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03:07:13 03:07:18 03:07:21 03:07:23 03:07:26 03:07:27 03:07:28 On AD ah ON = 03:07:30 iis) 03:07:33 10 030733 11 030736 12 03:07:38 13 o30742 14 oxoras 15 oso7aa 16 oxorsa 17 030733 18 oxorss 19 03.0755 20 03:07:50 21 030801 22 03:08:07 23 o30oe10 24 030011 25 03:07:33 03:08:17 03:08:22 03:08:22 03:08:25 03:08:26 03:08:29 03:08:31 ON Oak © DH = 03:08:32 iis) 03:08:34 10 030840 14 0308-41 12 o30a49 13 o30asi 14 oosss 15 030902 16 ox0002 17 os0o10 18 os0e14 19 030021 20 030921 21 0303-21 22 0309-26 23 030030 24 030032 25 03:08;37 37 of 46 sheets 296 but, obviously, Epstein and his criminal associates have had the ability to -- to destroy the evidence that's been -- that we have been trying to gather. Q. And in -- in your answer a couple of questions -- A. They have been able to conceal would probably be a more I-- I'm sorry. I shouldn't say "destroyed." accurate term, the -- the evidence that we are trying to gather. Q, A. Yeah. Q. my question a couple of questions ago, you talked about whether Mr. Epstein and Virginia Roberts would have the In my answer -- in my answer -- ~~ in the question and answer, your answer to same or equal ability to disclose -- A. Right. Q. -- what these prominent politicians, et cetera, had done, correct? A. Q. Without attempting to make any comparison, Correct. you would agree, would you not, that as of December 30th, 2014, Miss Roberts had the ability to name the names of the people who are referenced in this document? A. Q. Physical ability, yes. And -~ well, let me ask this: You say a ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 well-known prime minister. Is that Prime Minister Barak? MS. McCAWLEY: I'm gonna instruct you not to reveal any attorney/client communications you had with Virginia Roberts on the specifics of her counsel to you about these individuals. BY MR. SIMPSON: Q. business executives, Les Wexner? MS. McCAWLEY: Again, same instruction. BY MR. SIMPSON: Q. Okay. Now, you mentioned yesterday -- well, Is one of the other -- one of the powerful a moment ago, you testified that these -- in your view, these allegations about other powerful men furthered Miss Roberts’ legal position in the case, correct? A. Yes. Q. the allegations regarding Professor Dershowitz and And it's also your position, I assume, that Prince Andrew furthered Miss Roberts' legal position; is that right? A. Q. Does the fact that Judge Marra struck those Absolutely. allegations as impertinent, scandalous, and completely irrelevant to the case, cause you to reassess? MR. SCAROLA: Excuse me. Is that -- is that ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 03:09:34 03:09:36 03:09:37 03:09:39 03:09:41 03:09:45 03:09:46 ON Dah ON = 03:09:48 iis) 03:09:50 10 03:09:54 1 1 03:09:50 03.0988 12 o3t000 13 14 15 16 17 03:10:05 18 os:to0s 19 0310-09 20 oxto13 24 03:10:15 22 031017 23 03:10:20 24 osto2s 25 03:10:01 03:10:04 03:10:04 03:10:04 03:10:27 03:10:28 03:10:29 03:10:31 03:10:31 03:10:32 03:70:34 On Dak WN «a 03,10:35 is) 03:10:37 10 osto-at 14 osto4s 12 ostoas 13 o3:1052 14 o310:52 15 os1oss 16 o3t100 17 o3:t1:01 18 oatt04 19 oxt107 20 ostrie 24 oxi13s 22 o31116 23 oxi? 24 oxttte 25 03:10:38 Page 296 to 299 of 335 intended to be a direct quote? MR. SIMPSON: Back up. BY MR. SIMPSON: Q. What is your understanding of Judge Marra's ruling with respect to these allegations about Professor Dershowitz and Prince Andrew? A. That they were premature. Q. That's your understanding of his order? A. Yes. Q. Okay. A. And I-- maybe I should -- I see some skepticism there, so let me explain why I think those allegations -- Q. Yeah. Well, we can pull -~ A. -- are appropriate. Q. ~~ we will pull out the order itself -~ A. Sure. Q. -- at the appropriate time, but first, your understanding is that the judge didn't find that those allegations, at the time they were made, were so irrelevant to the case, that they should be stricken from the public record? A. had in our -- our brief -- let me explain the -- the In that pleading at that time, remember, we nine reasons why we thought that those allegations were ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 299 relevant to the case, since I think your question calls for that. Q. Are those the nine reasons you gave yesterday? A. No, I didn't have a chance to. Q. Are they the nine reasons that are set forth in your -- in your brief? A. They are. Those are the nine reasons that are set forth in the brief. Q. Okay. And -- and Judge Marra had that brief in front of him when he held that, these allegations were so not relevant to the issues before the court, that they would be stricken and not part of the public record? A. I think you're mischaracterizing Judge Marra's ruling in At that time, in that particular pleading -- its entirety, He specifically said that the allegations could be reasserted, if they were relevant to issues that are -- that were coming up. And so, in following that ruling, we went to the U.S, Attorney's Office, propounded discovery requests and said, look, we believe you're sitting on information that Dershowitz was, you know, connected with the -- with the criminal trafficking here; we would like you to produce those documents. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:08:15 PM HOUSE_OVERSIGHT_010877