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304 osteoo 1 Idon't know. steco 2 Q. And what they did with the fact that Courtney o3ste04 3 Love and Donald Trump were circled, you don't know also, o3t¢08 4 correct? oste08 | 5 A. That's right. Fair point. oteo7 6 Q. But somehow it's suspicious as to o3ste10 7 Mr. Dershowitz, but not as to anyone else? otei2 8 MR. SCAROLA: Objection. Argumentative. oste12 9 THE WITNESS: And I'm -- I'm glad to argue on osie1a 10 that point, let me, because they -- oste14 11 MR. SIMPSON: I'll withdraw the question. oate1s 12 THE WITNESS: All right. Because I would osteitis 13 have a -- oxteis 14 MR, SIMPSON: Let -- oste17 15 THE WITNESS: -- a substantial argument on oste18 16 that. os620 17 MR. SIMPSON: I -- 1 will withdraw the o3is20 18 question. 031620 19 BY MR, SIMPSON: 03:16:28 20 Q. With respect, again, to the -- 031630 21 MR. SCAROLA: And I'll withdraw the osrtes2 22 objection. osr1632 23 MR. SIMPSON: Thank you. 031633 24 BY MR. SIMPSON: ostese 25 Q. At the time that you filed this joinder ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 305 osteao 1 motion, Exhibit 2, you knew that the United States oste4aa «2 Attorney's Office had denied having any contact -- any osteaa. 3 documents reflecting any contact with Prince Andrew; atest 4 isn't that true? ostes1 5 A. They had -- there were -~ there were various asses 6 discovery requests that had been propounded, and I think oies9 7% with regard to one, they had denied, and my recollection 01701 8 is with regard to another, where there had been an 031706 9 assertion of privilege. o3i707 10 Q. Is it not true, that before December 30th, os:700 11 +2014, in response to a request asking the government: 0371s 12 Are there any documents reflecting contact with -- by 031720 13 Prince Andrew regarding the NPA, the government 031724 14 represented, there were none? 031728 15 A. That -- with regard to the -- you're talking 0231730 16 about RFPs, request for production of documents, I 031732 17 believe that's -- I believe that's correct. o31733 18 Q. And on December 30th, 2014, knowing that, you 031738 19 named Prince Andrew in this motion, correct? oxs740 20 A. Correct. os7a 24 Q. And is it your testimony that you believe 031748 22 that Prince Andrew somehow attempted to influence the 03:1752 23 negotiations of an NPA in the United States as to osi7se 24 Mr. Epstein? o3i7s7 25 A. I don't have direct evidence of that, but I ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 39 of 46 sheets 03:17:59 93:18:02 03:18:04 03:18:07 03:18:09 03:18:15 03:18:19 On AoOeh WH = 03:18:23 93:18:23 9 03:18:25 1 0 03:18:27 1 1 03:18:30 1 2 03:18:31 1 3 o31e34 14 03:18:36 1 5 63:18:38 1 6 03:18:40 4 7 63:18:41 1 8 03:18:43 1 9 03:18:47 20 03:18:49 21 03:18:54 22 03:18:54 23 03:18:56 24 03:48:57 25 03:19:06 03:19:03 03:18:07 03:19:08 03:19:44 03:19:12 93:19:16 On OO ON = 03:19:20 is) 03:19:22 osta24 10 o3sto27 11 03:19:29 12 o31932 13 031033 14 osto3s 15 oxto38 16 ostaae 17 ostea2 18 osteas 19 osto-40 20 ostose 21 o3t9ss 22 ostosa 23 ostoss 24 osrteso 25 Page 304 to 307 of 335 306 certainly believe I have a good-faith basis, along with my co-counsel, to explore that subject, and try to see how someone who is fifth in line to the British Throne might have been able to use the contacts and power that he has to influence a -- a -- a disposition in this -- in the Crime Victims’ Rights Act case that it would have been favorable to one of his friends and potentially favorable to himself. Q, And -- and you have that view, notwithstanding that the government had represented they have no record of that? A. They didn’t -- no, no, no, no. Let's not -- not -- let's not slip and try to get me to admit something that is not what the record reflects. The government said they did not have documents. They did not say that they didn't have any information along those lines. To the contrary: They asserted a whole series of privileges every time we tried to get information along these lines. So the fact that they didn't have a letter, signed Prince Andrew, saying, please do the best you can for this convicted sex offender is one thing. That's the request for production of documents. But they never said that they -- they -- that ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 307 something along these lines had never happened and, to the contrary, we were faced with assertions of privilege over roughly, if I remember correctly, about 10,000 pages of documents where a whole host of privileges were being asserted. Q. Do you think it's credible that the United States Attorney's Office would be discussing an NPA with a member of the British Royal Family? A. Not directly, but there certainly are possibilities of surrogates. I -- my -~ somebody who is that powerful certainly wouldn't go out at it directly. What they would probably do is try to find the best lawyers they could around the United States and -- and, you know, and some of the, you know, big-named lawyers and try to bring them in there to -- to work a deal. That's, I think, how, you know, we're -- you're asking -- your question is asking for speculation and I'm saying that -- that based on, how would you influence a deal in an American criminal justice system? You go try to get the best defense lawyers you could and see -- you know -- you know, figure out which political party was in power; and try to get people who are well-connected to that political party, things like that. So that's the way that I think somebody might ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:08:15 PM HOUSE_OVERSIGHT_010879