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ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 268 270 oz3as2 1 believe, please provide me with any such reason. 02:35:33 1 In the context of this case, to say, you have eras | 2 I am certain I can demonstrate to you that it is ozss3s | 2 been observed in the -- in -- by numerous ozaase | 3 false." ozasar 3 witnesses in the presence of a convicted sex 023380 4 Is that consistent with your recollection of ozssa1 4 offender and underage girls, and we would like to oz3401 § the response? ozasas | 5 talk to you about those observations, I think ozaan1 -& A. That sounds about right, yeah. oz3sas 6 that puts you on notice that you're in -- in -- oz3sa0a 7 Q. So Mr. Dershowitz did not ignore the letter; ozasa9 «7 in jeopardy of -- of criminal activity, oz3s0e §=©8 ~—-he responded to it, correct? o2ass2 8 particularly when you combine that with the fact ozsa0e | 9 A. I think that's right. 023854 9 that there is a duty to report child abuse in oz3a07 10 Q. And go back to the first letter. o238s7 10 many states in this country, including the State oz3a10 11 A. But, now, if we are -- if we're talking 023557 14 of Florida. 023411 12 about -- yeah, there's that one letter and now there's a o2ssso 12 And so that if those observations were such 23414 13 response letter, right. 023602 13 that they would give rise to a reasonable cozaar 14 Q. My question to you is: Does the statement to ozze0s 14 inference that sex abuse was -- of children was 023421 15 a person that "we have reason to believe that you have oz3608 15 going on and you'd be obligated to report it, as 023426 16 personally observed another person in the presence of o2ae00 16 I think Mr. Dershowitz conceded yesterday, yes, o23431 17 underage females and we would like to ask you about your 023612 17 you -- I think that puts you on notice that -- 023433 18 observations,” put the recipient on notice that you, o2se14 18 that those kinds of things are being alleged. 023441 19 yourself, are accused of criminal conduct in abusing 23616 19 BY MR. SIMPSON: ozaaas 20 = minors? ozse18 20 Q. So, first, the letter itself, the fetter from ozsaas 21 A. Well, it puts you on notice that you're a 023622 21 Mr. Scarola simply says, you were -- you were personally o230aa 22 potential, obviously, witness to this and then therefore 023628 22 ~- you personally observed Jeffrey Epstein in the 023451 23 you could have potential involvement. 02:36:31 23 presence of underaged females, correct? 023453 24 Let me give you a simple illustration. It'll 023633 24 A. Correct. ozasss 25 take about 20 seconds. If somebody says -- 02:36:33 25 Q. It does not say, you witnessed abuse of any ESQUIRE DEPOSITION SOLUTIONS ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 (954) 331-4400 269 271 o2zsass | 1 Q. Well, let me back up. My first question, 023637 1 minor; we have reason to believe you observed abuse of 02:34:57 2 though, if you can answer the question. 023639 2 minors? ozaass |S MR. SCAROLA: No. I'm sorry. The witness is 023630 «3 A. If those words do not appear there, but come o2zas00 | 4 entitled to complete his response. If you os3ea1 4 on, we -- we know -- we know in the context of this o23so1r 5 don't -- if you believe it to be unresponsive, o23e4a «5 case, when somebody is asking to take a deposition about oz3s03 «6 you can move to strike it, but he’s entitled to 023647 6 your observation of young girls, they weren't talking ozas0e «67 complete it. 023650 ¢ about preparations for birthday parties. They were orasas «8 MR. SIMPSON: He -- 023652 8 talking about sexual abuse of children. aasos 9 MR. SCAROLA: So go ahead and complete your ozsese 9 And that was what Mr. Dershowitz was going to o23808 10 response. o23eso 10 be asked about. And he did not -- he did not take that o2as08 11 MR. SIMPSON: Can we have a -- you can give oz3702 11 opportunity to try to clear the record; instead, we are, ozasne 12 an explanation, but a yes or no with an 023708 12 you know, here today, because among other reasons, he -- oza810 13 explanation. o2a700 13 he -- he wasn't deposed then. ozas11 14 MR. SCAROLA: You already got that. Could we ozs712 14 Q. I want -- I want to comment. I'm just a o23612 15 now have the completion of the response? oza7-18 15 little bit non -- nonplussed, so I want to come back to eras 16 THE WITNESS: Here's the simple illustration 0237-21 16 this again. oz3s16 17 I think makes it pretty clear: If somebody says, o2z3721 17 A. Well, I'm -- I have to tell you, I'm a little oz3617 18 we have observed you in the presence of a kilo of 023723 18 bit nonplussed that somebody would say that letter 023520 19 cocaine, we would like to question you about the 023728 19 doesn't put you on notice that you're potentially 0236-23 20 presence -- about your observations of this, that 023721 20 involved in criminal activity. I mean, come on. 023626 21 doesn’t directly state that you are a drug user 02:37:30 21 Q. 1-- my question wasn’t potentially involved o2627 22 or a drug dealer, but it certainly puts you on 0237:33 22 in criminal activity. We disagree about whether it does 02:35:29 23 notice that you're associated with that criminal ozarae 23 that. 02:36:31 24 activity and somebody is going to question you o2ar37 24 A. Okay. I think it does, 023831 25 about it. ozar3s 25 Q. I suspect you -- that’s how you read it? ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 30 of 46 sheets 10/20/2015 01:08:15 PM Page 268 to 271 of 335 HOUSE_OVERSIGHT_010870