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02:24:50 02:24:50 02:24:52 02:24:53 02:24:57 02:24:58 02:24:59 On Don bh WH = 02:25:01 iis) 02:25:03 o22505 10 02:25:08 11 e221 12 o22514 13 oz2s14 14 02:25:19 15 022520 16 02:25:22 17 o2z2s23 18 022626 19 022528 20 022532 21 02:25:34 22 0225:37 23 02.2542 24 o2r254a 25 02:25:49 02:25:54 02:25:56 02:26:04 02:26:05 02:26:06 02:26:10 On Oa B&H = 02:26:15 c2ze1a 9 022623 10 022625 11 ozz628 12 022633 13 or2eas 14 o2z636 15 oz26a1 16 022646 17 o2ze49 18 022650 19 022686 20 022650 21 0227.00 22 02:27:02 23 o2270s 24 022707 25 10/20/2015 01:08:15 PM Yes, In all four, you met with the clients? in three of the four, And were those three the three in which you were counsel of record? A, Yes. Q. As of December -- A. I believe I was counsel of record on all three of those. I would have to double-check. I know I was counsel of record in the federal case. The two of them are state cases, I believe, that it was pro hac in the state cases, Q. Okay. I won't ask you the names, but in the four cases, what are the initials of your clients? A. Okay. So the -- the -- Q. Put it this way: How are they identified in the caption that you filed? A. Well, also the three that were filed, one was ~~ one was the initials S.R. I referred to Miss S.R. yesterday. That was the Jane Doe case in Federal Court in front of Judge Marra. There were two state claims. I'll -- I'll identify the clients as E.W. and L.M. Q. And then the fourth one? A. The fourth one, I believe -- the initial M. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 261 and I believe the last initial was B., but I may be wrong about the B. First initial M. Q. At the -- okay. At the time that you filed the joinder motion -- A. Yes, Q. — -- in the federal case, so December 30th of 2014, you knew that naming Prince Andrew would generate substantial publicity, correct? A. I knew it would attract a lot of attention. Yeah, I mean, “substantial” we could debate, but, sure, I knew that that was going to -- you know, once you start exposing the extent of this criminal activity, obviously, there were going to be a lot of people interested, yes. Q. And you also knew that naming Professor Dershowitz would attract publicity? A. Well, when you say "naming," one of the things you've got to understand is the names were already in the case, both Prince Andrew and Alan Dershowitz. We had pending discovery requests for information about both of them. So when you say “naming them," you know, they were already named in the case. Now, would the additional allegations have attracted additional attention? Sure. Q. Mr. Cassell, it's true, is it not, that the ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 02:27:40 02:27:16 02:27:24 02:27:25 02:27:28 02:27:34 02:27:31 On On kh WD a 02:27:39 iis) 02:27:41 oz2745 10 oz2raa 14 czars: 12 02:27:54 13 ozarss 14 ozorsa 15 ee 16 022808 17 022812 18 oz2a12 19 ozze19 20 0228:20 21 022821 22 022824 23 022825 24 02:28:27 25 02:28:29 02:28:31 02:28:33 02:28:36 02:28:37 02:28:38 02:28:45 Aan nah © NH = 02:28:50 o22a86 9 o22as7 10 ozz000 14 02:25:09 12 0229-12 13 022017 14 oz2019 15 022922 16 022927 17 022929 18 022931 19 022935 20 0229:38 21 022042 22 02:29:43 23 0220.47 24 oz2049 25 262 filing on December 30th of 2014, was the first time that you had ever, yes, ever on behalf of Virginia Roberts or any other client, accused Professor Dershowitz or Prince Andrew of sexual abuse in a public filing? A. If you're talking about direct allegation, that’s correct. Q. Had you ever public -- well, at no other time that -- you expected when you filed the pleading on December 30th, 2014, that it would be -- be something of public record that would generate publicity, correct? A. Public record, the focus was not generating publicity. Of course, when you file an allegation like that, there certainly would have been -- we would anticipate there would have been publicity, absolutely. Q. And before December 30th of 2014, to the best of your knowledge, neither you, nor anyone else, had told Professor Dershowitz that there were allegations that he personally had engaged in sexual misconduct? A. Um... MS. McCAWLEY: I'm going to object to that date if that reveals anything that would be privileged between something that would have been communicated by the client. MR. SIMPSON: No. These are communications to Professor Dershowitz. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 263 MR. SCAROLA: Yes. And that could very well include attorney/client privileged communications. MR. SIMPSON: Let me -- I'll ask my question. BY MR. SIMPSON: Q. My question is: Did you ever advise Professor Dershowitz that there were allegations that he had engaged, himself, in sexual misconduct with minors? A. Not me personally, no. Q. Are you aware of any e-mail, letter, other communication from anybody that went to Professor Dershowitz that told Professor Dershowitz that he had been accused of engaging in misconduct himself? A. Well, there -- I mean, I'm aware that there was a deposition request in 2009. There was a deposition request in 2011. That was accompanied by an exchange of correspondence that said, for example, numerous witnesses have placed you in the presence of Jeffrey Epstein and underaged girls. It didn't then go on to say, and you were committing sexual abuse of them, but it said numerous witnesses had -- had done that. And I think a reasonable inference would be that, you know, you're verily sure that a witness and then that also raises the possibility of -- well, I mean, I think Professor Dershowitz mentioned yesterday, ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 Page 260 to 263 of 335 28 of 46 sheets HOUSE_OVERSIGHT_010868