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19 of 38 sheets
73 we would be happy to make it available to you. MR. SIMPSON: And -- and I'll give you an opportunity to look at that -- THE WITNESS: Sure -~ BY MR. SIMPSON:
Q. -- but I'm entitled to ask first about your recollection.
A. Okay.
Q. Based on your recollection --
A. Right.
Q, -- I want to know all the evidence --
A. Right.
QQ. -- you were relying on here.
A. to make a list here on my -- on my notepad of all the
So what -- what I'm going to do is, I'm going
things, and then I'm going to compare that with notes I have here. There may be a couple things that I don't cover.
Q. As long as your counsel is okay with that. Yeah.
>
Q. You understand you'll have to give that to
A. Yeah. I'll give you the notes --
Q. All right.
A. -- and then I will compare with what I've got ESQUIRE DEPOSITION SOLUTIONS
(954) 331-4400
74
there. So I mentioned the Palm Beach Police Department
report.
The next thing that I want to mention is the Jane Doe 102 complaint. In August of 2009, Bob Josefsberg -~ who is, from what I understood, a very well-regarded lawyer here in Florida; in fact, a lawyer that was selected by the United States Government to represent a number of the -- of the girls that had been sexually abused by Jeffrey Epstein. He was -- he was part of the procedure that was including the nonprosecution agreement.
In August of 2009, he filed a complaint on behalf of Virginia Roberts. That complaint indicated that Virginia Roberts had been sexually abused in Florida, in New York, and in -- in other places, as I recall. The thing that -- that I particularly recall was that Mr. Josefsberg had said, Virginia Roberts was abused by -- and he gave some categories of people.
He mentioned, I think, business people. He mentioned royalty, and he mentioned academicians. And so to tie into your question, I knew that Professor Dershowitz was an academician. And so what I was seeing now was, that according to a very, very respected attorney here in Florida, he had found Virginia Roberts to be credible, and had filed a lawsuit against ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400
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Mr. Epstein saying that she had been trafficked, sexually trafficked, you know, not just abused by Mr. Epstein, but now being forcibly sent to, you know, other people to abuse.
And in the categories of people that were sexually abusing her were academicians, and I knew that Mr. Dershowitz fell within that category of -- of being
an academician. The -~ that complaint also indicated that there might be flight logs that would show that Virginia Roberts had been sexually abused in these
various locations. And that started to indicate to me that there might be what the law refers to as a common
scheme or plan. And that, just as Virginia Roberts was
being trafficked to these powerful people in various
places, there might well be other girts.
And so I have mentioned a flight log, and let
you -~ you wanted to talk about Mr. Dershowitz. On --
on December 30th, 2009, I was aware that there was a
flight log showing Mr. Dershowitz flying with Tatiana,
who as far as I can tell was not a business person, was
not providing financial advice or something else.
I understood that Mr. Epstein was a
billionaire who was heavily involved in financial
issues. I knew that Tatiana was on a plane with
Mr, Dershowitz, and then there was also, if I recall ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400
76 correctly, working from memory as -~ as you were wondering about, there was a notation that Mr, Dershowitz was on a plane with one female.
And so I was -~ when I looked at that, I'm seeing Mr. Dershowitz on a -- on a flight with a woman who doesn't seem to be there for, frankly anything other than sexual purposes or something along those lines with Mr. Epstein, with Mr, Epstein, who is a sex trafficker, and with one female which seemed to me to be a potential entry for disguising international sex trafficking. So that was of concern.
I then began to look at, well, I wonder, how would I find out if Mr. Dershowitz had been abusing other girls? Let's see. I knew that Virginia Roberts had been forced to -~ to -- to -- to do this sort of thing.
MS. McCAWLEY: You're okay as long as
you're -~ if you're revealing something that's in an affidavit --
THE WITNESS: That's right.
MS. McCAWLEY: -- that she submitted, you're
fine.
THE WITNESS: Right. So -- so what...
Let's see. What did I want, at this point --
ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400
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