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have another hour.
MR. SCAROLA: I'm almost ready to take a break.
MR. SCOTT: Okay.
MR. SCAROLA: Could you read back the last question, please?
First of all, I move to strike the unresponsive specch,
And now read back the last question, if
you would.
(Requested portion read back as follows:) THE REPORTER: "Do you remember having made those statements?” Do you want me to read prior to that? MR. SCAROLA: No, that's fine. That's the question that I asked. BY MR. SCAROLA:
Q. Is the answer yes?
A. I don't remember specifically. Ido gencrally remember having said that your clients could have easily discovered conclusive proof that Virginia Roberts was lying about me and that had -- because 1 knew, of course, it was false --
MR. SCAROLA: Tom -- A. -- been able to uncover such proof.
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be
CMU MOY AUB WDNR
266
MR. SCAROLA: That has nothing to do with the question I asked --
MR. SCOTT: Let's take -- let's take a break like I suggested and we'll come back and then you can ask your question and -- okay?
MR. SCAROLA: Well, while the question is pending, I would like an answer to the question before we break.
MR. SCOTT: Did you answer the question?
JHE WITNESS: [ thought I did.
A. But what -- could you repeat the question? I'll try to answer it in a yes or no if I can.
BY MR. SCAROLA:
Q. Did you make the statement that within an hour of learning of these allegations, you had gathered documents that completely exonerated you?
A. I don't recall those specific words --
Q. Thank you, sir.
A. -- but the truth --
MR. SCOTT: That's it, and I think he indicated that before.
MR. SCAROLA: That would be very helpful if we said that and then we stopped and we can take a break.
MR. SCOTT: He previously had said that
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and then explained it but now you have it
directly answered. So we're -- we're ata
break point.
MR. SCAROLA: Thank you. VIDEOGRAPHER: Going off the record. The time is approximately 11:01 a.m. (Recess was held from 11:01 a.m. until 11:23 a.m.) VIDEOGRAPHER: Going back on the record. The time is approximately 11:23 a.m. BY MR. SCAROLA:
Q. When did you last travel from outside the State of Florida to arrive in Florida?
A. The day before yesterday, | think.
Q. And where did you travel from?
A. New York.
Q. When were you last in Boston, in the Boston area?
A. About two weeks ago.
Q. So, if anyone had represented that you were going to be traveling from Boston to Florida this past weekend, that would have been a misrepresentation; is that correct?
A. Thave no idca what you're talking about.
Q. Well, I'm talking about your personal travels. If anyone had represented that you were
268
going to travel from Boston to Florida and canceled travel arrangements from Boston to Florida this past weekend, that would have been a misrepresentation, correct?
A. [have no idea what you're talking about.
I'm sorry.
Q. Well, what is it that you don't understand about that question? Either you were in --
A. The basis --
Q. -- Boston and were planning on traveling from Boston to Florida this past weekend or the last time you were in Boston was two weeks ago, so you couldn't have been planning --
A. I--
Q. -- on traveling from Boston to Florida.
A. Iwas actually in Boston -- now that I checked my calendar, [ was actually in Boston -- here, | have -- aha. It says -- and my calendar says | was in Boston. Then it says leave for Florida, but that got changed. Yes, that got changed, right.
Q. May | see that, please?
A. No, this is my personal calendar.
Q. Yes, I'm sorry, but if you refer to anything to refresh your recollection --
23 (Pages 265 to 268)
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