIGHT_010866