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264 that if you're in the presence of a convicted sex offender, or a sex offender and sex abuse is going on, you would have obligations, for example, at a minimum to report that, and it raises the possibility of other criminal activity as well.
Q. Is it your testimony, Mr. Cassell, that telling a person that multiple people have identified you as a witness to some activity is fair notice that you, yourself, are accused of engaging in criminal misconduct?
A. So--so you, I think, recharacterized the letter that went to Mr. Dershowitz in 2011. The letter, as I recall, doesn't say he is a witness. It says, if I recall -- we can double-check the language -~ but I believe the language says: Numerous witnesses have placed you in the presence of Jeffrey Epstein, underaged girls, and Epstein. Then, you know, so at that point, given what we know in this case, given that at that point in 2011, there had been an ongoing set of allegations against Mr. Epstein, I -- I think your question doesn't -- doesn't take into account this surrounding context.
Not to mention the fact there had been a 2009 deposition request and a 2013 document request.
Q. Okay. I think you accurately characterized ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400
265 the communication about the deposition request that
multiple persons have placed you in the presence --
A. Right.
Q. — -- of minors -~ A. Right,
Q. -- correct?
A. I believe that’s my recollection. Numerous witnesses have placed you in the presence of sex offend -- at that point, convicted sex offender Jeffrey Epstein, who was convicted of sexually abusing underaged girls, and underaged girls, and those are the subjects we would like to question you about.
And rather than getting a response that says, well, let me clear that all up, the response that's received was, something along the lines of, give me more information and -- and, quote: I'll decide whether I want to cooperate, close quote, or something along those lines.
Q. Mr. Cassell, let me -- I'm going to read to
you == A. Good. Q. -- from the letter itself -- A. Okay. Q. -- and tell me if it's consistent with your recollection.
ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400
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Page 264 to 267 of 335
266 MR. SIMPSON: I'm sorry. You were right, yes.
MR. SCAROLA: Can you just show it to him?
MR. SIMPSON: I'll read it, and then if he wants to look at it, that will be fine.
MR. SCAROLA: Thank you.
BY MR, SIMPSON:
Q. This is a letter from Mr. Scarola to Mr. Dershowitz dated August 23rd, 2011. The second sentence says -~ well, I'm going to read the whole thing.
MR, SCAROLA: Yeah, thank you.
BY MR, SIMPSON:
Q. "We do not" --
MR. SCAROLA: It's short, so it would be helpful if you just read the whole thing.
BY MR, SIMPSON:
Q. Yeah.
“We do not intend to inquire about any privileged communications or attorney work product. We do, however, have reason to believe that you have personally observed Jeffrey Epstein in the presence of underaged females, and we would like the opportunity to question you under oath about those observations. Thank you for
ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 267 your anticipated cooperation. Signed, Jack Scarola." If you would like to --
A. Sure.
Q. -- take a look at the letter to refresh yourself, you're welcome to.
A. Great. Thanks. Okay.
Q. Now, first, you're aware, are you not, that Professor Dershowitz answered that letter and said the assertion that he had observed Mr. Epstein in the presence of underage --
MR. SCAROLA: Females.
BY MR. SIMPSON:
Q._ -- females was not true?
A. Something along those lines, yeah,
Q. Yeah. And I will read it from that letter --
A. Okay. That would be good. Yeah, that would be great.
Q. And "I have never" -- this is a letter from Mr. Dershowitz to Mr, Scarola, August 29th, 2011.
“Dear Mr. Scarola, I have never personally observed Jeffrey Epstein in the presence of underaged females. I do not believe you have any reasonable basis for believing that I have. If you have ~- if you claim to have reason to
ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400
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