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03:32:42 03:32:43 03:32:43 03:32:43 03:32:46 03:32:50 03:32:54 On Oo OM hb O&O NH wa 03:32:58 osazss 69 03:3300 10 03:33:02 11 033306 12 o33305 13 033307 14 oss 15 023312 16 033315 17 oaasia 18 033321 19 03:33:24 20 03:33:28 21 03:33:28 22 03:33:32 23 03:33:34 24 o3xaa% 25 03:33:37 03:33:40 03:33:41 03:33:42 03:33:42 03:33:50 03:33:53 03:33:56 oon Oak WH 03:33:59 03:34:01 1 0 03:34:03 1 1 03:34:08 1 2 03:34:42 1 3 03:34:12 1 4 03:34:13 1 5 03:34:15 1 6 03:34:17 1 7 03:34:18 1 8 93:34:20 1 9 03:34:22 20 03:34:22 21 03:34:34 22 03:34:39 23 03:34:44 24 03:34:51 25 43 of 46 sheets 320 Q. Let -- let me ask you a different question then. A. Okay. Q. By -- by submitting this brief with your name signing it, you were representing that the factual allegations, factual assertions, were support -- are supported by the record citations that are given for those, correct? A. Yeah. I mean, obviously, when you write a brief, you're -- you're -- you know, you're trying to represent that this is the best product I can come up with. Now, you know, in a 40-page brief did -- did -- is there some, you know, error in citation or something like that? I have to -- I'm not perfect. I'm sure that's a possibility, but, you know, I worked hard to try to put together the best product that I could on behalf of Virginia Roberts when I filed this brief. Q. And -- and in general, when a lawyer signs a brief, it's a representation to the court that the citations to the record support the factual -- A. Yeah, to the -- Q._ _-- propositions given to the court? A. Yeah, that's right. To the best of, you know, your ability, sure. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 321 Q. Take a look if you would at page 29 -- A. Okay. Q. -- the top of the page -- A. Okay. Q. -- the statement: "Jane Doe number 3 came to the house when Dershowitz was there." And then it's "Id." which is a citation to the Alessi deposition, page 73, line 18 to 20. Do you see that? A. Ido. Q. So that sentence if I -- do you agree with me that sentence is representing to the court that Virginia Roberts came to the Palm Beach house when Professor Dershowitz was there? A. Yes. Q. I'm going to read you what's cited for that proposition. I can show it to you if you like. A. I would like to see it because, you know, it's possible I'm off. Q. Let me read it for the record. A. Sure. Q. And I will read what is cited. It's page 73, lines 22 to 25. Actually -- I'm -- yeah, I'm sorry. 73, 18 to 20. Line 18: "Not sure. When Mr. -- Mr. Dershowitz was ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 03:34:54 03:34:55 03:34:56 03:34:59 03:35:02 03:35:06 03:35:09 oN OM hk & HM = 03:35:09 03:35:10 9 03:35:12 1 0 03:35:15 1 1 03:35:15 1 2 03:35:16 1 3 03:35:16 1 4 03:35:16 1 5 03:35:20 41 6 03:35:22 1 7 03:35:24 1 8 03:35:26 1 9 03:35:27 20 03:35:30 21 03:35:32 22 03:35:35 23 03:35:36 24 03:35:40 25 03:35:43 03:35:44 03:35:46 03:35:49 03:35:50 03:35:53 03:35:54 On Oa ah WD «a 03:35:55 03:35:58 9 03:36:00 1 0 03:36:01 1 1 03:36:02 1 2 03.36:04 41 3 03:36:04 1 4 03:36:06 1 5 03:36:08 1 6 03:38:14 1 7 03:36:15 1 8 03:36:16 1 9 03:36:19 20 03:36:23 21 03:36:27 22 03:36:30 23 03:36:30 24 03:36:34 25 Page 320 to 323 of 335 visiting? "Uh-huh. Answer. "Question: How often did he come? "Answer: He came pretty -- pretty often. I would says as least four or five times a year.” And that's what is cited as the support for the proposition -- A, I'd -- I would like to look at the document. Q. I'm going to give you the document before I ask you to comment on it. A. Sure. Q. I will -- I will go beyond what was cited to the court -- A. Okay. Q. -- to put it in context. A. But I mean, there's -- this is a large -- well, that's what I'm saying. I would like -- my recollection is that there are number of parties to the Alessi depo -- Q. No. My -- my only question is in this brief, the lawyers signing it represented to the court that this citation supported that factual assertion. A. But that's true, yes. Q. Okay. I will read it. "Do you have any recollection of V.R., ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 323 Virginia Roberts, coming to the house when Prince Andrew was there? Question. "Answer: It could have been, but I'm not sure. "Not sure. When Mr. Dershowitz was visiting? "Uh-huh. "How often did he come? "He came pretty -- he pretty often. I would says at least four or five times a year." A. Okay. Q. Do you want to take a look at that? A. Yeah. MS. RICHARDSON: Page 73. BY MR, SIMPSON: Q. Page 73, line -- it's right here (indicating) if it helps you find it. A. Yeah, Okay. All right. That's what those lines say, yes. Q. Okay. So my -- my question is: In your view, as an attorney, does that quotation -- does that testimony support the assertion that Professor Dershowitz and Virginia Roberts were in the house at the same time? A. Those -- those lines 18 to -- Q. And if you want to put it in the context of a ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 10/20/2015 01:08:15 PM HOUSE_OVERSIGHT_010883