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BY MR. SCAROLA: Q. Who told you that the manifests confirm the accuracy of your publie statements? MR. SCOTT: If it involves lawyer-client privilege, don't answer it. THE WITNESS: Okay. BY MR. SCAROLA: Q. You're refusing to answer? A. No, I would like -- MR. SCOTT: Instruct you not to answer. A. -- to answer. But I've been instructed not to answer. I would like to answer. You've made a statement -- MR. SCOTT: There's no question pending. THE WITNESS: But he made a statement -- MR. SCOTT: But there's no question pending, sir. BY MR. SCAROLA: Q. What does it mean to make something up out of whole cloth? A. It means that Virginia Roberts and your clients -- Q. No, sir, | haven't asked you anything about Virginia Roberts. | haven't asked you anything about my clients.
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MR. INDYKE: Objection. This is Darren.
Anything that relates to your conversations
with Jeffrey --
THE REPORTER: He's going to have to speak up.
MR. SCOTT: You're going to have to speak up a little bit more, Counsel.
MR. INDYKE: Objection. This is Darren
Indyke. Anything that Alan might have to say
to that, to the extent they are covered under
conversations with Jeffrey Epstein, privileged
under attorney-client privileges as well as common interest privileges. MR. SCOTT: Do you understand? THE WITNESS: I do. BY MR. SCAROLA:
Q. To which your response was: "Sure, sure, certainly I have been his lawyer and J did speak to him about it. I wanted to make sure that his memory and mine coordinated about when I was at his island. He was able to check. I was able to check. | checked with my friends who went with me."
Did you make that answer to that question?
A. Yes.
Q. Disclosing the contents of your
254
1 want to know what the words "making something up out of whole cloth" mean.
A. 1 said those words in the context of Virginia Roberts.
MR. SCOTT: That's -- that's fine. Go ahead. BY MR. SCAROLA:
Q. What do the words mean?
A. That there was absolutely no basis for Virginia Roberts' claim that she had any sexual contact with me. That the story was entirely false. I don't know where the metaphor derives about whole cloth, but certainly that's the common understanding. And I repeat under oath that Virginia Roberts made up the entire story about
having sexual contact with me out of whole cloth.
Q. During the course of the same interview that we have been referencing with Hala Gorani —~ for the record, that's H-A-L-A, G-O-R-A-N-I.
A. What page?
Q. Page 19.
You were asked: "I'm wondering, have you
spoken to Jeffrey Epstein about this since these allegations came out in this suit in the United States? Have conversations happened there?"
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communication with Jeffrey Epstein, correct?
A. I disclosed that | had spoken to him to find out whether he had any records of when | was on his island. And, yes.
MR. INDYKE: Again, this is Darren Indyke. Jeffrey does not waive any attorney-client privileges here.
BY MR. SCAROLA:
Q. Well, the reason why you were able to answer that question and discuss with the press what Jeffrey Epstein was telling you was because you weren't his lawyer at that time, right?
A. No, I was his lawyer at that time. I'm still his lawyer.
Q. Oh, what were you representing him on then --
A. The ongoing --
Q. -- that is, on January --
MR. SCOTT: Whoa.
BY MR. SCAROLA:
Q. -- on January 5, 2015?
A. The ongoing --
MR. INDYKE: My objection stands.
MR. SCOTT: You can answer what you were representing him on, | think.
20 (Pages 253 to 256)
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