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Thereupon, PAUL G. CASSELL, having been first duly sworn, was examined and testified as follows: THE WITNESS: I do. CONTINUED DIRECT EXAMINATION BY MR. SIMPSON: Q. Good morning -- A. Good morning. Q. -- Mr. Cassell. As of December 30th, 2014, had you ever met with Virginia Roberts in person? A. Yes. Q. And how many times had you met with her in person? A. Once. When was that? Approximately May 2014. May of 2014? Yes. Who was present for that meeting? I'm just pausing for a second because I don't -- I think we're -- Q. 1-- I'mnot-- A. -- clearly not trying to get into ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 161
attorney/client communication.
Q. I’m not asking you for what was said at this point. I'm just asking you who was present. I'm going to ask you where it was, those kind of questions.
A. Sure. Yeah, The main person who was present was Bradley J. Edwards, my Co-Plaintiff in this case.
Q. Okay. And Miss Roberts obviously was present?
A. Yes.
Q. Anyone else present?
A. You know, there were -- this was at the Farmer, Jaffee office here, and so persons who were associated with the law firm were assisting, but those were the main people.
Q. Okay. Do you remember any of those other people associated with the law firm who were present?
A. Present for, you know, coming in and assisting, I believe Brad's assistant, Maria, was there, and perhaps others at the firm, but it was -- it was basically Brad and I.
Q. Was there anyone else who attended for the entire meeting or a substantial portion of the meeting?
A. No.
Q. Okay. How long did the meeting last?
A. Approximately all day.
ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400
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162
Q. And when you say "all day," what time period are you referring to?
A. 9:00 to 5:00.
Q. 9:00 to 5:00. Okay. And was that through lunch; you just stayed through eight hours; is that -- what's your recollection of that?
A. Yeah, I remember we were working very hard on ~~ on it, so I think we had, if I recall correctly, had lunch brought in and worked straight through that.
Q. Any other meetings in person with Miss Roberts before December 30th of 2014?
A. No.
Q. Any telephone calls with her that you -- you had, obviously, before December 30th, 2014?
A. I believe there were a couple of -- of telephone calls.
Q. And can you tell us when those were?
A. Let's see. Roughly September 2014. Give or take a month. I mean, you know, sometime after May and before December 30th.
Q. Okay. And were those telephone calls between just you and Miss Roberts, or was anyone else on the line?
A. No. It was just the two of -- just Miss Roberts and I.
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163
Q. Okay. And are you able to distinguish the calls in your mind as two separate telephone calls?
A. 1I--I think there were either one or two calls. I think there may have been two, but it -- it would not have been more than two that I can recall.
Q. Okay. How long did each of the telephone calls last?
A. Less than five minutes.
Q. I'm going to ask you a question now, but before you answer it, pause, because I believe you will
be instructed not to answer it --
A. Okay.
Q. -- but want to -- I think -- we disagree on the privilege --
A. Sure.
Q. -- we believe it’s been waived.
My question is: During the meeting, did you
discuss Professor Dershowitz?
MS. McCAWLEY: I'm going to object to any discussion of what my client told you during any situation where you were representing her as an -- an attorney.
MR. SIMPSON: So -- and I think we had an agreement yesterday, if you follow your own counsel's instruction on not answering, are you
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