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264 266 022951 1 that if you're in the presence of a convicted sex 023203 1 MR. SIMPSON: I'm sorry. You were right, oz254 2 offender, or a sex offender and sex abuse is going on, ozaz0s «2 yes. 022857 3 you would have obligations, for example, ata minimum to | 023208 3 MR. SCAROLA: Can you just show it to him? 23000 4 report that, and it raises the possibility of other 023209 4 MR. SIMPSON: I'll read it, and then if he 023002 § criminal activity as well. o23211 § wants to look at it, that will be fine. oza004 6 Q. Is it your testimony, Mr. Cassell, that ozaz12 6 MR. SCAROLA: Thank you. oz3007 7 telling a person that multiple people have identified 023213 7 BY MR, SIMPSON: oza01s § you asa witness to some activity is fair notice that ose «8 Q. This is a letter from Mr. Scarola to 23020 9 you, yourself, are accused of engaging in criminal o2a21s 9 Mr. Dershowitz dated August 23rd, 2011. The second 023023 10 misconduct? oza223 10 sentence says -- well, I'm going to read the whole 023026 11 A. So-- so you, I think, recharacterized the 023226 11 thing. 023022 12 letter that went to Mr. Dershowitz in 2011, The letter, 023226 12 MR, SCAROLA: Yeah, thank you. o2:3032 13. as I recall, doesn't say he is a witness. It says, if I 13. BY MR. SIMPSON: 23023 14 recall -- we can double-check the language -~ but I 14 Q. "We do not" -- oz3022 15 believe the language says: Numerous witnesses have 15 MR. SCAROLA: It's short, so it would be 023042 16 placed you in the presence of Jeffrey Epstein, underaged 16 helpful if you just read the whole thing. oz3048 17 girls, and Epstein. Then, you know, so at that point, 17 BY MR. SIMPSON: 022048 18 given what we know in this case, given that at that 18 Q. Yeah. 23052 19 point in 2011, there had been an ongoing set of 023228 19 "We do not intend to inquire about any o2z308s 20 allegations against Mr. Epstein, I -- I think your ozaza1 20 privileged communications or attorney work o2z3089 21 question doesn't -- doesn't take into account this 02:32:33 21 product. We do, however, have reason to believe 02:31:03 22 surrounding context. 02:32:37 22 that you have personally observed Jeffrey Epstein 02:31:04 23 Not to mention the fact there had been a 2009 023241 23 in the presence of underaged females, and we 023107 24 deposition request and a 2013 document request. 023240 24 would like the opportunity to question you under o23i12 25 Q. Okay. I think you accurately characterized ozaza7 25 oath about those observations. Thank you for ESQUIRE DEPOSITION SOLUTIONS ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 (954) 331-4400 265 267 23115 4 the communication about the deposition request that o23261 1 your anticipated cooperation. Signed, Jack 02:31:20 2 multiple persons have placed you in the presence -- oz3283 2 Scarola." 023123 3 A. Right. o2s2se 3 If you would like to -- o2323 4 QQ. -- of minors -- ozsesa 4 A. Sure. oars § A. Right. ozazss § Q.— -- take a look at the letter to refresh 023126 6 Q. -- correct? oz32s7 6 yourself, you’re welcome to. oa3t27 7 A. I believe that’s my recollection. Numerous oz3300 7 A. Great. Thanks. Okay. 023123 8 witnesses have placed you in the presence of sex oz3a08 8 Q. Now, first, you're aware, are you not, that 023133 «9 offend -- at that point, convicted sex offender Jeffrey 023300 9 Professor Dershowitz answered that letter and said the oat3s 10 Epstein, who was convicted of sexually abusing underaged | 023312 10 assertion that he had observed Mr. Epstein in the 023138 11 girls, and underaged girls, and those are the subjects 0233018 11 presence of underage -- 02314 12 we would like to question you about. 023322 12 MR. SCAROLA: Females. 023143 13 And rather than getting a response that says, 023322 13 BY MR. SIMPSON: 023146 14 well, let me clear that all up, the response that's 023323 14 Q. — -- females was not true? o23142 15 received was, something along the lines of, give me more 023324 15 A. Something along those lines, yeah, oars1 16 information and -- and, quote: I'll decide whether I 023328 16 Q. Yeah. And I will read it from that letter -- 023154 17 want to cooperate, close quote, or something along those 023329 17 A. Okay. That would be good. Yeah, that would ozas7 18 Hines. 023331 18 be great. 02:31:57 19 Q. Mr. Cassell, let me -- I'm going to read to 023333 19 Q. And "I have never" -~ this is a letter from ozsis9 20 you -- 023333 20 =©Mr. Dershowitz to Mr. Scarola, August 29th, 2011. 023180 21 A. Good. oza338 21 “Dear Mr. Scarola, I have never personally 02:31:59 22 QQ. _-- from the letter itself -- 023341 22 observed Jeffrey Epstein in the presence of 023150 23 A. Okay. 023343 23 underaged females. I do not believe you have any 023202 24 Q. = and tell me if it's consistent with your 0233.46 24 reasonable basis for believing that I have. If 023203 25 recollection. 023349 25 you have -- if you claim to have reason to ESQUIRE DEPOSITION SOLUTIONS ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 (954) 331-4400 29 of 46 sheets Page 264 to 267 of 335 10/20/2015 01:08:15 PM HOUSE_OVERSIGHT_010869