891 893 1 not there are missing logs, have you -- 2 A. That's not been something I've focused on. 3 I was only looking at whether or not, within the 4 timeframe, who was with who on what flights, and I 5 saw that was on some flights with 6 other prominent academics, but never on a flight 7 with me. 8 Q. Do you know who 9 out to for sex by Jeffrey Epstein? 10 MR. INDYKE: Objection based upon 11 attorney-client privilege, work product. 12 A. No, I can tell you outside of the 13 privileged information. I can tell you outside of 14 the privilege. I can tell you outside of the 15 privilege that she has claimed to have had sex on 16 numerous occasions with Leslie Wexner, and was told 17 by — by Sigrid McCawley that -- 18 MS. McCAWLEY: I'm going to object to the 19 line of questioning. 20 MR. SCOTT: Time out. 21 A. That is from a statement made to me -- 22 MS. McCAWLEY: No, I just want to be clear 23 because if we're going to violate the privilege 24 again, the order of seal. 25 A. We are not. was lent 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. EDWARDS: Q. I just want the names of the individuals. A. I can't just give you that. I can tell you that -- Q. That's what Pm asking for. SPECIAL MASTER POZZUOLI: Hang on one second. The question is: Do you know who was lent out to for sex by Jeffrey Epstein? MR. EDWARDS: Right. The names of the individuals is all Tm looking for. SPECIAL MASTER POZZUOLI: There's an objection. Okay. Go ahead. A. I was told by John Zeiger, who was Leslie Wexner's lawyer, that Sigrid McCawley claims that her client, , alleges that she had sex with Leslie Wexner on numerous occasions, including one -- and she said this, according to Mr. Zeiger, very aggressively -- MS. McCAWLEY: This is revealing confidential settlement discussions. A. Between who? MS. McCAWLEY: Between -- I'm not going to reveal what confidential settlement discussions because that breaches a privilege. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 892 MS. McCAWLEY: Fm going to stop that right now because the only conversations I've had with you are in the context of settlement discussion in this case. A. It was not a conversation with Sigrid McCawley. And please let me answer the question. I had a conversation — BY MR. EDWARDS: Q. Just so we know what the question is, my question is -- A. The question is do I know whether she had sex -- Q. No, its not. MR. SCOTT: Let's just ask the question. SPECIAL MASTER POZZUOLI: Hang on. And, court reporter, please reread the question so we understand. COURT REPORTER: "Do you know who was lent out to for sex by Jeffrey Epstein?" A. And the answer — MR. SIMPSON: Darren had an objection for you. A. Okay. I understand the instruction, and I can answer the question. 894 1 So what I'm going to say is that we are 2 not entitled here to be revealing any 3 settlement discussions that have happened on 4 behalf of my client. I'm not going to allow 5 there to be testimony as to that. To the 6 extent this involves Mr. Wexner's attorneys, 7 they are not present at this deposition at this 8 moment who you are mentioning, John Zeiger, 9 who's not able to object to this line of 10 questioning. You've had your client Jeffrey 11 Epstein's lawyers on the phone the entire time, 12 he should be entitled to a right to object to 13 this before there's a revelation of any 14 settlement discussions. 15 MR. SCAROLA: I want to know for the 16 record that Mr. Dershowitz has chosen to 17 disregard the instruction that came from 18 Mr. Epstein's counsel. And that -- 19 A. No, I haven't. I have said this comes 20 outside the privilege. 21 SPECIAL MASTER POZZUOLI: Stop. Let him 22 put his — on the record. Go ahead. 23 MR. SCAROLA: Which is inconsistent with 24 the position that Mr. Dershowitz's counsel says 25 they were taking, and that is that they were 29 (Pages 891 to 894) www.phippsreporting.com EFTA01137786