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excerpts out of a deposition to try to imply something when there's other parts that totally are inconsistent with that. And if you're going to do that, then he has the ability under our rules to review the entire transcript of
the deposition and that's what I'm permitting him to do, just like when we're in court.
MR. SCAROLA: What I ain doing,
Mr. Scott -- what | am doing, Mr. Scott --
MR. SCOTT: Have you read that now, sir?
MR. SCAROLA: -- is reviewing the evidence that was relied upon by Bradley Edwards and by Paul Cassell in coming to the conclusion that the allegations that had been made by Virginia Roberts were, in fact, credible allegations.
MR. SCOTT: And I'm --
MR. SCAROLA: Because your own client has acknowledged that this is information that was available to both him and to them back in 2009.
MR. SCOTT: And what I am doing is showing him portions of the same deposition that totally take a different position from this witness from what you have read, so that this record is a complete record and not a partial record with your inference only. And I feel
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that that's totally appropriate. If we were in a courtroom, a judge would permit him to do it. So you have your position and I have mine. MR. SWEDER: Can we have the witness read that? BY MR. SCAROLA: Q. Do you recall the following testimony
having been given in that same deposition?
"Question: Allright. This is follow-up to questioning by Ms. Ezell. Ms. Ezell asked you about Mr. Dershowitz being present in Mr. Epstein's home, and I think you said -- I think you said Mr. Epstein and he and Mr. Dershowitz were friends?
“Answer: Yes.
“Question: She also, I think, asked was Mr. Dershowitz ever there when one of the young women who gave a massage was present in the home.
“Answer: I don't remember that.
"Question: That's where I want to clear
up. Is it your testimony that Mr. Dershowitz
was there when any of the women came to Mr. Epstein's home to give a massage? "Answer: Yes."
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295
Do you remember that testimony having been given?
A. lassume that when your clients used the transcript as a basis for their false conclusion that I was guilty, they read the whole transcripts, not just the --
BY MR. SCAROLA:
Q. Every word.
MR. SCOTT: Don't interrupt him. BY MR. SCAROLA:
Q. You don't need to assume that. 1 will stipulate they read every word.
MR. SCOTT: Mr. Scarola, he's speaking.
You don't have a right to do this.
A. And if you read every word, you will see that it's totally exculpatory, that I have no idea whether there were any young women in one part of the house when I was in another part of the house. It's completely consistent with my testimony that | have never seen any underage women. Let's see.
And if you read the whole transcript, you'll see, | think: "Was Dershowitz ever there when one of the woman gave a Massage? "I don't remember that.
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"Were you in -- were you in any way attempting in your response to imply that
Mr. Dershowitz had a massage by one of these
young ladies?
"T don't know, sir.
"You have no knowledge?
"No, sir.
"And you certainly weren't implying that
that occurred; you just have no knowledge,
correct?
“Answer: I don't know."
And I would hope that your clients would be reading the whole thing in context, unlike what you've tried to do to try to create a false impression that this testimony in any way exculpates me.
I have to say if this is what they relied on, my confirmation of their unethical and unprofessional conduct has been strongly corroborated by that and you're helping my case.
BY MR. SCAROLA:
Q. Would it have been reasonable for Bradley Edwards and Paul Cassell to have relied upon the detailed reports of Palm Beach police department?
A. 1 don't know. I don't know what the Palm
30 (Pages 293 to 296)
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