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"Certainly he knew they were there?
"T don't know, sir."
That's the best you can do? That's really
the best you can do? You think a professional lawyer would make these allegations based on "I don't know, sir."
MR. SCAROLA: Is there a question pending, Mr. Scott?
MR. SCOTT: He's reading -- you asked him what he was reading --
MR. SCAROLA: Yes, sir.
MR. SCOTT: -- from and I had him publish it.
MR. SCAROLA: Yeah, I know, and then he went on to make a speech. So I know I don't have to do it, but I'm compelled to move to strike the unresponsive speeches.
MR. SCOTT: And I consider these to be a response to the interrogation that you did taking excerpts improperly and not having the entire record in front of him, which he's entitled to do to make that the record is complete. And | intend to protect him in that way.
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303
A. Let me answer. "Rely" connotes to me that they would place a heavy emphasis on that to the exclusion of other things and that it would be enough. And so my answer is, yes, they certainly should have read all the reports. They certainly should have read all the transcripts. But they also should have called me, they should have made other inquiry, and they should have made sure that they read all of these depositions and reports in context.
And if you're implying that there are FBI reports that in any way inculpate me, that's inconsistent with the information I have from Former Chief of Assistant Jeffrey Sloman, who was prepared to file an affidavit saying that that wasn't the case but was prevented from doing so by the Justice Department.
MR. SCOTT: It's about noon now. So I
guess we're heading -- we're wrapping this up?
MR. SCAROLA: Not quite yet.
BY MR. SCAROLA:
Q. You do agree that the allegations that Virginia Roberts made against Prince Andrew were well-founded allegations, correct?
A. Ihave absolutely no idea. I've met
302
BY MR. SCAROLA:
Q. So we have agreed that it was reasonable for Bradley Edwards and Paul Cassell, in assessing the credibility of Virginia Roberts, to rely upon police reports, FBI reports, U.S. Attorney's Office information, and information from the Palin Beach County State Attorney's Office, correct?
A. No.
Q. No?
A. No. It would not be enough for them to do that --
Q. I didn't ask you whether it was enough.
A. You said it was --
Q. Lasked you: Would it reasonable for them to rely upon those sources of information in assessing the credibility of Virginia Roberts?
A. Not alone, not without looking at --
Q. That wasn't ny question.
A. -- other sources of information.
MR. SCOTT: Wait a minute. BY MR. SCAROLA:
Q. Well, what he's relying upon --
MR. SCOTT: You're not the judge here.
Let him -- ask a question and let him answer it
and not cut him off, please.
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Prince Andrew on a number of occasions in a public context. He came and spoke in my class at Harvard law school. The dean then had a dinner in his -- or lunch in his honor. I was then invited to a dinner
at the British Consulate.
I've never seen him in the presence of any underaged women, so I have absolutely no basis for reaching any conclusion whatsoever about Prince Andrew.
Q. So you don’t know one way or another whether those allegations are true or false?
A. Neither do you. Nobody would know except two people, I imagine. But I don't know. Of course
. All right.
A. But I presume --
. You say you have never seen him ~-
A. -- people innocent --
Q. -in the presence of any underaged women, but you've seen photographs of him in the presence of an underaged woman, correct?
A. Thave, yes.
MR. SCAROLA: May we mark this as the next numbered exhibit, please.
A. And I want to note --
32 (Pages 301 to 304)
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