03:07:13
03:07:18
03:07:21
03:07:23
03:07:26
03:07:27
03:07:28
on A ah ON =
03:07:30
is)
03:07:33 03:07:33 10 ox07a3 14 030726 12 030728 13 oxo742 14 oxoras 15 oxor4a 16 oso749 17 03:07:53 18 osorss 19 030755 20 oxo7se 24 03:08:01 22 03:08:07 23 oxos10 24 03.081 25
03:08:17
03:08:22
03:08:22
03:08:25
03:08:26
03:08:29
03:08:31
ON Oak © DH =
03:08:32
is)
03:08:34 a30827 10 o30e4o 14 0308-41 12 ox0849 13 o30ss1 14 03:08:58 15 osos02 16 o30e02 17 o3x09:10 18 o0914 19 03:09:21 20 030921 21 030921 22 030928 23 o3.0030 24 03.0932 25
37 of 46 sheets
296 but, obviously, Epstein and his criminal associates have had the ability to -- to destroy the evidence that's been -- that we have been trying to gather.
Q. And in -- in your answer a couple of questions --
A. 1I--I'msorry. I shouldn't say "destroyed." They have been able to conceal would probably be a more accurate term, the -- the evidence that we are trying to gather.
Q. In my answer -- in my answer --
A. Yeah.
Q. -- in the question and answer, your answer to my question a couple of questions ago, you talked about whether Mr. Epstein and Virginia Roberts would have the same or equal ability to disclose --
A. Right.
Q. -- what these prominent politicians, et cetera, had done, correct?
A. Correct.
Q. Without attempting to make any comparison, you would agree, would you not, that as of December 30th, 2014, Miss Roberts had the ability to name the names of the people who are referenced in this document?
A. Physical ability, yes.
Q. And -- well, let me ask this: You say a
ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400
well-known prime minister. Is that Prime Minister Barak?
MS. McCAWLEY: I'm gonna instruct you not to reveal any attorney/client communications you had with Virginia Roberts on the specifics of her counsel to you about these individuals.
BY MR. SIMPSON:
Q. Is one of the other -- one of the powerful business executives, Les Wexner?
MS. McCAWLEY: Again, same instruction.
BY MR. SIMPSON:
Q. Okay. Now, you mentioned yesterday -- well, a moment ago, you testified that these -- in your view, these allegations about other powerful men furthered Miss Roberts’ legal position in the case, correct?
A. Yes.
Q. And it's also your position, I assume, that the allegations regarding Professor Dershowitz and Prince Andrew furthered Miss Roberts' legal position; is that right?
A. Absolutely.
Q. Does the fact that Judge Marra struck those allegations as impertinent, scandalous, and completely irrelevant to the case, cause you to reassess?
MR. SCAROLA: Excuse me. Is that -- is that
ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400
03:09:34
03:09:36
03:09:37
03:09:39
03:09:41
03:09:45
03:09:46
ON MD Oh WON =
03:09:48
iis)
03:08:50 03:09:50 10 03:09:54 11 oxooss 12 031000 13 oxr001 14 o3:10.01 15 0310001 16 03:10:01 17 oxto0s 18 o3:1005 19 031009 20 o3to13 21 03:10:15 22 03:10:17 23 031020 24 osto2s 25
03:10:27
03:10:28
03:10:29
03:10:31
03:10:31
03:10:32
03:70:34
On Oak WH «a
03,10:35
is)
03:10:37 oxt038 10 031041 14 oatoas 12 ostoss 13 oxt0s2 14 oxtos2 15 03:40:55 16 oattoo 17 oat. 18 oatto4 19 oatsor 20 03:41:10 21 ott 22 oats 23 oat? 24 otis 25
Page 296 to 299 of 335
intended to be a direct quote? MR. SIMPSON: Back up. BY MR. SIMPSON:
Q. What is your understanding of Judge Marra's ruling with respect to these allegations about Professor Dershowitz and Prince Andrew?
A. That they were premature.
Q. That's your understanding of his order?
A. Yes.
Q. Okay.
A. And I-- maybe I should -- I see some skepticism there, so let me explain why I think those allegations --
Q. Yeah. Well, we can pull -~
A. -- are appropriate.
Q. ~~ we will pull out the order itself --
A. Sure.
Q. _-- at the appropriate time, but first, your understanding is that the judge didn't find that those allegations, at the time they were made, were so irrelevant to the case, that they should be stricken from the public record?
A. Inthat pleading at that time, remember, we had in our -- our brief -- let me explain the -- the nine reasons why we thought that those allegations were
ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 299 relevant to the case, since I think your question calls for that.
Q. Are those the nine reasons you gave yesterday?
A. No, I didn't have a chance to.
Q. Are they the nine reasons that are set forth in your -- in your brief?
A. They are. Those are the nine reasons that are set forth in the brief.
Q. Okay. And -- and Judge Marra had that brief in front of him when he held that, these allegations were so not relevant to the issues before the court, that they would be stricken and not part of the public record?
A. At that time, in that particular pleading --
I think you're mischaracterizing Judge Marra's ruling in its entirety, He specifically said that the allegations could be reasserted, if they were relevant to issues that are -- that were coming up. And so, in following that ruling, we went to the U.S, Attorney's Office, propounded discovery requests and said, look, we believe you're sitting on information that Dershowitz was, you know, connected with the -- with the criminal trafficking here; we would like you to produce those documents.
ESQUIRE DEPOSITION SOLUTIONS
(954) 331-4400
10/20/2015 01:08:15 PM
HOUSE_OVERSIGHT_010877