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212 on this piece of the Alessi depo and it's not in the answers to interrogatories, it's hard for me to -- to give an answer to that. So -- so that's the -- that's the concern I have. MR. SIMPSON: I move -- I move to strike as nonresponsive. BY MR. SIMPSON: Q. My question went to whether -- let me back up. If -- if I'm -- unless I misunderstood you -- MR. SCAROLA: The question was: Did he recall the contents -- MR. SIMPSON: I'm asking the question. MR. SCAROLA: -- of the Alessi deposition, MR. SIMPSON: I'm withdrawing it. I will ask a new question. MR. SCAROLA: BY MR, SIMPSON: Q. LI understood you in your -- the long answer that you gave a while ago to suggest that Professor Dershowitz had either testified falsely or failed to
Okay. Thank you.
provide relevant information on which he was basing his testimony about Miss Roberts's arrest; is that right? A. Yes. Q. And that assertion would be incorrect if there's a deposition in this case that all the parties ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400
213 have that include that information?
MR, SCAROLA: Mr. Simpson, there was an express reference to an answer to interrogatory, and the absence of any reference to an arrest for theft in your client's sworn answer to interrogatory. That's --
MR. SIMPSON: We -- we --
MR. SCAROLA: -- exactly what the testimony was.
MR. SIMPSON: If you object to the form, please just object to the form. I think it's a proper question --
MR. SCAROLA: I -- I object -- MR, SIMPSON: -- in our discovery response. MR. SCAROLA: -~ I object to your
misrepresentation of the earlier testimony. I'm sure it was not intentional, and that's why I'm calling it to your attention so that we don't go down a rabbit trail.
MR. SIMPSON: I'm not going down any rabbit trail. I'm really -- objection to the form will preserve it.
BY MR. SIMPSON: Q. My question is whether you were aware at the time that Professor Dershowitz testified that, in fact, ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400
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214 Mr. Alessi had also testified previously about the arrest of Miss Roberts for stealing from her employer?
A. I didn't recall that. If that's in there, you're -- you're making a representation, and I know you're a fine lawyer, so I'll accept your representation.
I didn't recall that when he was testifying a -- a day or two ago on that subject. MR. SCAROLA: We have been going for about an hour. Is it time to take a break? Is that convenient for you? MR. SIMPSON: We can take a break now. THE VIDEOGRAPHER: We are going off the video record, 9:35 a.m. (Thereupon, a recess was taken.) THE VIDEOGRAPHER: We are back on the video record, 9:47 a.m. THE WITNESS: I need to take two minutes, if I may, and just supplement the long answer that I gave about the series of things. By looking over my checklist, I noticed that item 5 of the 12 items was not given during my testimony. I'm -- BY MR. SIMPSON: Q. I don't -- I'm not going to ask about item 5. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 215 It's in the record as part of your -- your -- your -- A. Iwould like to just supplement -- MR. SCAROLA: That's fine. That's fine. If you don't want to hear it, that's okay. THE WITNESS: I'd like -- MR. SCAROLA: Just as long as it’s noted that there was an inadvertent omission. THE WITNESS: Yeah.
BY MR. SIMPSON:
Q._ As part of -- I'm going to go back actually to --
A. Sure.
Q. -- the questions I was asking. One question about the -- the flight logs again.
A. Okay.
Q. It's true, is it not, that you have no personal knowledge as to whether Professor Dershowitz or some other member of Jeffrey Epstein's defense team
prepared those logs for production to the government?
A. I don't have personal knowledge of -- of that, that's right.
Q. And you would agree, would you not, that it's the duty of a defense counsel to represent a client zealously within the bounds of the law, correct?
A. Correct.
ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400
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