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Oo O DN OO FF WwW NY = NO RO PRP LP PNMO NO | S| S| |S FS FS S| S| | | no Bb WO NO F- ODO OO WDNnN DO OT BP WO NYO — 111 would be the benefit of asking him. Well, I thought the benefit would be zero. What I thought we would get was zero, because in 2009, an effort to depose him had been made unsuccessful. 2011, an effort had been made to depose him unsuccessfully. In 2013 -- MR. SIMPSON: Was there an objection on the phone? MR. INDYKE: No. MR. SIMPSON: Okay. I didn't think so. BY MR. SIMPSON: Q. Please continue. A. In 2013, an effort had been made to depose him unsuccessfully, and I mentioned a moment ago this manner of people involved in Epstein's organization that had been evading efforts to get information. So it wasn't just that something hadn't been received in the mail. It appeared to me that Dershowitz fit into a pattern of not providing information and, indeed, he had been party to making, supposedly, Mr. Epstein available to the Palm Beach Police Department and then pulling -- pulling him back. And that seemed to be a stall tactic. So I didn't think we were going get any information. On the other hand, now we had to waive a cost of calling Mr. Dershowitz and saying, we are preparing to file a pleading that identifies you. And I ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021934