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02:48:55 02:49:56 02:49:56 02:49:59 02:50:02 02:50:02 02:50:03 ON OO hB WD = 02:50:08 o2zso09 9 ozso14 10 02:50:20 11 ozs024 12 0280-20 13 ozs0:30 14 ozsoa1 15 asos1 16 o2soas 17 asoss 18 o2so4st 19 o2:s045 20 025049 24 o2s040 22 o2ses4 23 o2s0se 24 025058 25 02:51:01 02:51:02 02:51:05 02:51:08 02:54:71 02:51:12 02:54:17 ON anh WD 02:54:19 iis) 02:51:24 10 o2s126 14 ast3s2 12 o25136 13 asic 14 oasis 15 o2sias 16 ozs1a9 17 ozs1s1 18 02152 19 025156 20 025200 21 o2s203 22 028212 23 o2sar 24 o2s219 25 02:51:24 10/20/2015 01:08:15 PM I've read it correctly. o2s221 1 A. Okay. 028228 2 Q. “Epstein also sexually trafficked the ozs225 | 3 then-minor Jane Doe" -- and that's Virginia Roberts, 025231 4 correct? ozse35 5 A. Yes. ozs230 6 Q. -- "making her available for sex to ozseae 7 politically-connected and financially-powerful people. ozszaa 8 Epstein's purposes in lending Jane Doe, along with other ozszae 9 young girls, to such powerful people were to ingratiate ozs2s0 10 himself with them for business, personal, political, and o2s2si 11 financial gain, as well as to obtain potential blackmail oze2s3 12 information.” ozsase 13 Did I read that correctly? o2rs304 14 A. You did. ozsa07 15 Q. What did you mean by “obtain potential oas311 16 blackmail information"? 028313 17 A. Okay. Let me just double-check. o2sat6 18 Once the criminal organization had put the orsate 19 bait out, so to speak, to various people, and they took orsa2a 20 the bait that -- you know, I'm -- I'm speaking orsa26 24 colloquially here. These are -- these are young girls 025330 22 who are being sexually abused. Once the criminal orsaa2 23 organization had gotten people to sexually abuse 028335 24 these -- these young girls, at that point, they had ozsa3ze 25 ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 285 information that they could use to blackmail those orsa39 1 people and -- and then get favors in exchange. oxsaaa «2 And that's Epstein at the head of the ozsa4s 3 organization would be the one who would benefit most | 025.48 4 directly from the black -- the blackmail information. ozs3s9 | 8 Q. And by “blackmail information,” do you mean ozsass «6 that Mr. Epstein then had information that he could ozsass | 7 threaten to disclose if the other person didn't do what ozsaso | 8 Epstein asked them to do? orseor 9 A. Precisely. orsaos 10 Q. As of December 30th, 2014, if Miss Roberts ozsaoo 11 had access to publicity, she had exactly the same o2s409 12 ability to blackmail people; isn’t that true? ozss00 13 A. Absolutely not, A billionaire has far more aseis 14 resources than a victim of child sex abuse, particularly | 025422 16 one that has been forced into hiding in Australia to o2sa2r 16 escape the criminal organization. orsezt 17 So for you to suggest that Virginia Roberts 02432 18 had the same ability to blackmail somebody as Jeffrey — | 02:53. 19 Epstein is, I think, preposterous. ozsa3s 20 Q. As of -- Miss -- Miss Roberts had the same o2se36 21 ability as Jeffrey Epstein to reveal publicly the names ozsa30 22 of the people who she says sexually abused her, as did orsaa2 23 Mr. Epstein; isn't that true? ozssar 24 A. You're talking about physical ability to 025480 25 ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 Page 284 to 287 of 335 286 speak words. They both have the same physical ability to speak the English language, yes. Q. And, in fact, before, at least three years before December 30th, 2014, she had the ability to be quoted in an article, more than one article, in the Daily Mail in London about her experiences, correct? A. That's correct. Q. Andam I correct that as of December 30th, 2014, you didn't know whether she was paid for that interview or not? A. Iwasn't sure. That's right. Q. And after December 30th, 2014, the references to Prince Andrew and Professor Dershowitz generated international publicity; isn't that true? A. Okay. Which -- yes, I mean, in a general sense, I could ask which allegations, but these allegations did generate publicity, certainly. Q. Yes. The allegations in your joinder motion that Prince Andrew and Professor Dershowitz had abused Virginia Roberts, then known as Jane Doe Number 3, generated a firestorm of publicity; did it not? A. It generated a lot of publicity, yes. Q. And within days of that, you were -- you were participating in attempting to arrange an interview with ABC News; isn't that true? ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 287 A. That -- within days of -- the chronology is important here: The allegations were filed in this pleading on December 30th. Several days after that, Mr. Dershowitz then took to the airwaves to denounce, not only Brad and me, but -- but particularly of concern to me was Virginia Roberts, this victim of sex trafficking. And, at that point, as one of -- as one of her attorneys, I was looking for a way to respond to that media assault on her by Mr. Dershowitz. MR. SIMPSON: Move to strike as nonresponsive. BY MR. SIMPSON: Q. Did -- within 24 hours of this pleading being filed, there was publicity about the allegations against Prince Andrew and Mr. Dershowitz -- Professor Dershowitz; isn't that correct? A. I don't know the exact time frame, but that -- you know, roughly that time frame sounds about right. Q. said anything, wouldn’t you expect that these If Mr. -- if Professor Dershowitz had never allegations as to Prince Andrew, in particular, and Professor Dershowitz would get substantial publicity? A. There was -- there was -- ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 34 of 46 sheets HOUSE_OVERSIGHT_010874