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02:37:40 02:37:42 02:37:45 02:37:49 02:37:52 02:37:58 02:37:56 On A OB OD = 02:38:01 02:38:05 9 02:38:14 10 ozae19 14 023822 12 02:38:26 1 3 ozces0 14 02:38:31 1 5 02:38:32 1 6 czas 17 02:38:37 1 8 02:38:41 1 9 oz:a843 20 02:38:46 21 ozae4s 22 02:38:49 23 02:38:54 24 o23e00 25 272 A. I think it puts you on notice in the context of a country which has required people to report the sexual abuse of children, and somebody wants to talk to you about your observations of a convicted sex offender with underage girls, that that's going to be one of the subjects that's going to be discussed, yes. Q. My question was -- my initial question was: Does -- do the statements in this letter put the reader on notice that you, personally, are accused of abusing minors yourself, not that you have in some knowledge or evidence that someone else did it, but that you, yourself, did it; is that a way to give fair notice? A. Well, in fair notice in what context? You know, is he on notice that a lawsuit is going to be filed the next day? Simply from that piece of -- that letter alone, they are on notice, you know -- I mean, I think that puts you on notice that there are serious allegations afoot and it would be in your best interest if you hadn't done anything, to show up, attend a deposition, let all the facts come out so that everybody can know them. Q. Would you agree that accusing someone of themselves abusing a minor is different than accusing someone of having knowledge that somebody else did it? ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 02:39:03 02:39:04 02:39:09 02:39:14 02:39:17 02:39:21 02:39:21 On Ooh WD =A 02:39:23 © 02:39:28 oz3ae26 10 0230-26 14 oxae26 12 023927 13 023920 14 023030 15 o23032 16 02:39:36 17 0239-41 18 023943 19 ozae4s 20 02:30:48 21 02:39:62 22 023955 23 ozsesa 24 oz4o001 25 31 of 46 sheets 273 A. Yes. Q. And to accuse someone of abusing a minor is a serious, serious accusation of criminal conduct, personal criminal conduct, not just failing to report somebody else, but you, yourself, are abusing people? A. Oh, yeah. MR. SCAROLA: Are you suggesting that that's not criminal conduct? MR. SIMPSON: I'm -- I'm -- my question stands. BY MR. SIMPSON: Q. What is the answer to that? A. Itis a very serious charge, I agree. That's why we are all here today. Q. Okay. And -- and if you wanted to put someone on fair notice that they are accused themselves of being a sex offender, a criminal who has abused children, wouldn't you tell them that? A. That's a speculative question because that letter was designed to try to collect information about an international sex trafficking organization. And so as to =~ you know, I'm not going to speculate as to why Mr. Scarola wrote it that way. But my sense, based on the public record is, that he was trying to get as much information as he could about what Jeffrey Epstein and ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 02:40:03 02:40:05 02:40:07 02:40:08 02:40:10 02:40:13 02:40:16 ON Ooh WD = 02:40:18 © 02:40:22 ozao2e 10 oz4o27 11 024028 12 024032 13 ozaoze 14 ozao37 15 ozao40 16 ozao43 17 ozsoar 18 02400 19 024052 20 ozaoss 21 024058 22 ozator 23 oxstos 24 ozaros 25 02:41:16 02:41:21 02:44:25 02:41:26 02:41:28 02:41:31 02:41:35 ON Oa bh wD = 02:41:36 o2ataa 9 o2z4ta2 10 ozarazs 11 ozatas 12 02:41:44 13 ozata? 14 ozats3 15 ozarse 16 ozaz02 17 ozaz0a 18 o2420e 19 o2za209 20 ozaz12 21 o24r14 22 oazie 23 ozazie 24 02:42:18 25 Page 272 to 275 of 335 274 his criminal associates were doing. And he thought that Mr. Dershowitz would have information and was trying to collect that. Now, whether the -- the -- the tentacles of the organization would extend so that they wrapped around Mr. Dershowitz himself, I guess was the subject that -- that Mr, Scarola, I am assuming, was hoping to explore. But Mr, Dershowitz prevented that opportunity. Q. And Mr. Dershowitz, you knew, had been Mr. Epstein's attorney, correct? A. Correct. Q. And you knew, just as we have seen here today with multiple assertions of privilege, that he could not testify about anything he learned as an attorney? A. He could testify, and the fetter itself says, we are not going to ask you about any communications; we are going to ask you about observations of sex abuse by a convicted sex offender, and your personal knowledge of that. That would not have erased in the -- and Mr. Scarola's a very good attorney, and I'm sure all of his questions that we saw the last couple of days would have been very narrowly focused on observations about what this criminal organization was doing. Q. And so to the bottom line is that your view, your sworn testimony, this letter of August 23rd, 2011, ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 275 put Mr. Dershowitz, Professor Dershowitz, on fair notice that he was being accused of being a sex offender himself? A. We-- we have gone over this. I think it put him on fair notice that there were serious questions being raised about what he knew about this criminal organization, what the potential criminal responsibility he had for failure to report sexual abuse of a child, as well as other possibilities. MR. SIMPSON: I'm going to move to strike as nonresponsive. BY MR. SIMPSON: Q. My question is a very narrow one, whether this letter, in your opinion, under oath, fairly put Mr. -- Professor Dershowitz on notice that he himself was accused of abusing minors. A. Again, that's a vague question, I've tried to give the best answer I can. That was certainly a potential area of questioning. I think that puts him on notice that it would have been in his best interest to appear to answer those questions. MR. SIMPSON: I'm going to object to the answer again as nonresponsive. BY MR. SIMPSON: Q. It's a really simple question. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:08:15 PM HOUSE_OVERSIGHT_010871