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of outrageous, horrible, inexcusable misconduct, at least call the person and ask them if they can disprove it before you file a -- a statement. Not even asking for a hearing on it, not even basically seeking to prove it, just -- just putting it in a pleading as if scrolling on a bathroom stall.
So, yes, | had -- I had a great basis for making that kind of statement and I repeat it here today. And we will find out in depositions what basis they actually had. And I'm anxiously awaiting Mr. Cassell's deposition this afternoon.
MR. SCAROLA: Move to strike the
non-responsive portion of that answer.
Could I have a standing objection to
unresponsive --
MR. SCOTT: Sure.
MR. SCAROLA: -- answers? That would be
helpful. Thank you. I appreciate that. That will save us --
MR. SCOTT: Absolutely. No, any time.
MR. SCAROLA: -- save us some time.
MR. SCOTT: Thank you, sir.
BY MR. SCAROLA: Q. The one portion of what you just said that directly responded to my question was you knew in
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your assertion that the testimony of these two individuals completely exculpates you.
A. Uh-huh.
Q. The following question was asked of --
MR. SCOTT: What you are reading from?
MR. SCAROLA: I'm reading from the deposition transcript.
BY MR. SCAROLA: Q. The following question was asked of ~
MR. SCOTT: The deposition transcript --
BY MR. SCAROLA: Q. -- of Mr. Juan - Mr. Juan Alessi and --
MR. SCOTT: Let me object to the -- first of all, let me object to this format because he has not been provided a part of the deposition. You're reading portions from the deposition --
MR. SCAROLA: Yes, Iam.
MR. SCOTT: -- which can be taken out of context. He has not had the ability to review the deposition. This is improper.
MR. SCAROLA: Okay.
MR. SCOTT: Cross-examination,
BY MR. SCAROLA: Q. Do you recall the following questions having been asked of Mr. Alessi and the following
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early January of 2015 that Bradley Edwards and Paul Cassell had the sworn testimony of two - did you refer to them as house --
A. House people.
. House staff? . House staff. . House staff of Jeffrey Epstein's -- . That's right. . —- correct? And those two individuals are Juan Alessi and Alfredo Rodriguez, correct?
A. That's right.
Q. And you, in fact, were aware of the existence of that testimony from shortly after the time that the testimony was given, weren't you?
A. Well, I was certainly aware of it at the time | made these statements.
Q. Yes, sir. But you also knew as far back as 2009, when this sworn testimony was given, that you were specifically identified by name in the sworn testimony of Jeffrey Epstein's house staff members, right?
A. Iwas identified by name in a manner that completely exculpated me, yes.
Q. Okay. Well, let's -- let's take a look at
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answers have been given during the course of this deposition which you contend completely exonerates you?
"Question: Do yeu have any recollection of VR, referring to Virginia Roberts, coming to the house when Prince Andrew was there?
"Answer: It could have been, but I'm not sure.
"Question: When Mr. Dershowitz was visiting --
"Answer: Uh-huh.
"Question: -- how often did he come?
"Answer: He came pretty -- pretty often.
I would say at least four or five times a year.
"Question: And how long would he stay typically?
“Answer: Two to three days.
"Question: Did he have massages sometimes when he was there?
“Answer: Yes. A massage was like a treat for everybody. If they wanted, we call the massage, and they get -- excuse me -- and they have a massage.
"Question: You said that you set up the inassage tables, and would you also set up the
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